What are Prerequisite Programmes?
Food businesses must have prerequisite programmes in place before developing the HACCP plan. Prerequisite programmes are essential practices and conditions (environmental and operational) that are necessary to provide food that is safe to eat. This term is also commonly referred as either ‘good manufacturing practice’ or ‘good hygienic practice’. Prerequisite programmes are the foundation of HACCP, and control general low risk hazards that occur throughout the food chain. The failure of a prerequisite may not necessary have an immediate objectionable or harmful effect on the safety of food.
Prerequisite programmes must meet all regulatory requirements as a minimum standard. These programmes mainly include: approved suppliers, premises (design, facilities and equipment), control of operation, maintenance, cleaning and disinfection, personal hygiene, training, maintenance, calibration of equipment, pest control, waste management, contingency plans, traceability, etc. Prerequisites programmes that are already in place do not necessarily mean they are effective in supporting the HACCP plan and meeting a specific requirement. There may be gaps in existing standards in place compared to what is required externally. The HACCP team must consider appropriate reference documentation such as regulatory requirements, national and international sector standards, customer specifications and technical standards for certification schemes (BRC, SALSA and FSSC 22000). Once standards have been established a baseline audit conducted by a competent auditor will identify any potential gaps.
What are Operational Prerequisite Programmes?
Operational prerequisite programmes (OPRP’s) are a requirement for FSSC 22000 and sit in between prerequisite programmes (PRP’s) and critical control points (CCP’s). These activities control hazards at a specific process step as opposed to PRP’s which manage them across the entire food operation. Operational perquisite programmes are identified in the hazard analysis as essential control measures in preventing contamination in products or in the process environment. For example: targeted cleaning of a shared production line. They can also be classified as control measures where continuously monitoring or setting observable critical limits are difficult to achieve. Confusion can arise in the identification and justification for OPRP.A decision tree is a useful tool that can help determine whether a specific hazard identified during the hazard analysis is controlled by a PRP, OPRP or CCP. Campden BRI have produced a simple to use decision tree (HACCP: a practical guide). The decision and justification for an OPRP must be recorded.
Validation, Monitoring and Verification
For prerequisite programmes and operational prerequisite programmes to be effective they must include validation, monitoring and verification.
Validation is about obtaining evidence that PRP’s and OPRP’s are effective in controlling hazards. This may require benchmarking against reference documentation (e.g. published scientific studies) and conducting further tests. Cleaning and disinfection, for example, may require obtaining evidence that chemicals and the process can reduce pathogenic bacteria to an acceptable level.
Monitoring is important because it can identify if a standard has been achieved or not. This provides an opportunity when a deviation occurs to take the appropriate corrective actions to regain control. Complete and accurate monitoring records demonstrate standards have been achieved and can support a ‘due diligence defence’. Methods of monitoring may include organoleptic assessments, observations, visual inspections, checking records, asking questions, and taking measurements (testing).
Verification activities, in addition to monitoring, demonstrate prerequisite programmes are working in accordance with set standards. These activities include compliance audits, testing, reviewing documents and records. They can be completed by someone internally who does not conduct day to day monitoring, such as supervisor or manager, or externally by a competent auditor.
Percipio Training discuss prerequisite programmes and operational prerequisite programmes on all its accredited Food Safety and HACCP courses. We offer open courses in Milton Keynes, London and Corby. Contact us by email or call 01296 320247. Our prices are the most competitive on the market.