Research – The Effective Use of HACCP for the Control of Environmental Microbial Contamination by the use of Operational Prerequisite Programs – Russell Berg – November 2021

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When the concept of prerequisites was first formulated in the late 1980s there was no distinction in importance between them. In many ways this goes against the principle of HACCP, in which resources should be allocated according to risk. Hence greater control should be imposed at Critical Control Points rather than Control Points. In the early days of HACCP (but unfortunately still is often the case) this principle has been applied to the direct product pathway, but barely to the processing environment. In this sense in the U.K. all fourteen allergens are treated the same way, as far as legislation, but many food manufacturers do not treat all the allergens the same as far as environmental control. Very food factories exclude staff from bringing any of the listed allergens on to site, but many exclude peanuts and tree nuts from site. Hence the risk from all the allergens is not considered the same, so as far as allergen control. In these circumstances peanuts and tree nuts could be considered and controlled by Operational Prerequisite Programs (OPRP), whilst other allergens would be controlled by Prerequisite Programs (PRP), to reflect the risk level.

The concept of OPRPs was first introduced in ISO 22000:2005 to address this problem with environmental controls but created some confusion in that they would bean intermediate control between Control Points and Critical Control Points along the direct product pathway. By this definition the main difference between CCPs and OPRPs is that CCPs are critical for safe food whilst OPRPs are essential for food safety. A better term for OPRP would be ECP (Essential Control Point).When this standard was updated in ISO 22000:2018 more details were included in the definition about controlling OPRPs (either by measurement or observation) but the use of OPRPs was not clarified to avoid the confusion.

However Ismail in his LinkedIn article of 15thNovember 2019(Ref. 1)gave a good resolution to the problem by splitting food safety hazards into two categories. Type A hazards are introduced with the raw materials and are best controlled by Critical Control Points and (Process) Control Points along the direct product pathway. Examples of these are Campylobacter in poultry or E. coli in raw meat. Type B hazards are introduced from the processing environment, usually due to poor or inadequate GMP (Good Manufacturing Practice). These hazards are controlled by (Environmental) Control Measures(as part of PRPs) and the ones essential to food safety should be controlled by OPRPs Examples of these hazards are Staphylococci aureus from food handler’s hands and pathogens(microbes with the potential to cause harm)spread by flies. Unlike CCPs, which deal with contamination, multiplication and survival of microbial hazards, environmental OPRPs are only concerned with contamination of food with microbial hazards.

For the rest of this article we will be concerned with Type B microbial hazards.

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