Here’s a simple assessment for you; compare all the non compliances you have received from both Internal audits and External audits over the past two years and categorising them into the following;
Still getting a number of non compliances raised against Pre Requisite Programs?
Yes, as auditors we are seeing this also.
In general, most sites have their HACCP / CCPs adequately developed and there are not so many CCPs non compliances raised in audits now. However, there are still large numbers of non compliances being raised against Pre Requisite Programs; e.g. non compliances on Hygiene issues, Pest control issues, Personnel hygiene issues, Structure & Fabrication issues, Traceability issues.
By categorise these Pre Requisite Program non compliances further, you can determine which PRPs need further development or verification and where additional training against such PRPs may be required.
You may also want to develop a Pre Requisite Program improvement plan, targeting improvements on certain Pre Requisites across all or certain areas of your site.
There are good guideline documents for use or reference; Regulation 852/2004, Annex II, BS EN ISO22000:2005, FSSC 22000 and of course BRC Global Standard for Food Safety, issue 7
As most Food Processing sites in Ireland are working to the BRC Global Standard for Food Safety, issue 7 for their main site certification, as an initial guide look at the Fundamental Requirements (as listed on page 9 of the standard).
We can see many of the ‘basic’ Pre Requisite Programs listed against Fundamental clauses ; Management of suppliers of raw materials and packaging (3.5 – new fundamental clause), Traceability (3.9), Layout, product flow and segregation (4.3), Housekeeping & hygiene (4.11), Management of allergens (5.3), control of operations (6.1), Labelling and pack control (6.2 – new fundamental clause)
One way to improve on the overall performance of your Food Safety System and in turn improve on audit performance, can be developing your Pre Requisite Program and ensure that all PRPs are correctly validated initially and then verified on a routine basis.
Learn more about what you need to know on Pre Requisite Programs on our HACCP Development, Implementation & Verification training course………
Submitted by our Food Safety Tutor, Brian Robinson
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