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Prerequisite Programmes: The Foundation of an Effective HACCP Programme

By Stephanie Adams

Food & feed safety are paramount in today’s society, the application of Hazard Analysis and Critical Control Points (HACCP) principles is a cornerstone of any Quality Assurance & feed safety programme. The implementation of HACCP principles is also a requirement of The European Feed Hygiene Regulation, EU 183/2005. Prerequisite Programmes (PRPs) are defined as “practices and

conditions needed prior to and during the implementation of HACCP/ Food Safety Programme and are essential for food and feed safety”. The programmes can be, but are not limited to: sanitization, pest control, management of ingredients, utilities, waste disposal, sanitary design, sanitary operation, training, maintenance, bio-vigilance, security and personal hygiene. These may be programmes which are implemented because it is just good business but they also play a keep role in keeping food and feed hazards out of your pet food. Our world has also changed making bio-vigilance and security programmes necessary to keep pet and human food safe.

The goal: safe product. Without strong PRPs, as a foundation, a food safety system can crumble. The PRPs hold up the other key building blocks of a successful food safety Programme: Management Systems, HACCP, and Continuous Improvement. PRPs are the base for HACCP to be successful in controlling feed and food safety risks. PRPs are unique to each segment of the food chain. There is no

absolute list or regulatory mandate of prerequisite programmes that everyone must follow. The PRPs for infant formula are not going to be the same as for dog food but both need to produce safe food for the intended user and possible unintended user. Each facility food safety team must honestly evaluate the potential hazards for their product and determine which combinations of PRPs are right for them. PRPs are not critical control points. They do not have critical limits or clearly defined measurements which makes it hard for some

to understand their full importance. Prerequisite programmes support critical control points by preventing food safety hazards from occurring. Critical control points (CCPs) remove or reduce a food safety hazard to a safe level. Without PRPs you run the risk that every hazard would result in a CCP, which would lead to an unmanageable system. Successful prerequisite programmes will leave a big paper

trail of records and documentation. Records of completed activities are evidence that PRPs such as cleaning, inspections, validations, training and management food safety meetings are being followed. PRP documents will include standard procedures, (SOPs) validation studies, standards, and knowledge of regulations. Remember though, you can have detailed documentation and written SOPs but PRPs must be implemented in the field and have records to back up actual PRP activities. Never underestimate the importance of prerequisite Programmes in your food safety plan. Without active PRPS you leave your products open to unnecessary hazards and unnecessary risk.

A Case Study A facility manufactures pet food. They have identified metal foreign material as a pet food safety risk and have thus installed a foreign material screen, magnet and metal detector on the final product system. They have a prerequisite programme for incoming ingredients that includes inspecting the ingredients for foreign material and keeping a record of the inspection. However, the facility has not completed food safety or PRP training and the PRPs are not viewed or updated by the food safety team or a management team. Their metal detector was kicking out a significant amount of

finished pet food for metal contamination. No contaminated pet food was entering the market place, however it was costing the company to reprocess and discard product that was contaminated with metal. Metal was not found on the screen but was found on the magnet. A team was formed to investigate the cause of the metal contamination. They determined that the metal was coming from the front end of their


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