PRP, OPRP, PC or CCP: How Do You Classify HACCP Controls?

Product safety professionals are surrounded by terminology for controls: PRP, OPRP, PC, and CCP. Understanding what the abbreviations stand for is often the easy part. The harder question is: Which type of control should actually be applied to a particular hazard? That is where HACCP control classification can become difficult and inconsistent.

What are PRPs, OPRPs, PCs and CCPs?

The purpose of the control stage is to determine what is needed to prevent, eliminate or reduce identified hazards to an acceptable level.

The product safety plan may contain different categories of control, including:

• Prerequisite Programme controls (PRPs)
• Operational Prerequisite controls (OPRPs)
• Preventive Controls (PCs)
• Critical Control Points (CCPs)

The control stage also needs to consider how controls will be monitored, the limits that will be used and the corrective action required when those limits aren’t met. The difficulty is ensuring that the category assigned genuinely reflects the hazard and the level of control it needs.

Prerequisite programmes create the foundation

Prerequisite programmes provide the generic controls that support safe operations across a business. They can cover areas such as supplier management, specifications, equipment and maintenance, contamination control, hygiene, pest management, personnel, storage and dispatch, and training. These are the building blocks of the wider product safety management system.

However, complications arise because a broad programme can contain individual activities that are much more directly associated with the control of a specific hazard. This is one of the reasons control classification can become confusing. Businesses may already have procedures and programmes in place to manage product safety risks, but their existing names do not determine whether they should be treated as a prerequisite programme, operational prerequisite programme, preventive control or critical control point. The classification needs to reflect how the control manages the hazard within the product safety plan.

FSMA makes this distinction particularly important

Another difficulty arises when controls are defined before hazard analysis is complete.  If the business has always called something a PRP, there can be a tendency to continue treating it as a PRP. If something has always been listed as a CCP, there may be a similar reluctance to challenge it.

However, hazard analysis should establish the risk first and the required control should follow from that analysis. Starting with predetermined controls risks bending the hazard analysis around an existing system rather than designing the system around the actual hazards.

FSMA makes this distinction particularly important

Under FSMA, the likelihood of a hazard is assessed without preventive controls already assumed to be in place.

This creates a clearer separation between two questions:

What is the hazard and how significant is it?
and
What control does it need?

Assessing the hazard first, without assuming existing preventive controls are already managing it, helps ensure that the significance of the hazard is considered before the type of control is determined.

Why HACCP control classification needs to be consistent

Even when organisations understand the terminology, two different HACCP teams can sometimes classify an identical control differently. One may regard it as part of the prerequisite programme. Another may treat it as an operational prerequisite or preventive control. Another may regard it as a critical control point. The problem isn’t necessarily a lack of technical knowledge. Often, the problem is the lack of a consistent method for moving from the result of hazard analysis to the appropriate control classification. That is particularly important for businesses working across more than one framework.

The product safety plan will need to reflect Codex HACCP principles, GFSI-recognised certification requirements, customer or retailer standards and, where applicable, FSMA.

HACCP controls also need monitoring and limits

Assigning a control category isn’t the end of the control stage – a control has to work in practice. The team must consider how it will be monitored, what limits will be applied and what must happen if those limits aren’t achieved. Without those elements, the business may have identified a control without creating a practical system for managing it.

Focus on the hazard, not the label

The objective isn’t to maximise the number of CCPs in a HACCP plan, or minimise them, and it isn’t to fit every existing procedure into the category it has always occupied. The objective is to understand the hazard, and apply the level of control it requires.

PRP, OPRP, PC and CCP are useful terms because they allow different types of controls to be managed appropriately.

However, knowing the definitions isn’t the same as knowing how to determine which one applies – a methodology to do this is required. It needs a consistent, evidence-based approach — as the product safety plan must comply with Codex, certification and customer standards, and FSMA requirements.

Apply a consistent method to control classification

Understanding the definitions of PRPs, OPRPs, preventive controls and CCPs is important. The more difficult part is consistently determining which type of control should be applied to a particular hazard.

Our Level 3 HACCP for manufacturing course teaches a structured methodology for moving from the outcome of hazard analysis to the appropriate type of product safety control.

It helps learners understand how to assess the function of a control, how different control categories relate to the level of risk identified, and how to apply the approach consistently across different products, processes and regulatory frameworks.

The methodology is designed to work across Codex principles, GFSI-recognised certification standards, customer requirements and FSMA, helping businesses avoid relying on historic labels or individual interpretation when deciding whether a control should be managed as a PRP, OPRP, PC or CCP.

Find out more about our Level 3 HACCP for manufacturing course and the practical methodology it provides for control classification.