Why Updating PRPs Is Essential for HACCP 2020 Compliance
Here’s what I’ve noticed after working with factories transitioning from Codex 1997 to Codex 2020: most teams think the “HACCP update” is about CCPs and hazard analysis. But in reality, the biggest changes sit in the PRPs—your sanitation, allergen control, personnel hygiene, supplier programs, and facility-related controls.
In my experience, when PRPs aren’t aligned with Codex 2020, everything else becomes harder. You see it in audit findings, training gaps, inconsistent monitoring, and even unnecessary CCPs created just to compensate for weak foundational hygiene programs.
This guide walks you through exactly which PRPs changed, how they changed, and what you should update first. By the end, you’ll have a clear roadmap that strengthens your food-safety foundation and brings your HACCP system fully in line with Codex 2020 expectations.
Understanding PRPs Under Codex 2020 – What’s New, What’s Expanded, and Why It Matters
Codex 2020 puts far more emphasis on PRPs than the 1997 version ever did. The structure is clearer. The expectations are more detailed. And there’s a stronger connection between PRPs and hazard-control decisions.
When I review HACCP systems, this is usually where I see the biggest gaps. Teams still rely on generic or outdated PRP procedures—especially for sanitation, allergen management, and supplier control—even though Codex 2020 outlines specific requirements for each.
Pro Tip: Treat PRPs as formal, controlled programs with clear owners, monitoring, and verification—not as a “supporting appendix” to HACCP.
Common Mistake: Focusing only on updating CCPs while the hygiene foundation remains stuck in the 1990s. Auditors almost always start findings in the PRPs, not the CCPs.
Allergen Management PRPs – Strengthened Expectations Under Codex 2020
One of the biggest shifts in Codex 2020 is the expanded focus on allergen control. In the 1997 version, allergens weren’t emphasized the way they are now. Today, allergen management is non-negotiable.
Codex 2020 expects clear policies for segregation, storage, changeovers, validated cleaning methods, cross-contact prevention, and accurate labeling. When I help teams upgrade their PRPs, allergen control is usually one of the most impactful updates they make.
A bakery I worked with saw a significant drop in allergen near-misses simply by redesigning their flow and validating their cleaning steps. That’s the kind of improvement Codex 2020 aims for.
Pro Tip: Validate allergen-cleaning procedures. Don’t rely on “we’ve always done it this way.”
Sanitation & Cleaning PRPs – Updating Procedures, Frequencies, and Verification
Codex 2020 expects more structure within sanitation programs. It’s not enough to list cleaning tasks—you need validated methods, documented frequencies, and regular verification.
Sanitation SSOPs should now include: • What to clean • How to clean • Chemicals and dilution rates • Disassembly requirements • Pre-clean and post-clean inspections • Verification steps (swabs, ATP tests, visual checks)
What I’ve seen repeatedly is that companies clean frequently, but don’t validate or verify the effectiveness. Auditors zero in on this instantly.
Pro Tip: Include a quick pre-operation hygiene check before every shift. It catches issues early and shows auditors strong control.
Common Pitfall: Relying on “time-based cleaning” without evidence that it works.
Personnel Hygiene PRPs – Enhanced Controls for Behavior, Training, and Facilities
Codex 2020 strengthens expectations around personnel hygiene and behavior. This covers gowning, handwashing, illness reporting, hygiene zoning, training frequency, and supervisory oversight.
Some facilities still use hygiene rules from decades ago without adjustments for allergens, new product lines, or expanded zoning requirements.
A dairy plant I worked with drastically improved hygiene compliance by simply updating their handwashing flow and adding visual reminders. Small changes can have big operational impact.
Pro Tip: Add micro-training sessions on hygiene behavior. Short and frequent beats long and forgettable.
Facility & Equipment Design PRPs – Aligning Layout, Flow, and Construction with 2020 Standards
Codex 2020 expects a more intentional approach to facility and equipment design. This includes hygienic construction, zoning, airflow, drainage, material selection, and ease of cleaning.
Many plants have “legacy equipment” that wasn’t designed for modern hygiene expectations. During transitions, we often identify ergonomic or design issues that contribute to contamination risks.
Pro Tip: Map hygiene zones and match them with people, product, and waste flow. Poor zoning is one of the fastest ways to create cross-contamination.
Common Mistake: Assuming old equipment is acceptable simply because it’s been in use for years.
Supplier & Raw Material Control PRPs – Strengthened Requirements for Verification & Traceability
Codex 2020 expands expectations for supplier approval, raw material risk classification, COA checks, vulnerability considerations, and traceability.
You’re now expected to understand the hazards associated with each ingredient—not just trust supplier documentation.
A ready-to-eat facility I supported updated their supplier questionnaires to include allergen, microbiological, and fraud-prevention elements. Their supplier risk map became far more accurate.
Pro Tip: Re-screen suppliers using updated Codex 2020 categories. Some “low-risk” suppliers may no longer be low-risk.
Pest-Control Program PRPs – Improved Documentation, Monitoring & Evidence Expectations
Codex 2020 expects better control, oversight, and evidence when it comes to pest management. Even if you outsource pest control, you still own the program.
You should have: • Clear monitoring points • Trend charts • Service reports • Corrective actions • Risk-based response levels • Competency checks for the service provider
Pro Tip: Use trend graphs. Auditors rely on them to assess whether your pest-control system is improving or declining.
Common Mistake: Treating pest control as “the contractor’s job,” without internal review.
Codex 2020 is much more specific about water potability, compressed air, ice/steam quality, and waste separation. These utilities are often overlooked but directly affect product safety.
Facilities need clear specifications, maintenance records, test results, and verification procedures.
Pro Tip: Schedule routine water potability checks—even if your supplier provides certificates.
Verification could include environmental monitoring, internal audits, data trending, review meetings, or cross-checks.
Pro Tip: Use a PRP verification calendar. It keeps your team consistent and creates strong evidence for audits.
Common Pitfall: Collecting records without reviewing them regularly.
PRP Documentation & Record-Keeping – Updating Procedures & Forms for 2020 Alignment
Documentation is one of the easiest areas to fix—and the fastest way to show auditors you’ve aligned with Codex 2020.
This includes updating: • SOPs • Cleaning logs • Allergen controls • Supplier forms • Water and utility records • Personnel hygiene rules • Training materials • Glossary and terminology
Many teams are still using outdated forms from the 1997 era without realizing how much they need updating.
Pro Tip: Start by revising your PRP index. It instantly organizes the rest of your documentation.
FAQs – Updating PRPs for HACCP 2020 Compliance
Do we need to rewrite all our PRPs for Codex 2020?
Not entirely, but most PRPs need updates in structure, terminology, and verification steps.
Which PRPs do auditors focus on most?
Allergen control, sanitation, personnel hygiene, pest control, and supplier programs.
Can weak PRPs create CCP failures?
Yes—and it happens more often than people think. PRP gaps often show up as CCP issues.
Conclusion – Strengthening Your PRPs for Codex 2020
Updating PRPs is one of the most impactful steps you can take to strengthen your HACCP system. It improves audit results, enhances daily operations, and builds the foundation the 2020 Codex model expects.
After helping many facilities modernize their PRPs, I’ve seen how quickly performance improves once sanitation, allergen control, hygiene, supplier assurance, and verification programs catch up with today’s standards.
If you want, I can create a PRP Update Checklist or a full Codex 2020 PRP Manual Rewrite tailored to your facility.
Melissa Lavaro is a seasoned ISO consultant and an enthusiastic advocate for quality management standards. With a rich experience in conducting audits and providing consultancy services, Melissa specializes in helping organizations implement and adapt to ISO standards. Her passion for quality management is evident in her hands-on approach and deep understanding of the regulatory frameworks. Melissa’s expertise and energetic commitment make her a sought-after consultant, dedicated to elevating organizational compliance and performance through practical, insightful guidance.
