Understanding the Updates to the PRPs for Transport and Storage ISO 22002-5 & ISO 22002-100, A Practical Guide for Food Safety Managers

Understanding the Updates to the PRPs for Transport and Storage

ISO 22002-5 & ISO 22002-100

A Practical Guide for Food Safety Managers

Based on the webinar presented by

Lyndri, Food Safety Consultant & EO Builder — Entecom

Summary

The ISO 22002 Prerequisite Programme (PRP) standards have undergone a significant structural update in 2025. For organisations operating in transport and storage, this means two standards now apply in combination: ISO 22002-100:2025, which sets the common PRP foundation across the food supply chain, and ISO 22002-5:2025, which adds the sector-specific requirements for storage and distribution operations.

This guide is designed to help food safety managers working in logistics, warehousing, and distribution understand what has changed, what remains the same, and what practical steps are needed to align existing systems with the updated requirements.

The core message:

These updates are not a complete overhaul. If your site is already certified to FSSC 22000 or operates under the previous ISO/TS 22002-5:2019, most of your controls are already in place. The focus now is on alignment, justification, and demonstrating that your PRPs are effective in practice.

 What This Guide Covers

  • The new structure of ISO 22002 and how ISO 22002-100 and ISO 22002-5 work together
  • A clause-by-clause walkthrough of the updated PRP requirements from a transport and storage perspective
  • Key changes and what auditors are increasingly looking for as evidence
  • A practical implementation checklist to support your transition

Whether you are preparing for an upcoming audit, conducting a gap assessment, or simply updating your documentation, this guide provides a clear, practical starting point.

 Key Changes at a Glance

Before working through the details, it helps to understand the big picture. The table below summarises the most significant structural and content changes between the previous technical specification and the updated 2025 standards.

Area

Previously (ISO/TS 22002-5:2019)

Now (2025 Standards)

Standard Structure

Single standalone document (ISO/TS 22002-5:2019)

Two standards used together: ISO 22002-100 (common base) + ISO 22002-5 (sector-specific)

Document Status

Technical Specification (TS)

Full International Standard (IS)

Alignment with Codex

Based on Codex HACCP pre-2023

Fully aligned with Codex HACCP 2023 revision

Food Defence & Fraud

Limited coverage

Explicit clause requiring threat/vulnerability assessments and prevention plans

Justification of Controls

Controls expected, but reasoning is less explicit

Risk-based justification is now clearly expected for all PRPs

Traceability in Logistics

Basic traceability requirements

Strengthened identification, categorisation, and traceability of logistic units throughout storage and distribution

Product Recall

Listed as a standalone PRP clause

Moved to ISO 22000 management system level — not removed, but elevated

Monitoring & Verification

Controls expected to be in place

Clearer emphasis on demonstrating effectiveness, not just having procedures

The key shift in thinking:

The question is no longer ‘Which PRP document do I use?’ It is now: ‘How do I demonstrate effective, risk-aware prerequisite programmes using this new structure?’ This means moving from a documentation mindset to a demonstrable control mindset.

 

Part 1: Understanding the New Standard Structure

How ISO 22002-100 and ISO 22002-5 Work Together

For many years, transport and storage operations relied on ISO/TS 22002-5:2019 as the sole PRP reference document. The 2025 update changes this by introducing a layered framework:

ISO 22002-100:2025 — The Common Foundation

ISO 22002-5:2025 — Transport & Storage Specific

• Applies across the entire food supply chain

• Covers: building design, utilities, pest control, waste management, maintenance, personal hygiene, food defence, and corrective action

• Sets the baseline PRP requirements for all sectors

• Builds on top of ISO 22002-100

• Adds operational detail specific to storage, warehousing, and distribution

• Addresses: categorisation of goods, environmental control, logistic unit identification, and transport conditions

Think of it this way: ISO 22002-100 provides the foundation, and ISO 22002-5 adds the operational layer relevant to your specific processes. These two standards are applied together, not as alternatives.

Why Were the Standards Updated?

The update was driven by three key factors:

  • Evolving food safety risks — the updated framework addresses emerging global risks, including allergen management, intentional adulteration (food fraud and food defence), and cyber-related vulnerabilities in food safety systems.
  • Alignment with Codex HACCP 2023 — the revised standards ensure consistency between international hazard analysis principles and the way PRPs support those systems.
  • Harmonisation across sectors — rather than each sector developing PRP requirements independently, the ISO 22002 series now follow a common framework with sector-specific detail added through separate parts.

What This Means for Sites Already Certified to FSSC 22000

Important clarification:

ISO 22002-100 does not mean starting from scratch. If your site is already operating under FSSC 22000, most of your prerequisite programmes will already meet the intent of the updated requirements. What has changed is how those PRPs are structured, referenced, and demonstrated.

In practice, the transition involves three main focus areas:

  • Updating references — particularly procedures that still cite older PRP documents such as ISO/TS 22002-5:2019
  • Strengthening justification — being clearer about why certain controls are implemented and what risks they address
  • Demonstrating effectiveness — showing that PRPs are monitored, reviewed, and acted upon when deviations occur

It is also important to clarify that formal risk assessments are not required for every PRP. What is expected is risk-based thinking — controls that are appropriate to the risks at your site, supported by evidence that those controls are working.

Part 2: Clause-by-Clause Walkthrough

This section examines the key PRP clauses from a transport and storage perspective, highlighting what auditors are looking for and where expectations have evolved. The structure follows ISO 22002-100, with additions from ISO 22002-5 noted where relevant.

Clause 4 — Construction and Layout of Buildings

For most organisations involved in warehousing or distribution, this clause will feel familiar. The controls themselves have not fundamentally changed — what is different is the expectation that risks are clearly identified and controls are demonstrably effective.

Site Boundaries and the Surrounding Environment

The updated standard makes explicit what was previously implied: organisations must actively define and maintain site boundaries, assess contamination risks from the surrounding environment, and periodically review whether controls remain effective.

Examples of environmental risks relevant to transport and storage operations include:

  • Waste or recycling areas located too close to loading docks
  • Dust from nearby construction sites or high-traffic roads
  • Drainage flowing toward warehouse entrances
  • Outdoor pallet storage creating pest harbourage near building entry points

Building Design and Internal Layout

The facility must be designed and maintained to support the safe storage and movement of food products. Key questions an auditor will explore include:

  • Are goods protected during loading and unloading?
  • Does the building prevent contamination from external sources?
  • Are storage areas capable of maintaining appropriate conditions?
  • Is there adequate spacing between pallets and walls for cleaning and inspection?

Auditor focus areas:

Damaged floors in pallet storage areas, gaps around dock doors, damaged wall panels in cold rooms, and water accumulation near loading areas. These may seem minor operationally, but can quickly become pest, contamination, or hygiene risks.

 Clause 5 — Facilities and Workspace Layout

This clause focuses on ensuring that the facility layout minimises contamination risks and supports logical product flow. For storage and distribution environments, this typically means:

  • Clear separation of incoming and outgoing goods
  • Defined storage zones and segregation areas
  • Adequate space for pallet movement and inspection
  • Defined forklift routes to prevent damage to stored goods

Storage Segregation — A Common Audit Focus

Storage segregation is often one of the most visible areas during an audit because it directly affects contamination risk. Typical expectations include:

  • Dedicated chemical storage areas, clearly separated from food products
  • Separate zones for damaged, quarantined, or returned goods
  • Clear labelling of storage locations and defined pallet storage areas

While ISO 22002-5 does not introduce additional requirements in this area, the same principles apply — the layout must demonstrably support safe storage and handling.

Clause 6 — Utilities

Utilities are sometimes regarded as background systems, but they are among the most direct contributors to food safety risks if not properly managed. ISO 22002-100 provides clarity and structure on how utilities should be managed.

Water

Even in logistics environments, water is used in cleaning floors and loading bays, washing vehicles or containers, and defrosting cold storage areas. The key expectation is that water used around food products is of suitable quality and monitored where necessary. Non-potable water systems must be clearly identified and prevented from contaminating food or food-contact surfaces.

Ventilation and Air Quality

In warehousing, ventilation helps control moisture and maintain stable storage conditions. Condensation in cold rooms or loading areas is something auditors often notice quickly because it creates drip contamination risks. Key expectations include:

  • Ventilation systems that do not introduce contamination
  • Airflow that prevents condensation build-up around temperature-controlled areas
  • Managing dust in dry goods warehouses

Compressed Air

Where compressed air is used near food or packaging, the system must be appropriate for its intended use, specifications must be defined and monitored, and lubricants must be food grade where necessary.

Lighting

Adequate lighting is important for inspection and hygiene control, enabling personnel to detect damaged packaging, identify contamination, and carry out effective cleaning. In warehouse environments, auditors assess lighting levels in storage aisles and loading docks, and the protection of light fixtures against breakage.

Clause 7 — Pest Control

Pest control is now structured as a preventive, risk-based system in ISO 22002-100, rather than something addressed only when problems occur. The goal is not just to remove pests when they appear, but to identify and control the conditions that allow pests to enter or survive in the first place.

Note on numbering:

Pest control is covered in Clause 7 of ISO 22002-100. In the previous ISO/TS 22002-1:2009, it appeared as Section 12. This is worth noting when updating internal procedures, audit checklists, or cross-referencing older documentation.

Pest Prevention — The Most Effective Control

Preventing pest access is generally more effective than eradication. In warehouse and logistics environments, common pest entry points include:

  • Gaps around dock doors and damaged door seals
  • Openings around utility pipes and poorly sealed roller shutter doors
  • Vehicles inadvertently bringing pests into the facility

External pallet storage is a frequent audit finding. Wooden pallets stored outside can become harbourage for rodents and insects, and when brought inside, introduce pests directly into storage areas.

Removing Harbourage

Pests need food, water, and shelter to survive. In logistics environments, harbourage risks often come from:

  • Accumulated damaged stock and packaging waste
  • Standing water near loading bays
  • Cluttered storage areas and unused equipment stored outside
  • Spilt product under racking

Monitoring and Eradication

Monitoring programmes typically use bait stations, traps, insect monitors, and regular inspections. The key is not just placing traps — it is reviewing the monitoring data. Trend analysis can identify seasonal pest activity, recurring entry points, or areas where housekeeping improvements are needed. When activity is confirmed, the root cause must be addressed and the product protected, not just the pest removed.

Clause 8 — Waste Management

This clause was previously Section 7 in the older Technical Specification. The clause number has changed, which is important for document alignment and audit referencing. The intent, however, is to control waste, food loss, and recyclable materials to prevent contamination.

Waste Identification and Removal

In storage and distribution environments, waste typically includes damaged or leaking product, broken packaging, returned goods, spilt product, and general warehouse waste such as cardboard and plastic wrap. The expectation is that waste is clearly identified, collected, and removed regularly, stored in designated areas, and handled to prevent contamination of stored food products.

Food Loss and Waste (FLW)

The standard introduces the concept of FLW management, recognising that damaged or rejected product should be controlled and traceable to prevent it from accidentally re-entering the supply chain. For logistics sites, this means having clear procedures for handling damaged or rejected pallets.

Recyclable Materials

Recyclable materials such as cardboard, plastic wrapping, and pallets may be reused, but the key requirement is that these systems must not introduce contamination risks. Recyclable materials should be stored separately from food products, recycling areas should be kept clean and organised, and where materials are reused, traceability and inspection may be required.

Pest control link:

Poorly managed waste is one of the most common reasons pests become established around facilities. Waste management and pest control are closely linked — waste containers near loading docks or packing areas should be kept closed and secured.

Clause 9 — Equipment Suitability and Maintenance

In storage and transport operations, the relevant equipment typically includes forklifts, pallet-handling equipment, racking systems, refrigeration units, and vehicle-loading equipment. The expectation is that all equipment is hygienically designed where relevant, easy to clean and maintain, regularly inspected, and used according to manufacturer instructions.

Planned Preventive Maintenance

All equipment should be maintained through planned preventive maintenance, supported by documented schedules and records. In storage and distribution environments this typically includes:

  • Maintenance of refrigeration systems and temperature monitoring equipment
  • Servicing forklifts and handling equipment
  • Inspecting racking structures
  • Checking dock shelters and doors
  • Maintaining warehouse lighting and ventilation systems

Maintenance activities must not themselves introduce contamination risks. Areas should be cleaned after maintenance work, tools and debris removed, and equipment condition verified before returning to use.

Common audit check:

Auditors frequently request forklift maintenance records and refrigeration service reports. These should be readily available and demonstrate a pattern of preventive, not just reactive, maintenance.

Clause 10 — Purchased Materials

This clause focuses on how materials entering the facility from external suppliers are managed, verified, and controlled. For storage and logistics operations, purchased materials often include pallets, packaging materials, protective wrapping, cleaning chemicals, and sometimes transport containers.

Supplier Management

Organisations should have a defined process for evaluating and approving suppliers. The standard expects organisations to assess potential risks associated with suppliers, approve them accordingly, and monitor performance over time. In practice, this might involve:

  • Supplier approval lists and questionnaires
  • Certification verification (e.g., requiring food safety certification from chemical suppliers)
  • Performance reviews and tracking of complaints or non-conformances related to supplied materials

Incoming Goods Verification

Incoming goods should be checked before being accepted into storage or use. For logistics sites, this often includes:

  • Inspecting delivery vehicles for cleanliness and condition
  • Checking pallets for damage, contamination, or pest activity
  • Verifying packaging materials are clean and suitable
  • Confirming chemicals are correctly labelled and stored upon arrival

Clause 11 — Storage, Dispatch, and Transport Conditions

This section focuses on a highly operationally relevant area for transport and storage organisations. It explains how products are stored, prepared for dispatch, and the conditions that are maintained during transport.

Storage Conditions

Where products require specific storage conditions, appropriate parameters such as temperature, humidity, air quality, or filtration must be controlled. Three key principles apply:

  • Environmental control — temperature-controlled storage areas must be monitored, with corrective action taken if deviations occur.
  • Stock rotation — FIFO or FEFO systems help ensure products move through the facility in the correct order, reducing the risk of expired or deteriorated products remaining in storage.
  • Segregation — food products from chemicals, damaged goods from acceptable stock, and, where applicable, allergen-containing products from others.

Dispatch and Vehicle Inspection

Before loading, logistic units such as trucks, trailers, or containers should be inspected to confirm they are suitable for use. Typical checks include verifying that the vehicle is clean, in good condition, free from pests and odours, and — for temperature-controlled loads — that it is operating correctly before loading begins.

Transport Conditions

Vehicles used to transport food must be suitable for the product being carried and must be maintained hygienically. Where applicable, temperature, humidity, and protection from contamination must be controlled throughout the journey. Cleaning between loads is also important — a vehicle previously carrying chemicals or non-food materials must be properly cleaned and verified before being used for food products.

Key question for your operation:

Do you currently verify transport vehicles before loading? This should be formally documented. Vehicle inspection records and transport specifications are standard evidence that auditors will request.

Clause 12 — Prevention of Contamination

This clause urges organisations to proactively identify contamination pathways rather than just reacting when problems occur. In storage and transportation settings, this boils down to practical controls::

  • How products are handled and protected in storage
  • How chemicals are stored, segregated, and controlled
  • How damaged products are identified, isolated, and disposed of
  • How vehicles, equipment, and storage areas are kept clean and suitable

A useful way to think about this clause is the question an auditor might ask when examining your site: If I visited your facility today, what would physically prevent contamination from occurring — not what is recorded in your procedure? This shift in perspective, from documentation to actual operational control, captures the core of this clause.

Contamination Types in Storage and Logistics

The standard considers several contamination categories, all relevant to logistics environments:

  • Physical contamination — from damaged pallets, broken packaging, or warehouse infrastructure issues. Controls include good housekeeping, inspection practices, and proper maintenance.
  • Chemical contamination — from cleaning chemicals, pest control products, lubricants, or fuels. These must be stored, handled, and controlled to prevent product contamination.
  • Allergen contamination — where products containing allergens are stored together, transported in shared vehicles, or where cross-contact could occur through damaged packaging.
  • Microbiological contamination — primarily controlled indirectly in logistics through appropriate storage temperatures, clean transport vehicles, and protection from environmental exposure.

Clause 13 — Cleaning and Disinfection

This clause has evolved from a task-based mindset to a programme mindset. The emphasis is not just on ‘we clean’ but on demonstrating that cleaning is planned, documented, verified, and consistently effective.

Cleaning Programme Structure

Cleaning programmes in storage and transport environments typically cover warehouse floors and storage areas, loading docks and dispatch areas, forklifts and handling equipment, storage racks, and transport vehicles. The programme should clearly define:

  • What needs to be cleaned and how often
  • Who is responsible for each cleaning task
  • The chemicals and tools to be used
  • How the cleaning activity is verified

Cleaning Agents and Tools

Cleaning chemicals must be approved for use in food environments and used in accordance with the manufacturer’s instructions. Equally important is the condition of cleaning tools — worn brushes, damaged squeegees, or contaminated cloths can spread contamination rather than remove it.

Auditor focus:

Auditors increasingly look not just at whether you have a cleaning schedule, but at whether it reflects what actually happens on site and whether verification is carried out consistently. Behaviour in practice, not just procedures on paper, is the new benchmark.

Clause 14 — Personnel Hygiene

Even in storage and transport environments where food is not directly handled, people can introduce contamination through poor hygiene, improper behaviour, or unsuitable clothing. This clause focuses on ensuring that personnel behaviour actively supports food safety.

Hygiene Facilities

Employees must have access to adequate handwashing stations, toilets, changing areas, and storage for personal belongings. These facilities should be conveniently located and — critically — should not open directly into storage or operational areas.

Protective Clothing and Workwear

In storage and distribution environments, appropriate workwear may include high-visibility clothing, protective jackets, gloves, and hair covering, where applicable. Workwear should be fit for purpose, used correctly, and not worn outside designated areas where external contamination could be introduced.

Personal Behaviour and Prohibited Practices

Clear rules and consistent communication are essential. The standard expects controls over:

  • Eating, chewing gum, or smoking in operational areas
  • Carrying personal items such as phones or personal food into work areas
  • Wearing jewellery or artificial nails in product-handling areas

Health and Illness Reporting

Procedures for reporting illnesses and managing injuries should be in place, with employees understanding when they should not enter certain areas. These procedures should also align with relevant regulatory requirements.

Visitors and Contractors

Visitors and external service providers should be instructed on hygiene requirements, supervised where necessary, and provided with appropriate protective clothing. Everyone entering the facility must follow the same hygiene expectations.

Clause 15 — Product and Consumer Information

ISO 22002-100 strengthens the expectation that product information should help prevent consumer misuse, not just list ingredients or allergens. Labels should clearly communicate storage conditions, handling instructions, preparation or cooking requirements, and shelf-life information.

For logistics sites, these requirements are usually managed by the manufacturer or product owner. However, the supply chain plays a critical role in protecting that information. This means:

  • Ensuring labels remain legible and undamaged throughout the storage and distribution process
  • Preventing product mix-ups between similar lines
  • Maintaining the storage conditions specified on the product label

Clause 16 — Allergen Management

Allergen management is primarily addressed within food manufacturing environments, where allergens are actively processed or handled. However, this clause remains relevant for transport and storage operations, particularly where allergen-containing products share storage space, handling equipment, or transport vehicles with non-allergen products. The risk of cross-contact in logistics settings is real and increasingly scrutinised during audits.

When Does Allergen Management Apply in Logistics?

In a transport and storage context, allergen risks typically arise in the following situations:

  • Products containing allergens are stored alongside products that do not, without adequate segregation
  • Allergen-containing and allergen-free products are transported in shared vehicles without a verified cleaning and inspection procedure between loads
  • Damaged packaging allows allergen-containing product to spill or transfer onto adjacent goods during storage or transport
  • Repacking or consolidation activities involve mixed product types where allergen identity could be lost or confused

Key Controls for Storage and Distribution

The standard expects organisations to identify allergen risks within their operations and implement controls proportionate to those risks. In a logistics context, practical controls typically include:

  • Physical segregation of allergen-containing products within the warehouse, using clearly defined and labelled storage zones
  • Clear product identification on all logistic units, including allergen status where applicable, maintained throughout storage and distribution
  • Defined procedures for handling damaged goods where allergen-containing product may have been compromised, including isolation, investigation, and disposal
  • Transport vehicle cleaning and verification procedures when vehicles are used for both allergen-containing and allergen-free products
  • Staff awareness and training on allergen risks, including how to identify allergen-containing products and what to do if cross-contact is suspected

FSSC 22000 Additional Requirements

For organisations certified to FSSC 22000, allergen management requirements are further strengthened through the scheme’s additional requirements. These place greater emphasis on allergen risk assessment, documented controls, and evidence of staff competency. Logistics sites operating within an FSSC 22000-certified supply chain should ensure their allergen controls align with these expectations, even where direct food handling does not occur on site.

Auditor focus for logistics sites:

Auditors will typically ask: Do you know which products in your facility contain allergens? How are they identified and segregated? What happens when packaging is damaged? Can you demonstrate that your transport vehicles are cleaned and verified between allergen and non-allergen loads? Having clear, documented answers to these questions is the baseline expectation.

Clause 17 — Food Defence and Food Fraud

This clause introduces two related but distinct concepts that are new to many organisations in the logistics sector. Both deal with intentional risks — situations where someone deliberately attempts to compromise the food supply chain.

Food Defence

Food Defence focuses on protecting products from deliberate acts intended to cause harm. Organisations must perform a threat assessment to identify areas of vulnerability. For storage and transport environments, examples include:

  • Unauthorised access to warehouses or storage areas
  • Tampering with products during storage
  • Access to vehicles or containers during transport

Based on this assessment, organisations develop a Food Defence plan and implement controls such as restricted access areas, visitor controls, staff awareness training, and monitoring of high-risk areas.

Food Fraud

Food Fraud focuses on economically motivated deception — substitution, mislabelling, counterfeit products, or dilution of contents. Organisations must conduct a Food Fraud vulnerability assessment to identify where these risks could occur within their supply chain. For storage and transport operations, this may involve:

  • Product substitution during distribution
  • Tampering with packaging
  • Unauthorised product movement

Practical guidance:

You do not need a highly complex security system. Auditors want to see that you have actively thought through where you would be vulnerable if someone tried to compromise your products. Annex guidance in the standard can help structure this thinking without reinventing the wheel.

ISO 22002-5: Sector-Specific Requirements for Transport & Storage

The final part of the combined standard covers requirements specific to logistics operations. Unlike many earlier clauses, where ISO 22002-5 provides limited detail, this section introduces practical controls that are unique to storage and distribution environments.

Categorisation of Goods

Products must be categorised and managed, so they are stored under appropriate conditions. This may include separating products based on temperature requirements, allergen risks, product compatibility, or regulatory requirements. Storage practices must be documented and implemented consistently.

Environmental Monitoring in Storage and Transport

Where products require specific conditions, monitoring systems must be in place to detect when limits are exceeded. Automated monitoring is preferred because it provides continuous data and alerts. Where manual monitoring is used, it must occur at defined intervals and be fully recorded. Monitoring equipment must be calibrated and maintained to ensure accurate readings.

Identification of Logistic Units

All logistic units and picked goods must have clear identification to support traceability throughout storage and distribution. This identification should allow retrieval of:

  • Product identification and quantities
  • Supplier information and receipt dates
  • Expiry or best-before dates
  • Temperature or storage requirements
  • Non-conforming or quarantined status

Maintaining Identification Throughout Logistics Operations

Product identification must not be lost when goods are picked, repacked, consolidated into new logistic units, or moved between storage locations. Delivery and transport records form an important part of maintaining traceability throughout the supply chain.

A Note on Product Recall

You may notice that product recall no longer appears as a standalone PRP clause in ISO 22002-100. This is not an oversight — recall has been intentionally moved and elevated within the ISO food safety framework.

Recall is now addressed within ISO 22000 at the management system level rather than as a prerequisite programme. The reason: recall is not a hygiene control like cleaning or pest management. It is a crisis management and food safety governance process that requires leadership involvement, cross-functional communication, and coordinated response.

What auditors still expect to see:

A documented recall procedure (under ISO 22000 / FSMS)

A current recall team and contact list

Evidence of recall testing or mock recalls

Demonstrated traceability, speed, and effectiveness

Clear linkage between complaints, incidents, food fraud, allergens, and recall escalation

Being removed from PRPs does not mean being removed from audits. Recall has simply moved to a higher level of accountability. A recall procedure that has never been tested under pressure remains one of the most common major non-conformances encountered during audits.

Part 3: Implementation Checklist

Use this checklist to guide your transition to the updated ISO 22002-100 and ISO 22002-5 requirements. It is intended as a starting point for a gap assessment — focus on areas where your current documentation or operational controls may need strengthening.

How to use this checklist:

Don’t approach this as a rewriting exercise. Start by mapping your existing PRPs to the new clause structure — most requirements are still present, just grouped differently. Focus first on areas with real operational risk and visible gaps, rather than aiming for perfection on every point at once.

Documentation and Structure

Action Item

Priority

Update all PRP procedure references from ISO/TS 22002-5:2019 to ISO 22002-100:2025 and ISO 22002-5:2025

High

Confirm that your PRP system covers both ISO 22002-100 (common) and ISO 22002-5 (sector-specific) clauses

High

Align internal audit checklists and clause references with the updated numbering (e.g., pest control is now Clause 7, not Section 12)

Medium

Ensure the justification for each PRP is documented — why the control is in place, not just what it is

High

 

Construction, Facilities, and Layout

Action Item

Priority

Define and document site boundaries, including a site plan identifying potential contamination risks from the surrounding environment

High

Review building condition for issues such as damaged floors, gaps around dock doors, wall panel damage, and water accumulation

High

Confirm storage segregation is clearly defined for chemicals, quarantined goods, allergen-containing products, and damaged stock

High

Verify forklift routes and product flow do not create contamination or damage risks

Medium

Utilities and Environmental Control

Action Item

Priority

Confirm water quality monitoring is in place where water is used around food products or food-contact surfaces

Medium

Review ventilation controls in cold stores and loading areas to address condensation risks

High

Verify compressed air specifications and food-grade lubricant requirements where applicable

Medium

Check that temperature monitoring in storage and transport is automated or formally documented at defined intervals

High

Confirm monitoring equipment is calibrated and calibration records are current

High

Pest Control

Action Item

Priority

Review pest control programme to ensure it is structured as a preventive, documented system rather than reactive response

High

Inspect all external pallet storage areas for harbourage risks and establish controls

High

Confirm pest monitoring data is reviewed and trended, not just collected

Medium

Verify pest control contractor reports include species, locations, and corrective actions

Medium

Waste Management and Maintenance

Action Item

Priority

Confirm waste containers are adequate, labelled, and secured to prevent pest attraction

Medium

Establish or review a procedure for managing damaged or rejected pallets and food loss

High

Review planned preventive maintenance schedules for refrigeration units, forklifts, racking, and dock equipment

High

Confirm post-maintenance verification procedures are in place before equipment returns to use

Medium

Supplier Management and Incoming Goods

Action Item

Priority

Confirm all key suppliers (pallets, chemicals, packaging, pest control) are on a risk-based approved supplier list

High

Review incoming goods inspection procedures for pallets, packaging materials, and chemicals

High

Ensure supplier performance is monitored and reviewed periodically

Medium

Storage, Dispatch, and Transport

Action Item

Priority

Confirm FIFO or FEFO stock rotation systems are in place and actively followed

High

Review vehicle/container inspection checklists to ensure they cover cleanliness, condition, pest, odour, and temperature (where applicable)

High

Confirm cleaning-between-loads requirements are documented for vehicles transporting multiple product types

High

Verify that logistic unit identification (product ID, quantities, dates, storage requirements, non-conforming status) is maintained throughout storage and distribution

High

Allergen Management

Action Item

Priority

Identify all allergen-containing products stored or transported through your facility and document a current allergen register

High

Confirm allergen storage segregation is physically implemented with clearly labelled and dedicated storage zones

High

Establish a procedure for handling damaged allergen-containing goods, including isolation, investigation, and disposal steps

High

Confirm transport vehicle cleaning and verification procedures are in place for vehicles carrying both allergen-containing and allergen-free products

High

Verify staff training records cover allergen awareness, including product identification and what to do when cross-contact is suspected

Medium

Food Defence and Food Fraud

Action Item

Priority

Conduct or review a Food Defence threat assessment covering warehouse access, vehicle security, and high-risk areas

High

Develop or update a Food Defence plan with documented controls and staff awareness training

High

Conduct or review a Food Fraud vulnerability assessment for your supply chain activities

High

Establish a Food Fraud prevention plan and integrate it with supplier management and traceability controls

High

Hygiene, Cleaning, and Personnel

Action Item

Priority

Review cleaning programmes to confirm they are structured as documented schedules with verification, not just task lists

High

Confirm cleaning chemical approval and that tools are maintained in hygienic condition

Medium

Review hygiene facility adequacy for number, location, and condition of handwashing stations

Medium

Confirm workwear requirements, PPE, and prohibited behaviour policies are communicated and observed in practice

Medium

Ensure visitor and contractor hygiene induction procedures are in place and followed

Low

Product Recall

Action Item

Priority

Confirm that recall is addressed at the ISO 22000 management system level (not just as a PRP)

High

Verify recall procedure includes a current team list, communication protocols, and customer notification timelines

High

Conduct and document a recall test or mock recall, including traceability speed measurement

High

Confirm clear linkage between complaints, food fraud alerts, allergen incidents, and recall escalation

High

Final Thoughts

Auditors are not expecting a brand-new system. They are looking for alignment, understanding, and consistency — a system that makes sense for your business, where risks are genuinely understood, and where controls demonstrably work in practice and not just on paper.

The most effective way to approach this transition is not clause-by-clause rewriting, but risk-based prioritisation. Start by mapping your existing PRPs to the new structure, then focus first on areas with real operational risk — storage conditions, vehicle controls, traceability, food defence, and supplier management.

A thorough self-assessment is one of the most effective tools in this process. When reviewing your system, don’t just ask ‘do we have a procedure?’ — instead, ask: Does it reflect reality? Is it consistently implemented? Can we provide evidence? If your team can explain the reasoning behind your controls, that’s usually where audit confidence is built from.

The single most important takeaway:

Focus less on wording changes and more on how people, processes, and risks connect in your operation. That is where compliance and food safety actually meet.

This guide was produced by Entecom based on the ISO 22002-5 & ISO 22002-100 webinar series.

For further support with gap assessments, documentation, or EO system implementation, contact Entecom at info@entecom.co.za

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