BRC FOOD ISSUE 8 - Understanding The Requirements PDF

 

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BRC GLOBAL STANDARD FOR FOOD SAFETY ISSUE 8

CONTENTS Introduction

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Understanding the Requirements The BRC Global Standard for Food Safety Fundamental Requirements Within the Standard Section 1: Senior Management Commitment Section 2: The Food Safety Plan - HACCP Section 3: Food Safety and Quality Manual Section 4: Site Standards Section 5: Product Control Section 6: Process Control Section 7: Personnel Section 8. High-Risk, High-Care, and Ambient High-Care Production Risk Zones Section 9. Requirements for traded products

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BRC Food Issue 8 Audit Process BRC Audit Standards Audit Options Changes to Audit Requirements

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BRC GLOBAL STANDARD FOR FOOD SAFETY ISSUE 8

INTRODUCTION BRCGS is a leading brand and consumer protection organization, used by over 28,000 certificated suppliers over 130 countries, with certification issued through a global network of accredited certification bodies. BRCGS' Standards guarantee the standardization of quality, safety and operational criteria and ensure that manufacturers fulfill their legal obligations and provide protection for the end consumer. Certification to BRCGS' Standards is now often a fundamental requirement of leading retailers, manufacturers and food service organizations. The BRC Global Standard for Food Safety is the leading third-party certification standard worldwide with over 18,500 certified manufacturing sites. sites . There are six six BRC  BRC Standards including three for manufacturing, plus BRC Food, BRC Packaging, and BRC Consumer Products. These are in addition to BRC Storage and Distribution and BRC Agents and Brokers  and Retail. Retail. The BRC Global Standard for Food Safety is the leading third-party certification standard worldwide with over 18,500 certified manufacturing sites.

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BRC GLOBAL STANDARD FOR FOOD SAFETY ISSUE 8

BRC FOOD ISSUE 8 UNDERSTANDING THE REQUIREMENTS The BRC Global Standard for Food Safety

These requirements are crucial to the establishment and operation of an effective food quality and safety process. Failure to comply with a statement of intent of a fundamental requirement (i.e. a major nonconformity) nonconformit y) leads to non-certification at an initial audit or withdrawal of certification at subsequent audits. A further full audit will be required to demonstrate compliance.

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Senior Management Commitment The Food Safety Plan - HACCP Food Safety and Quality Management System Site Standards Product Control Process Control Personnel

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High-Risk, High-Care, and Products Ambient High-Care Production Risk Zones Requirements for Traded

Fundamental requirements within the Standard • • • • • • • • • • • •

Senior management commitment and continual improvement (1.1) The food safety plan – HACCP (2) Internal audits (3.4) Management of suppliers of raw materials and packaging (3.5.1) Corrective and preventive actions (3.7) Traceability (3.9) Layout, product flow and segregation (4.3) Housekeeping and hygiene (4.11) Management of allergens (5.3) Control of operations (6.1) Labelling and pack control (6.2) Training: raw material handling, preparation, processing, packing and storage areas (7.1)

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BRC GLOBAL STANDARD FOR FOOD SAFETY ISSUE 8

Section 1: Senior Management Commitment Commitment The fundamental stat statement ement of intent requires that the site’s senior management demonstrates demonstrates that they are fully committed to the implementation of the requirements of the Standard and to the processes which facilitate continual improvement improvement of food safety and quality management. Senior management needs to provide sufficient resources, both financial and human, to establish, maintain, and improve the food safety management system and associated infrastructure. This section of the Standar Standard d includes the need for a documented quality policy statement which defines the site’s obligations to produce safe, legal products and describes the site’s responsibilities to its customers. It also defines an agenda for management review meetings which need to be held at least annually. Other requirements include: •

Maintenance of certification: the site is obliged to have their audit within the audit window which is specified on their certificate. • The site must hold a copy of the Standard; either a hard copy or electronic. • Access to resources to ensure the site keeps up to date with scientific and technical developments, industry codes of practice, new risks to authenticity of raw materials, legislation in the country, production and country of sale. There is also a requiremen requirementt for corrective actions from previous audits to be addressed and verified to prevent recurrence. recurrence. Nonconformities that are carried over from one audit to the next may result in two non-conformities being raised, one for not effectively addressing addressing the root cause and escalation of the actual non-conformity itself from a minor to a major. This will inevitably impact the outcome of the audit and the grade awarded.

Section 2: The Food Safety Plan - HACCP The statement of intent is a fundamental requirement and requires the site to have a fully implemented food safety plan based on Codex Hazard Analysis & Critical Control Point (HACCP) (HACCP) principles. A HACCP system should be developed, reviewed, and managed by a multi-disciplinary team. The team should have knowledge of HACC HACCP, P, the products manufactured by the site, the processes employed, and the likely hazards. The HACCP team leader or nominated team representative needs to be able to demonstrate competence in the application of HACCP principles. Records should be maintained to show that key personnel identified as HACCP team members have adequate HACCP training and appropriat appropriate e experience. External expert assistance may be used to aid the development of the HACCP system; however, however, the site needs to demonstrate demonstra te that day-to-day implementation is being managed. Senior management needs to demonstrate demonstrate commitment to supporting the HACCP team.This is usually demonstrated demonstrated by a senior manager. The HACCP team needs to confirm the scope of the HACCP plan and conduct a hazard analysis identifying all the possible hazards, including those present in raw materials and those likely to be introduced or survive the process (including allergen risks). The team should determine the contro controll measures required to prevent, eliminate, or reduce hazards to acceptable levels and identify which hazards are managed via Critical Control Points (CCPs) and those that are managed prerequisites. The team should justify and document how acceptable levels of hazards are determined.

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BRC GLOBAL STANDARD FOR FOOD SAFETY ISSUE 8

Section 3: Food Safety and Quality Manual The management system needs to be fully implemented to meet the requirements of the Standard. Standar d. The syst system em will include procedures, work instructions, and records, records, and can be electronic or hard copy. There are requirements for document control and records maintenance. When defining how long records need to be kept, consideration consideration needs to be given to the shelf life of the product. The Standard requires that internal audits are carried out to a schedule with consideration given to the risks associated to the activity being audited. Audits should be spread throughout the year rather than undertaken as a multi-day annual internal audit. The internal auditor needs to be competent and independent of the area being audited. There needs to be a system in place to assign and track corrective corrective actions and verification or follow-up activities. This section also describes the processes for approval and monitoring of raw material suppliers and suppliers of services e.g. laundry, pest control, maintenance, cleaning and laborat laboratories. ories. There are also requirements that need to be met where parts of the production process or packing is outsourced to another organisation. The section also describes: •

Specifications management

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Corrective and preventative actions Control of a non-conforming product Traceability and the need for the site to test the system forwards and backwards at least annually. The exercise will also include a mass balance and should be achieved within four hours. The system will also be tested during the audit through a vertical traceability exercise. The auditor will select a complex product produced approximately two to five months before the audit and challenge the traceability. The challenge will be extended out to look at verification of the process flow, monitoring of CCPs, supplier approval, specifications (raw material, packaging, finished products and internal specifications), product release and testing, claim verification, and allergen management. Complaint management Management of incident product recall and withdrawal. This section of the Standard also includes the requirement for sites to test the procedure. This is different to the traceability test as it is looking at the capability of the procedure to operate under different scenarios; traceability will be one

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element of the test.

Section 4: Site Standards The auditor will spend approxima approximately tely 50% of the audit time in production assessing sections 4, 5, 6, 7, and 8. Section 4 covers many of the prerequisites including: • • •

External standards Site security and the need for a risk assessment and controls Layout, product flow, and segregation. Sites are required to use the decision trees within the Standard to determine whether areas are low risk, high care, high risk, or ambient high care.

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BRC GLOBAL STANDARD FOR FOOD SAFETY ISSUE 8

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Utilities, use of water, ice, steam, etc.

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Equipment Maintenance Staff facilities Chemical and foreign body control. For example, metal detection, x-rays, optical sorting, magnets, etc. Hygiene and housekeeping: the auditor will want to see a shift change over or production startup on day two. They may also ask to see inside equipment which is not in use but is clean and ready for use. Waste disposal Management of surplus food and products for animal feed: this is a new section recognising that surplus may be given to food banks or sold for animal feed. Pest management: frequency of inspections needs to be based on risk, and an annual detailed inspection is required. Staff need to be trained to spot the signs of pest activity and be aware of the need to report report evidence to the designated manager.

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Section 5: Product Control This section covers: • • •

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Product design and development, including review of HACCP, production trials, and assessment of shelf-life. Product labelling: this involves ensuring that labels meet legal requirements and that product claims (e.g. reduced sugar) are fully validated Management of allergens: the risk assessments which are to be carried out to determine the controls that need to be implemented and the information that needs to be communicated to the consumer. Where claims are made, validation and verification need to be undertaken. Product authenticity, claims, and chain of custody: sites need to undertake a vulnerability risk assessment on all raw materials or raw material groups to assess the potential for adulteration adulteration or substitution. The site needs to have access to sources of information to inform the risk assessment which needs to include historical evidence of substitution or adulteration, economic factors, ease of access to the materials in the supply chain, sophistication of routine testing, and the nature of raw materials. Where claims are made, for example MSC, halal, etc, current certification to the relevant scheme needs to be demonstra demonstrated. ted. Product packaging needs to be fit for use and comply with legal requirements. Evidence needs to be available to demonstrate that the packaging supplier has been made aware of any particular characteristics of the food e.g. high fat content, pH or usage conditions for example cook by microwave. Section 5 also includes requirements around product release and testing.

Section 6: Process Control There is a highlighted fundamental requirement aimed at reducing product recalls as a result of an incorrect logo being applied to the product. During the audit the auditor will, where possible, observe a product change-over. This section also includes requirements for: • •

Quantity, weight, volume, and number control Calibration and control of monitoring devices

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BRC GLOBAL STANDARD FOR FOOD SAFETY ISSUE 8

Section 7: Personnel This section includes requiremen requirements ts on the following: • Training and competency assessment for staff and agency staff • Personal hygiene rules • Medical screening for employees, agency staff and visitors • Requirements for protective clothing Subscription to BRC Participate, Participate, the BRC’s online subscription service, which will provide sites with access to all BRC Standards, Standards, guidance documents, and webinars. The website contains a lot of useful materials to help sites prepare for certification. Some of the guidance documents provide examples of how to set out the risk assessments required in the Standar Standard. d.

Section 8: High-Risk, High-Care, and Ambient High-Care Production Risk Zones Zones The Standard identifies a number of different production risk zones within the processing and storage stora ge facilities, with corresponding levels of hygiene and segregation to reduce the potential for product contamination with pathogenic micro-organisms. micro-organisms. The purpose of this section is to assure that the site is able to demonstrate demonstrate that production facilities and controls are suitable to preventt pathogen contamina preven contamination tion of products. Where a site produces products that require handling in high-risk, high-care and/or ambient highcare production facilities, all the relevan relevantt requirements from sections 1–7 of the Standar Standard d must be fulfilled in addition to the requirements in this section.

Section 9: Requiremen Requirements ts for Traded Products Where a site purchases and sells food products that would normally fall within the scope of the Standard Standar d and are stored at the site’s facilities, but which are not manufactured, further processed or packed at the site being audited, the site’s management of these products shall be cover covered ed by the requirements in this section, in the traded goods. Issue 7 introduced a traded goods module for sites that store and sell food products that are not manufactured, processed, or packed on site. Issue 8 has incorpora incorporated ted these requirements into the main text of the Standard (section 9). Section 9 will remain voluntary and any site with applicable products may opt into these additional requirements to demonstrate to customers that good management practices relating to traded products are in place. Sites wishing to be audited to section 9 should notify their chosen certification body in advance of the audit.

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BRC GLOBAL STANDARD FOR FOOD SAFETY ISSUE 8

BRC FOOD ISSUE 8 AUDIT AU DIT PROCESS BRC Audit Standards • • •

• • Issue 8 has been developed to specify the food safety, quality, integrity, and operational criteria required to be in place within a food manufacturing organisation to fulfil obligations with regards to legal compliance and protection of the consumer. The format and content of the Standard is designed to allow an assessment of a company’s premises, operational systems, systems, and procedures by a competent compet ent third party- the certification bodyagainst the requirements of the Standard.

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Learn: Visit the BRC Global Standards website, obtain a copy of the Standard, and study it. You may find the Interpretation Guidelines useful. Review: Perform a self-assessment gap analysis, assemble and train a team, and obtain consultancy if required. Prepare: Carry out risk assessments. Establish necessary control points, prepare pro cedures, confirm site is capable of meeting BRC requirements and undertake internal audits. Plan: Select and contact a certification body, arrange visit and implement any identified corrective actions. an optional pre-assessment Audit & Certification: Arrange an audit visit, ensure staff are available and preparations are made for the audit to be conducted. A non-conformity summary is left with the site at the time of the audit. The site needs to respond to the nonconformities. The auditor’s notes, full report and corrective action response are reviewed, and the certification decision is made. The audit report and certificate are uploaded to the BRC Directory. Sites provide their customers access  to their report and certificate via the Directory. Certified sites are also listed on the BRC public directory. Maintain: Continue to meet requirements, arrange a new audit before expiry and continue the development.

The latest issue of this BRC Global Standar Standard d focuses on: • • • • • • •

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Encouraging development of product safety culture Expansion of the requirements for environmental monitoring to reflect the increasing importance of this technique Encouraging sites to further develop systems for security and food defense Adding clarity to the requirements for high risk, high care and ambient high care production risk zones Providing greater clarity for sites manufacturing pet food Ensuring global applicability and GFSI benchmarking. Issue 8 focuses the audit towards the implementation of good manufacturing practices within production Increased emphasis on areas which usually have the highest rate of recalls and withdrawals, such as labelling and packing. Issue 8 continues to highlight management commitment and HACCP-based food safety programmes and supporting quality management system Providing a greater confidence in the food safety management systems and encouraging the development of a site’s wider food safety culture

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BRC GLOBAL STANDARD FOR FOOD SAFETY ISSUE 8

Audit Options Food manufacturers can opt for full certification which involves an announced audit and a fully unannounced audit. •

Announced audit: the site and the certification body agree the date of the date of the audit in advance. • Unannounced audit: the audit date is not communicated to the site in advance of the audit. There has been an increasing interest in unannounced audits among specifiers during the lifetime of Issue 7 as this has been seen to provide a greater confidence in the food safety management systems and encourage the development of a site’s wider food safety culture. The unannounced programme remains voluntary but provides added confidence in certification to customers and creates marketing marketing benefits where sites achieve the top BRC grade of AA+.

Changes to the Audit Requirements BRC Food Issue 8 sees the following changes within the audit requirements:

ADDITIONAL MODULES Issue 8 maintains the principles developed in Issue 7, to enable the incorporation incorpora tion of additional modules. These allow sites to elect to include additional requirements with their audit to meet particular customer, regional or scheme needs and reduce the number of site audits. BRC Global Standards will continue to develop such modules in response to market needs and make these available via the website.

Food Safety Culture • • •

Food safety culture is a fundamental factor in the management of product safety. Although challenging to audit, it is important that food safety culture is considered within a site and therefore within the requirements of the Standard. Sites shall plan to maintain and develop product safety and quality culture within the business.

Reporting Issues • •

Product safety is the responsibility of all staff – not just a select few. Therefore, all staff need to know how to report concerns and incidents.

HACCP/Food Safety Plan •

Some countries (e.g. the United States) have regulatory requirements that incorporate all HACCP processes outlined by Codex Alimentarius but use different terminology.

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Review wording for section 2 of the Standard on the HACCP Food Safety Plan to ensure compatible in all countries and geographies. Sites are required to meet the requirements of the Standard - specific terminology should not be an impediment to demonstrating compliance.

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Printed or Electronic?  Standard permits both hard copy copy and electronic files, file s, documents, and records – it is not prescriptive. prescriptiv e. Where documents are stored in electronic form these shall also be stored securely (e.g. with authorised access, acce ss, control of amendments, or password protected) protected) and backed up to prevent loss.

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BRC GLOBAL STANDARD FOR FOOD SAFETY ISSUE 8

Internal Audits Clause 3.4.1 amended to make sure that the safety management systems systems are being assessed in depth at regular intervals – at least four audit dates per year.

Supplier Approv Approval al • • •

Safety, integrity, legality and quality of raw materials are fundamental to the site’s operations. GFSI benchmarking All of the requirements are reviewed and updated to ensure rigorous control controls of raw materials whilst maintaining practical application.

Outsourced & Subcontract Subcontracted ed Processes P rocesses Definitions for outsourced processing are often confusing. It’s vital that food safet safety y is maintained throughout the whole production process. Statement Statement of Intent is updated to ensure clarity.

Incident Management • •

The incident management plan and procedures must be capable of addressing all types of incident. Effective communication is vital. Clause 3.11.1 is updated to include ‘failure of, or attacks against, digital cyber security.’ Significant food safety incidents (including product recalls & regulatory food safety non-conformity) must be communicated to your certification body.

Product Security & Food Defense Defense •

Rigorous food defense systems have gained renewed understanding and should form an integral part of factory protocols. • Procedures are adopted to assure the safety of raw materials and products from malicious contamination or theft. Threat (risk) assessment with actions (a plan) should be based on risk. Scope of the risk (threat) assessment should be the same as the process flow diagram (clause 2.5) i.e. all stages when product is under the management control of the site.

Environmental Environmen tal Monitoring BRC Food Issue 8 introduces an important tool for identifying potential contamination contamination risks. Sites are to develop a rigorous monitoring programme, enabling timely corrective action before product contamination contamination occurs. Monitoring of all factory production areas as a minimum area with open, ready-to-eat products. Risk-based programme should be developed, and pathogens, spoilage organisms, and/or indicator organisms should be considered.

Pest Management Requirements are amended from ‘control’ to ‘management’ ‘ management’. Birds must not enter buildings or roost in loading/unloading areas.

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BRC GLOBAL STANDARD FOR FOOD SAFETY ISSUE 8

Cooking Instructions ••

Vital on pack information for consumers – consumers expect and need a consistently safe product Cooking instructions can affect Production Risk Zones: - Where provided – i.e. not mandatory to have cooking instructions - Fully validated instructions

Labels & Packing Product recall/withdrawal data shows the underlying cause of the greatest number of problems is still associated with errors in labelling and packing. Whilst unlikely that mis-packing or mis-labelling will occur whilst the auditor is onsite, it is important that the Standard continues to promote best practice. • • • •

‘Change control’ is needed at goods receipt. Managementt of obsolete packaging is clarified. Managemen Onsite printing (e.g. date codes) needs to be controlled. Online verification equipment needs to be tested. Vertical audit is to be extended to include a comparison of the label with specification and recipe should form part of the audit.

Pet Food Pet food is within the scope of the Standard-animal feed is not. GFSI benchmarking introduced three new requirements for pet food (not applicable for human food).

Production Risk Zones • • • • • •

Requirements remain largely unchanged from Issue 7 to Issue 8 Equipment returned following maintenance Waste management Portable equipment Requirements have been relocated into a single, newly created, section of the Standard (section 8). Protocol and definitions reviewed and updated for increased clarity

Traded Products (formerly the traded goods module) Issue 7 introduced a traded goods module for products that are stored onsite but not manufactured, processed or packed onsite. Customers require clarity – are traded products onsite and have they been audited. This is now Section 9 of the Standard. • •

Provides clarity, accredita Provides accreditation tion and inclusion on the certificate. Section 9 is voluntary but opting out is considered an exclusion from scope.

Unannounced audits The option 2 unannounced audit (two-part audit) has consistently proven to be unpopular, with very few sites selecting this audit. It was therefore necessary to review the audit options. • •

The unannounced audit programme remains voluntary and sites can still continue to opt for an announced or unannounced audit. Option 2 unannounced audits have been removed, simplifying the options to just announced or unannounced.

Interim Reporting • • •

Following each audit an interim report shall be available on the BRC Directory within 10 calendar days. Contents strictly limited to date of audit, details of the audit scope and the non-conformities found. Final audit report will still be available after 42 days – this is currently being designed. 13

 

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