In 1998 the British Retail Consortium (BRC) developed and introduced the BRC technical standard and protocol for companies supplying retailer branded food products.
The BRCGS Food Safety Standard Issue 9 was published in August 2022 with auditing against the standard commencing in February 2023.
After 8 previous issues of any prescriptive standard there is a need for a somewhat different approach to Food Safety. The strength of the BRCGS Standards is that they are prescriptive and tell food business operators (FBOs) what to do which does reduce ambiguity and provides clarity, however other standards like FSSC tend to be more objective based. The objective based approach tends to place a great responsibility on FBOs to think for themselves with regards to risk management and devise systems and procedures that protect their customers, consumers and hence their own business. For mature companies who have received certification against the previous 8 issues what can issue 9 bring?
Section 1 – Senior Management Commitment is really pushing the Food Safety Culture agenda. The recent amendment to food hygiene regulation 852/2004, commission regulation (EU) 2021/385, Chapter XI(a) legally defines Food Safety Culture expectations and responsibilities. A well designed Food Safety Culture Plan addressing the five elements of culture : Values, Processes, Leadership, Brand Protection and Behaviours will not only satisfy 3rd party auditors from BRC Certification bodies, customers and competent authorities but will also cement the non-negotiable food safety practices of the business. An interesting addition to Clause 1.2 is the ability of staff to request an assessment of training needs for activities they carry out. The requirement to make employees aware of the need to report any unsafe or out of specification product or raw material for immediate action also places greater responsibility on the FBO.
Section 2 is largely unchanged however Clause 2.12.1 has been added to emphasise the importance of validation.
Section 3, the fundamental clause of Internal Auditing has been expanded to address the Food Safety Culture Plan. Authenticity is again very much to the forefront in Clause 3.5, Supplier & Raw Material Approval and Performance Monitoring. Fundamentals Clause 3.7, Corrective and Preventive Action has also got a significant makeover. If re-occurring issues are not thoroughly dealt with via a comprehensive root cause analysis (RCA) a major against this fundamental clause can have significant certification consequences. An amendment to Clause 3.9, Traceability highlights the need for legal compliance with local law. This may be done to pre-empt new UK Food Safety legislation due to Brexit or the Food Safety Modernization Act (FSMA) law in the USA.
Changes to Section 4, site standard, includes visitor protocols, food defence, personnel training, site map to include details on pathogen risk zones. There has been a rewrite of Section 4.6, Equipment and Specific X ray requirements.
Section 5, Product Control has updated its allergen section possibly as a result of commission regulation 2021/385. Clause 5.4 product authenticity has a new sub-clause included regarding vulnerability assessment. Section 5.6 on Product Test and Laboratory Analysis has been significantly modified. Section 5.9 Animal Primary Conversion is a new clause and it is the first time specific details on veterinary medicines, ante and post mortem inspection and handling of live animals has been included in the BRCGS Food Safety Standard.
Section 6 Process Control is largely as it was in Issue 8 apart from some specifics on handling of by-products, greater label control and handling of reject packs due to weight, volume and number control.
Section 7, Personnel is again largely unchanged apart from some minor changes to personal hygiene and medical screening.
Section 8, Product Risk Zones places greater emphasis on the map of the site, previously mentioned in Section 4 to include location of the pathogen control steps. The CIP section of Clause 8.5, Housekeeping and hygiene in high risk and high care zones has been expanded with greater detail.
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