BRC Global Standard Issue 8 - Critical clauses & changes in the new standard

Is your business aligned with the latest BRC Issue 8? 
Update your food safety management systems

The British Retail Consortium (BRC) is a benchmark for best practice in the food industry and evolved into an internationally recognized BRC Global Standards. Gaining BRC Global Standard would give the brand an internationally recognition of quality, safety, responsibility and also as a value the brand attains customer confidence. Additionally, this programme is fully approved by the Global Food Standard Initiative (GFSI) and is designed to improve processes of the food business. Recently, BRC has published issue 8 and in this regard we are brining you with the critical changes from the previous guidelines i.e. issue 7

Key changes in BRC Issue 8

What are the larger inclusions in this issue?

• Enhancing product safety culture 

• Expanding requirements for environmental monitoring 

• Strengthening food defense at the manufacturing sites 

• Delineating risk classification of production zones and also requirements for pet food premises 

What is the scope of BRC food safety standard?

1. Processed food manufacturer 

2. Raw materials manufacturer for food application

3. Primary agriculture produce

4. Pet foods

What are the transition timelines?

According to the information released, we can expect the following timeline for BRC Food 8

BRC issue 8 implementation timelines 

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[item title="1.1.2 – Introduction of food safety culture"]

Organizations should document its strategic plan for development and continual improvement of food safety culture overarching all the divisions of the company, implementation plan and also review the effectiveness of completed activities. Point mentioned under the section 1.1.2 is delineated below

The site’s senior management shall have a documented strategic plan for the development and continuing improvement of food safety culture. This shall include:

1. defined activities involving all sections of the company

2. an action plan indicating how the activities will be undertaken and intended timescales

3. review of the effectiveness of completed activities

Auditors will not be attempting to audit the culture of the factory and will be evaluating the points delineated in the clause

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[item title="1.1.5 & 1.1.6 – Incident reporting & whistle blowing"]

In continuation to the previous point, the organization should promote a culture of incident reporting and any other concerns relating to product safety, integrity, quality and compliance to senior management. Please refer below 1.1.5 and 1.1.6 in the standard citing this explanation

Employees shall be aware of the need to report any evidence of unsafe or out of specification product or raw materials, to a designated manager to enable the resolution of issues requiring immediate action. The Company shall have a system (eg. a whistleblower system) that enables staff to confidentially report concerns relating to product safety, integrity, quality and legality to senior management.

[/item]

[item title="3.4.1 – Internal Audit"]

Internal audit programs are essential for ensuring process effectiveness and to this extent in the issue 8, there is a specific mention of a minimum number of audits to be performed in the organization and it should not be less than 4 audits spread throughout the year. The clause 3.4.1. describes the same

There shall be a scheduled programme of internal audits. As a minimum this programme will include at least 4 different audit dates spread throughout the year. The frequency that each activity is audited shall be established in relation to the risks associated with the activity and previous audit performance; all activities shall be covered at least once each year

[/item]

[item title="3.9.1 and 9.5 – Traceability"]

In this latest issue, there is a significant emphasis on both forward and backward traceability of products and raw materials. It is also mentioned in the clause 9.5 that the company should have control on the product movement. Further, it also specifies the minimum drills to be conducted along with the number time to achieve the product records i.e. 4 hours

The site shall have a documented traceability procedure designed to maintain traceability throughout the site’s processes. As a minimum this shall include:

1. how the traceability system works
2. the labelling and records required

[/item]

[item title="4.11.8 - Environmental monitoring"]

Environmental monitoring program should be in place in the production areas to mitigate the risk associated with pathogen and spoilage organisms in the food products. Clause 4.8 delineates the requirements of identification of areas, sampling protocol, test methods, recording and evaluation of results

Risk based environmental monitoring programmes shall be in place for pathogens and spoilage organisms. As a minimum, this shall include all production areas with open, ready-to-eat products

[/item]

[item title="4.2.1 - Site security and food defence"]

Strengthening the site security and defence mechanism was emphasized in the section 4.2.1

The company shall undertake a documented risk assessment of the potential risks to products from any deliberate attempt to inflict contamination or damage. This risk assessment shall include both internal and external threats. The assessment shall be reviewed at least annually.

[/item]

[item title="5.6.2.5 – Laboratory Testing"]

The significance of laboratory results shall be understood and acted upon accordingly. Appropriate actions shall be implemented promptly to address any unsatisfactory results or trends. Where legal limits apply these shall be understood and appropriate action implemented promptly to address any exceedance of these limits

[/item]

[item title="5.1.5, 5.1.6 and 5.1.7 – Pet food"]

Pet foods are included in the scope of the standards and there are requirements, procedures specified in the clauses 5.1.5, 5.1.6 and 5.1.7

Where the site manufactures, processes or packs pet food products that contain medicinal substances, the site shall have specific procedures for the management of the medicated raw materials and finished products. As a minimum, this shall include:

1. Identification of medication-containing materials handled on site. This shall include raw materials, processing aids, intermediate and finished products, rework and any new product development ingredients or products.

mechanisms to ensure correct concentrations of medicinal substances in finished products

2. procedures (eg cleaning procedures) to prevent contamination of non medicated pet food with materials containing medicinal substances

3. specific procedures to ensure the correct labelling of medicated pet food

[/item]

[item title="Interim Reporting"]

One of the consistent concerns raised by key stakeholders (e.g. customers, certificated sites, regulators) is the time gap between audit and confirmation of audit result (e.g. availability of certificate & audit report). Following each audit an ‘interim’ report shall be made available on the BRC Directory within 10 calendar days of the audit. This will be a simple summary of information with the contents strictly limited to date of audit, basic site information, details of the audit scope and the non- conformities found.

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We can help you in a smooth transition, please reach us at smartcomplainz@outlook.com for a free gap assessment.

Click here for the standard document 

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Issue 18