BRCGS Food Issue 9: Key Changes
- 1.1.1 The phrase “improvement of food safety and quality culture” has been added to the scope of the policy.• 1.1.2 The Food Safety Culture Plan must be reviewed and updated at least once a year, and its scope is now described in detail.• 1.1.4 The “Culture plan” is added to the senior management review agenda.• 1.1.11 Senior management must take part in the audit to discuss the effectiveness of the “Quality and Food Safety Culture Plan”.• 1.2.3 Employees must be aware of the requirement to report unsafe or out-of-specification products and inputs to their supervisors.• 1.2.4 Where there is insufficient knowledge of food safety, authenticity, legality and quality, external expertise may be used, provided that the day-to-day running of the system remains the responsibility of the site.• 2.7.4: When a hazard is controlled by prerequisite programmes or by measures other than CCPs, this must be specified and validated.• 2.12: HACCP plan validation has been added to this clause.• 3.4.1: The Food Safety Culture Plan must be addressed in the internal audit.• 3.5.1.2: Food fraud and food defence must be included in supplier audits and questionnaires.• 3.5.3.3: Performance of approved service providers must be evaluated at least once a year.• 3.5.4.3: Risks arising from outsourced processes must be included in food safety, food fraud and food defence risk assessments.• 3.9.3: The traceability exercise must also include mass balance for raw materials (excluding primary packaging).• 3.11.4: In the event of a withdrawal/recall, the correction, root cause analysis and corrective action plan must be submitted to the certification body.• 4.1 Site security has been added under the external areas standards clause.• 4.1.4 A visitor registration system must be in place, drivers, contractors and visitors must be informed of the site rules, only employees may enter processing and storage areas, and contractors may be present in these areas only when accompanied. (In Issue 8, this was a sub-clause of food defence.)• 4.2.1 The food defence team/person responsible must know the site and the food defence risks on site.• 4.3.1 Production risk zones must be assessed in accordance with Appendix 2 (such as high risk, high care, and low risk areas).• 4.3.2 The site layout plan must show production risk zones, such as high risk, high care, low risk and enclosed product areas.• 4.4.11 Plastic curtains must be in good condition to prevent the entry of pests.• 4.5.1 Risks related to water storage must be managed.• 4.6 The equipment clause has been considerably expanded.• 4.6.1 A purchase specification must be established for new equipment.• 4.6.2 A risk-based procedure must be established for the installation of new equipment. The procedure must cover topics such as post-installation cleaning and approval before operation. The location and design of equipment must allow cleaning and maintenance to be carried out effectively.• 4.6.3 The design and layout of equipment must not cause any product contamination; surfaces must be suitable for food contact, with suitable surfaces and smooth joints and welds.• 4.6.4 There must be a procedure for managing the relocation of fixed equipment.• 4.6.5 Equipment not in use must be stored hygienically and in a way that does not cause product contamination.• 4.6.6 Mobile equipment such as loading and lifting equipment must not pose a risk of product contamination.• 4.6.7 Battery charging must not take place in open product areas.• 4.9.5.1 Wooden materials in contact with food must be suitable for food use.• 4.10.3.5 X-ray equipment test procedures are described in detail.• 4.10.4.1 Magnets used for final product checks must be subject to effectiveness tests, as well as integrity and cleanliness checks and inspections.• 4.10.5.1 Optical sorters used in final product checks must be checked in accordance with the manufacturer’s instructions and recommendations.• 4.10.7.1 Other foreign body separation and detection equipment, such as aspirators, fluid bed separators and weight separators, must be checked in accordance with the manufacturer’s instructions and recommendations.• 4.11.7.4 The functional operation of spray balls must be checked.• 5.1.1 The management of changes to existing products, packaging and processes has been added to this clause.• 5.2.1 In addition to this clause, a procedure for label artwork approval is now required.• 5.3 Allergen management statements relating to pet food and animal feed have been added to the “statement of intent”. If there are legal requirements in the country where the product will be sold, or if allergen claims are made for the product, pet food and animal feed manufacturers must also comply with the allergen management clause.• 5.4.1 The person or team responsible for food fraud (adulteration) assessments must know the principles of food fraud and the risks related to raw materials.• 5.4.7 Where a claim is made about a product, the product recipe and process must be validated.• 5.5.1 When purchasing primary packaging or establishing its specifications, the packaging supplier must be informed about the nature of the food and the characteristics of the packaging (such as recycled material or reuse of the packaging).• 5.6 The clause title has been revised to product inspection, product testing and laboratory analyses.• 5.6.2 Immediate action must be taken when legal limits are not met, and measurement uncertainty must also be taken into account when evaluating analysis results.• 5.8 This clause, which previously covered pet food only, now also covers animal feed.• 5.8.4 In the case of animal feed production, the product safety legislation of both the country of production and the country of sale must be complied with.• 5.9 New clause: Additional requirements for all sites carrying out slaughter or post-slaughter operations for red meat, poultry and fish production are brought together under this clause.• 6.1.7 Products or materials outside the scope of the audit must not pose a risk to other products.
Transition from Issue 8 to Issue 9: As with all revisions of the Global Standards, there will be a transition period between the consultation process and the full implementation of the final standard. BRCGS Food Safety Issue 9 will therefore be published in August 2022, and certification audits will begin on 1 February 2023. Once published, the new standard will be available on the BRCGS website.
