With the BRC Global Standard for Food Safety issue 8 just around the corner I have been looking at some of the changes suggested in the consultation draft. This type of document is subject to change, but it’s a great chance to see what might be coming down the tracks, and even to help to shape the new standard with your own comments. I have given a link at the bottom of this post to the full consultation document to find your own highlights!
Issue 8 timeline
31st December 20017 – deadline for feedback
January 2018 – Standard wording finalised
August 2018 – Standard published
October 2018 – Standard training starts
February 2019 – Audits commence
One of the biggest changes are two new clauses!
Previously requirements for High Risk, High Care and Ambient High Care have been spread throughout the standard. These have been extracted from various sections of issue 7 and these requirements now have their own section; section 8.
Extra requirements in the consultation document include consideration given to the potential for cross contamination for handling waste in Ambient High Care, High Care and High Risk areas.
Traded Goods which is a separate voluntary module in issue 7 will now be section 9. This might not seem like a big change although it’s now got the potential to affect a sites audit grade. For BRC Food issue 7 any non-conformance against the Traded Goods voluntary module didn’t get counted for the letter grade – non-conformance in section 9 will be counted against the overall grade! If a site gets 10 minor non-conformances against clauses 1-8 and a non-conformance against clause 9 this would be grade B, under issue 7 the non-conformance gained against the Traded Goods voluntary module wouldn’t be counted and the site would get a grade A.
Some examples of other proposed new requirements
- The business will need to have a strategic plan for Food Culture, and a whistle-blowing system.
- The proposed whistle-blower clause has requirements to maintain the confidentiality of complainants, clearly communicate the contact details for the scheme, and also have a procedure to investigate and record any actions taken.
- If the site miss-uses the BRC logo this may lead to a non-conformance. Miss-use of the logo has always been prohibited, but not directly linked to a non-conformance against the standard.
- Consultants are now explicitly deemed to be a Supplier of Services. This means that the credentials of consultants helping with the implementation of a BRC Food Safety and Quality Management System will need to be vetted to ensure they have the appropriate qualifications and experience.
- Cyber-security must be considered as part of the Management of incidents, product withdrawal and product recall system.
- Raw material packaging removal procedures now required – presumably aimed at reducing the incidence of foreign body contamination in finished product.
- Pens explicitly need to be suitable for the application, such as metal detectable. “Factory pens” have been common place for many years, and it’s now proposed as a mandatory requirement.
- New clause for environmental monitoring. This adds more detail to establish monitoring systems, when these should be reviewed and how results should be used to improve operational standards.
- New clauses added to specifically target pet food.
- Cooking instructions will need to be fully validated. This may lead to extra requirements to verify the accuracy of cookers.
- Procedures required for testing checkweighers.
There are proposed changes to announced and unannounced audit types. Sites can still opt for announced or unannounced audits however the Option 2 unannounced audit, the split audit, has been removed for Issue 8.
These are a few of the more significant changes being suggested for the new BRC Global Standard for Food Safety, issue 8. There are a lot of changes, although sites that are already working with the UK’s largest retailers will be quite familiar with lots of these extra requirements.
If you would like to read through the full consultation document a copy can be downloaded from here.
Ian Trevor is a BRC Registered Consultant for the Food, Storage and Distribution and Agents and Brokers standards. If you need some help with your BRC project contact Ian via email at email@example.com or telephone 01775 729245.