BRC Agents and Brokers issue 2 is just around the corner with the publication last week of a draft version for industry comment. As could be expected the proposed new version will probably include lots of the requirements already in the BRC Food standard.
Changes are evident in many clauses such as HACCP, Internal Audit, as well as new clauses for Management of Surplus Stock and FSMA Preventative Controls aimed at the USA market.
The biggest changes, and those that will impact Agents and Brokers the most, relate to the approval of product suppliers and the control and risk assessment of Storage and Distribution service providers.
BRC Agents and Brokers using non-GFSI certified Agents and Brokers
Where BRC Agents and Brokers use non-GFSI certified (i.e. BRC) Agents and Brokers as part of their supply chain the BRC Agents and Brokers office must have systems in place to independently approve the manufacturing site. So, dependent upon the Supplier Approval Procedure for the BRC Agents and Brokers business, this could mean that a copy of the manufacturers BRC Certificate and Report may be required, a physical supplier audit may be needed or if the site is low risk a Supplier Approval Questionnaire should be completed by the manufacturer NOT just the suppliers Agent. The draft BRC Agents and Brokers standard also requires that certified sites have a contract or formal agreement in place with each supplier which mandates the supplier to inform the Agent and Broker if there are any significant changes to the suppliers status, such as any change in certification.
Extra controls for distribution and storage suppliers to BRC Agents and Brokers
The requirements for service providers, such as storage and distribution companies, could also change. The proposed amendment to this clause includes specific contractual controls for service providers to ensure the integrity of the whole supply chain. This means where the supply chain includes the use of pallet exchange schemes, groupage transport or 3rd party storage facilities this should be defined and agreed in a contract with the service provider.
A further change that relates to the supply chain can be found in the Traceability clause. The current requirement is that the traceability system needs to be tested at least once per year. The proposed amendment includes a requirement for traceability tests to be undertaken for each type of supply route. For example if an Agent and Broker imports containers from China, purchases product from Europe which is delivered directly to European customers and delivers individual pallets via a distribution network in the UK this may lead to a requirement for 3 different traceability studies.
Changes to audit protocol
Proposed changes to the audit protocol has also been identified which includes the provision for unannounced audits and the grading scheme will change to include the AA, A, B, C and Not Certified. This falls in line with the BRC Food and Storage and Distribution schemes which, in effect, tighten the requirements to get a “Good” grade. The current system has the highest level of Approval as less than 2 major and 10 minor non-conformances, whereas the proposed new issue this would give the site a Grade B.
These are some of the big proposed changes to the BRC Agents and Brokers standard although there are many phraseology changes which will need to be carefully examined when the final version is issued ready for implementation and audit against the new standard in February 2018.
If you would like a copy of the new draft standard a copy can be downloaded from here, and if you would like to have an input and comment on the draft document a form can be downloaded here.
Ian Trevor is the Managing Director of Food Fix, and a BRC Registered Consultant for the Agents and Brokers, Storage and Distribution and Food standards. If you would like some help with BRC related projects please get in touch.