The British retail consortium (BRC) food safety standard is one of the oldest and most widely used retail food safety standards. August 2018 saw the latest revision of the document published and this article outlines the most important changes you should consider. The draft standard was available for consultation so these changes shouldn’t come as too much of a surprise. But now that they are high, manufacturers should ensure they are planning to implement the changes as soon as possible.
The BRC have indicated that the changes are in response to their analysis of audit findings and the changes are to assist manufacturers in strengthening potentially weak areas in the food safety management systems. As expected there are now MORE requirements with nine sections instead of the historical seven sections.
There is always a lot of debate around what constitutes a high risk facility. One of the new sections finally clarifies and consolidates the requirements for production facilities who fall into the high risk, high care and ambient high care categories and all previous requirements have been centralized. There is also a the decision trees on included in the standard which will assist the sites in determining what risk zones they have at their facility.
The new edition has a clause which introduces food safety and quality culture as a compulsory requirement. Previously, this has been a voluntary requirement for companies.
Auditors will not be attempting to audit and evaluate culture at a site but rather the plans and objectives in place to improve the company culture. Part of this is also a whistleblower system to ensure all concerns regarding product safety, integrity, quality and legality to senior management can be reported and handled confidentially.
Food Defence and the potential for deliberate malicious contamination of food now requires a formal risk assessment commonly referred to as TACCP. Don’t forget the food fraud aspects too.
On the back of the South African Listeriosis outbreak the whole new section on Environmental Monitoring will be very helpful as it requires risk based programmes to be in place for pathogens or spoilage organisms for all production areas with open and ready to eat products.
It is now a requirement that organizations implement procedures to document and handle cyber attacks or the failure of their internet security. As this topic becomes increasingly more relevant, it brings BRC Food in line with other standards and principles.
According to BRC, it is clear that many sites are not effectively scheduling internal audits throughout the year, which is evident by the non-conformities being raised. The new standard requires at least 4 audit dates per year on a scheduled programme. This is to prevent a tightly scheduled block of internal audits immediately prior to the certification audit. For each internal audit a clear scope needs to be defined, to ensure that all activities are covered at least once a year, with the actual audit frequency of each activity being based on the risks associated. If you haven’t had your internal auditors trained, now would be a good time. You will need to conduct an internal audit risk assessment to indicate how they determined the frequencies of the internal audits and which aspects will need to be audited more frequently.
Pet food has been integrated and defined to assist manufacturers.
Many nonconformances have been identified around supplier approval and monitoring. The requirements have now been separated to ensure each activity get the attention it deserves in order to effectively manage the potential risks in the supply chain.
Previously an additional, voluntary module, the requirements for traded products have now been included. These requirements apply where a site purchases and sells food products that would normally fall within the scope of the standard, but are only stored at the site’s facilities without being manufactured, processed, or packed there. If there are any nonconformities with these products, these will impact on the site’s overall grade. They are now also your problem if you choose to include them. When traded goods are excluded the site can still use the BRC logo.
The train the trainer processes are now under way and in October 2018 Auditor and site training will begins. The first audits on version 8 will start in February 2019. That is not a long time to deal with the changes so make sure you don’t delay