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Are you prepared for BRC Issue 8?

11 March 2019

Verner Wheelock highlights some of the main changes and additions to the latest BRC Standard and explains why these changes are necessary. 

Anyone who supplies the larger retailers will be well aware of the British Retail Consortium (BRC) Global Standard for Food Safety which is designed to provide the basis for certification for food manufacturers who implement good manufacturing practices (GMP) and have supporting quality management systems. It can be applied to any food processing or food packing operation where food is handled, processed or packed.

Every few years the BRC Standard is updated to take account of new manufacturing practices, areas of concern and often to clarify or simplify points in previous versions. Issue 7 of the BRC standard, for example,  took into account the ‘Horsemeat Scandal’ of 2013 and included a section on traceability and product authenticity in response.

Product vulnerability and threat measures are still very much on the agenda in Issue 8 which replaced Issue 7 on 1st February.  

There has been a major revision of Section 4.2 relating to site security and food defence. The risk of malicious contamination from internal or external threats must now be assessed at all stages when the product is under the management control of your company – not just through the supply chain. 

There should be monitoring and control of risk in areas such as storage and intake points; and only authorised personnel should have access to production and storage areas. For this reason all staff need to be trained in site security procedures and food defence.  A Vulnerability Assessment and Critical Control Points (VACCP) and Threat Analysis and Critical Control Points (TACCP) course could be a good solution to alert employees to potential risks and advising them how to put measures in place to avert them.

There have been key changes too, relating to product labelling and packaging, which is still a major issue. New to BRC Issue 8 is a requirement to ensure that there are processes in place to prevent any obsolete packaging from being used inadvertently. This also includes controls for the disposal of obsolete packaging and other printed materials. 

Making sure that the correct packaging and labelling is used for a product is essential, especially where they contain allergenic ingredients. It is also imperative that the correct ‘Use by’ dates appear on the packaging. However, perhaps one of the most significant changes is the addition of a new clause regarding food safety culture. It requires the site to assess its current food safety culture, plan and implement activities to improve it and review the outcomes of these activities. The senior management of a company will be expected to present their food safety culture plan to the auditor during the audit.  

Plans can cover a number of years but should have activities spaced across it not front and/or end loaded.  Auditors will not be making a judgement on the type of culture, they will be looking for an understanding of the current culture, planned activities, implementation of some activities and a review of their effectiveness. If no plan or implementation is effected, it will represent a major non-conformance against a BRC audit.    To be effective, there needs to be buy-in from everyone in the company and it needs to be led from the top. 

Food safety and quality need to be viewed as being as important as hitting delivery schedules and profit targets. Measurement and monitoring can take the form of training, surveys and staff retention. 

Reporting system
Also in Section 1 is another new clause requiring companies to have a confidential reporting system for employees that have concerns relating to product safety, integrity and legality to be able to report them anonymously. 

Another new clause is the requirement for sites to have a risk based environmental monitoring programme in place for pathogens or spoilage organisms. Because this includes all production areas with open and/or ready-to-eat products it makes it applicable to all sites – high risk, high care, ambient high care and low risk.

Verner Wheelock is running a number of BRC Food Safety Issue 7 to 8 Conversion for Sites courses. The course is tutored by official BRC Approved Training Partner, Eleanor Nicholls, an experienced auditor and longstanding VWA trainer. For more information, please visit www.vwa.co.uk


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