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Navigating BRCGS Issue 9

13 June 2024

As the food safety landscape evolves, so do the standards governing it. BRCGS Food Safety Standard Issue 9 introduces several key changes aimed at further improving hygiene and safety practices within the food industry. Michelle Locke explains some of the key changes and their impact.

Within Issue 9, one of the main messages that shines through is the role of hygienic furniture and equipment in maintaining an audit ready food processing environment. 

One of the key non-conformities that Issue 9 raises is equipment design and construction. Put simply, if you are running a food operation and your furniture and equipment isn’t of the right standard, when being audited you are now very likely to receive non-conformities that would not have been raised under Issue 8.

Without effective planning and design – of both the premises and the equipment – there is no chance of instilling good hygiene practices within an organisation. This message is reinforced by Campden BRI, a global leader in food and drink science and research. It says that ‘the flow of raw materials, ingredients, packaging, people and utilities through a food area can markedly reduce or increase the risks of product contamination.’  

Root cause analysis of swab testing results shows that furniture is a significant risk factor in any facility. The quality of design and manufacture of the furniture can dictate future success or failure when it comes to an audit. But, while every professional working within the food processing sector knows this to be true in theory, in practice, furniture and equipment which is not specifically designed to aid robust hygienic clean down routines can still be found on food factory floors throughout the UK.

Risk assessment
The latest version of the BRCGS Food Safety Standard introduces a new clause (4.9.6.3) stating: ‘Based on risk, procedures shall be implemented to minimise other types of foreign-body contamination (i.e., types of contamination that are not specifically covered in section 4.9)’.  Foreign matter not included in clause 4.9 can include toolbox contents such as spare nuts and bolts, cable ties or even odd items of stationery such as spare printer cartridges or labels.

Most people working in food production environments will have seen out of place items on the factory floor, but the latest BRCGS standard makes it very clear that there is no place in a food production area for random pieces of equipment which have no specific purpose and no designated storage space. 

It is only by owning non-conformances such as foreign body contamination that food production businesses can enhance their hygiene standards and ensure that they are always audit ready. Adopting a foreign body control box system, is one way to demonstrate commitment to these standards.  This box, made from hygienic stainless steel, provides a central receptacle where any foreign bodies discovered within the food production area can be placed.  Ideally with a removable tray, the contents of the box should be able to be easily removed, investigated, and route cause analysis undertaken, to minimise further incidences and prevent further non-conformances.

Having a foreign body control box in plain sight demonstrates to both your staff and any visiting BRCGS auditor that you take potential contamination risks extremely seriously and have a process in place to deal with them.

Furniture specification 
Food factory furniture must be able to withstand harsh cleaning chemicals without the risk of corrosion and rust. It is advisable to invest in furniture that is made from the correct grade of stainless steel, or waterproof construction board, for the job in hand.  A wet, rusty environment is the perfect breeding ground for bacteria to thrive and multiply and biofilms to grow. These can cause a variety of potentially fatal illnesses.

Hidden ledges, seams, and raised welds offer a sanctuary for dangerous microbes, and areas where water or cleaning fluids can pool can be a listeria risk. Always opt for furniture with sloped surfaces and in-built drainage points to enable liquids to run off, rather than pooling.

The emphasis on risk assessment underscores the importance of selecting furniture that minimises contamination risks and complies with food safety standards. Buyers need to prioritise suppliers who demonstrate a robust risk assessment process for their furniture products.

Always audit ready
BRCGS Issue 9 places a renewed emphasis on ensuring that food processing environments are audit-ready, at all times. This entails maintaining rigorous standards of cleanliness, hygiene, and food safety practices, 24/7. Furniture and equipment play a pivotal role in achieving audit readiness, as they must meet stringent criteria to prevent contamination and comply with regulatory requirements.

An auditor will not be looking at an item of furniture in isolation. As well as testing the cleanliness of all surfaces, they will be checking the areas surrounding the furniture, such as the floor and any walls behind or to the sides. Cleaning staff need to be able to easily access these areas. The harder they are to reach, the more risk there is of sub-standard cleaning and non-conformities. 

From a production and profitability perspective, poor furniture design and accessibility means more time spent on cleaning.  While your cleaning team taking a few more minutes to reach tricky areas might not seem like a concern, think about how quickly a few extra minutes adds up over weeks and months, impacting both productivity and profitability.

The production area might look clean and tidy as you walk around and take a cursory glance.  But what would you see if you got down on your knees and looked more closely? Put yourself in the position of an auditor and look at your equipment and furniture with fresh, and very critical, eyes. Would you be happy for an auditor to look under tables, inside machines or in the hidden corners of storage areas?  

And consider the views of customers. What are their audit requirements? Once you have established and honed your hygienic processes in line with good manufacturing practices, ensure that every member of the team starts to think and behave like an auditor and a customer too.

BRCGS Issue 9 definitely presents challenges for some businesses that may have been working comfortably for years with the same equipment in place and no significant non-conformities.  But both old and new equipment is now audited against the requirements set out in Issue 9. Having the right furniture and equipment is no longer an option, it is absolutely essential.

For a food factory manager, an extended technical review is their worst nightmare.  It can lead to lost sales, reputational damage and even regulatory sanctions. The only way to prevent this is to ensure your business has fully digested the changes in BRCGS Issue 9 – including those relating to food factory furniture - and is audit ready, every single day.  

Michelle Locke is product and marketing manager at Teknomek.


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