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BRC Issue 8 – Make sure you’re prepared

supermarket shelves

Anyone who supplies the larger retailers will be well aware of the British Retail Consortium (BRC) Global Standard for Food Safety. The Standard is designed to provide the basis for certification for food manufacturers who implement good manufacturing practices 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.

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

Product safety and security is high on BRC Issue 8 agenda

Product vulnerability and threat measures are still very much on the agenda in Issue 8.  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. All staff need to be trained in site security procedures and food defence. A VACCP and TACCP course is ideal for alerting employees to potential risks and advising how to put measures in place to avert them.

Food packaging and labelling

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 products contain allergenic ingredients. In certain instances, it can literally mean the difference between life and death for consumers. It is also imperative that the correct ‘Use by’ dates appear on the packaging if illness and spoilage are to be avoided.

Food safety culture

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.

Whistleblowing and environmental monitoring

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.

This article has highlighted just a few of the many changes between the BRC Global Standard for Food Safety issues 7 and 8. For a detailed examination of all the changes, their interpretation and implementation, 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.

Other courses which are ideal preparation for BRC Issue 8 include Managing Food Allergens, Root Cause Analysis, VACCP and TACCP and Legal Labelling as well as Auditing Skills, Supplier Auditing and Lead Auditor.