FOOD SAFETY

An Overview of new changes in BRC Global Standard for Food issue 6 1.
Management Commitment and Continual Improvement
This is a new section to the standard.

• ·         Requirement for clear communication channels.
• ·         Management Review is required annually.
• ·         Additional requirements specific to audit process.
• ·         Copy of current issue of BRC Standard is required.
• ·         Certification to the BRC standard must not lapse.
• ·         Most senior operations/production manager on site must be at audit meetings.
• ·         Non-conformities from previous BRC audit must be completed.

2. HACCP
This section now follows Codex Alimentarius steps and is more descriptive in its requirements:

• ·         More detailed product description and intended use is required.
• ·         Detailed flow diagram and verification of flow diagram.
• ·         Use of decision tree for CCP determination.
• ·         Critical limits to be validated.
• ·         More requirements for documentation e.g. monitoring records signed and dated, corrective action and procedures for handling of unsafe products.
• ·         HACCP Review required annually as a minimum.

3. Quality Management System
3.1 Now called Food Safety and Quality Policy

• ·         Requirement for Continual improvement.
• ·         Senior manager must sign and date policy

3.2 Now called Food Safety and Quality Manual

• ·         Requirement for review at planned intervals.

3.3 Organisational Structure, Responsibilities and Management Authority

• ·         Organisation chart must be available.

 3.4 Contract Review and Customer Focus

• ·         There is a new requirement for the staff responsible for communication with customers to be defined.
• ·         Customer requirements need to be identified and agreed and these are to be reviewed at predetermined frequencies.

3.5 Internal Audit

• ·         There is a specific requirement to audit system annually as a minimum.

3.6 Purchasing – Supplier Approval and Performance Monitoring No changes.
 3.7 General Documentation Requirements No changes
3.7.1 Documentation Control

• ·         Documents now need to be in the ‘appropriate languages’

 3.7.2 Specifications

• ·         Manufacturing instructions need to comply with recipes and be fully implemented.
• ·         Documented procedure required for specification amendment and approval.
• ·         Specifications need to be readily accessible to staff. 3.7.3 Record completion
• ·         Period of retention of records needs to be related to shelf life, legislation and customer requirements.

3.8 Corrective and Preventive Action * Procedures required for preventive action and verification.
3.9 Traceability

• ·         Traceability audit / test to include quantity check / mass balance reconciliation.
• ·         Traceability audit / test to be carried out annually.

3.10 Complaint Handling

• ·         There must be a system to effectively capture and record complaints.

3.11 Management of Incidents, Product Withdrawal and Product Recall

• ·         More detail is included on what to include and consider regarding incidents & the management of incidents.
• ·         Detailed contingency planning for all types of incidents is required.
• ·         Record timing of key stages of recall / withdrawal audit / test.
• ·         Traceability and recall systems to be tested at least annually.
• ·         Now a requirement to notify your certification body in the event of a product recall.

 4.1 External Site Standards

• ·         Your site to be of suitable size, construction and design.
• ·         External yards and roads must be suitably surfaced and maintained.
• ·         Building fabric must be well maintained 4.2 Site Security
• ·         There must be controlled access and training of staff.
• ·         Secure storage of materials to be demonstrated.
• ·         Premises must be registered and approved.

4.3.1 Layout, product flow and segregation

• ·         Temporary repairs and structure must be controlled 4.3.2 Fabrication – walls, floors etc
• ·         Waste to go directly to drain.
• ·         Where floor falls are required is clarified.
• ·         Risk assessment of windows.
• ·         Doors to be maintained in good condition and cleanable.

 4.4 Services – now called Utilities No new requirements
4.5 Equipment

• ·         Requirement for Certificates of Conformity for suitability for use of food contact materials e.g. conveyor belt material.

 4.6 Maintenance

• ·         Specific control of maintenance contractors required.
• ·         Formal clearance / sign off required following maintenance work.
• ·         Maintenance consumables to be suitable for use.
• ·         Engineering workshops to be controlled to prevent contamination risks e.g. swarf mats.

4.7 Staff Facilities

• ·         There must be sufficient storage facilities available for personal items.
• ·         Waste must be controlled at outside designated eating areas.
• ·         Water, liquid soap, towels or air drier must be provided at handwash stations.
• ·         Hand wash instructions must be available.
• ·         Hand free operation taps and disinfection and high risk areas.
• ·         Water, liquid soap, drying facilities and signage must be provided at toilet handwash stations
• ·         At smoking areas the must be waste bins & signage for handwashing.

 4.8 Chemical and Physical Contamination Control

• ·         Specific requirements for non-food chemicals e.g. approved purchase, data sheets, suitability for food use, identified containers, secure and used by trained staff.
• ·         Procedures required for sharps e.g. knives and blades etc.
• ·         Glass breakage procedures e.g. quarantine, cleaning and release of area and Personnel controls. * ?Inspection procedures & documentation for sieves, filters and magnets
• ·         Procedures & control of foreign body contamination of packaging during filling operations e.g. use of inverters, air jets on line. 4.9 Housekeeping and Hygiene
• ·         Specific requirement for cleaning procedures to include responsibility, frequency, method, etc. * CIP to be monitored & controlled.
• ·         Cleaning chemicals and equipment to be fit for purpose, identified and stored to prevent contamination.

 4.10 Waste / Waste Disposal

• ·         Waste to be categorised based on legislative requirements.
• ·         Identified waste containers & rooms.
• ·         Waste containers & rooms cleanable and maintained.

 4.11 Pest Control

• ·         Risk assessment required to establish pest control programme and frequency of visits.
• ·         Clear specification for documentation required.
• ·         Bait station design and use specified e.g. tamper proof & tethered.
• ·         Corrective action required in the event of infestation.
• ·         Company to action recommendations.
• ·         Catch tray analysis required.

4.12 Storage and Transport

• ·         Covers storage as well as transport
• ·         Storage must be off floor and away from walls, use of bulk tankers, pre-loading and unloading inspection required.
• ·         Storage areas to be kept dry and well ventilated.
• ·         Global Standard for Storage and Distribution recommended for suppliers of these services.
• ·         Traceability to be ensured during storage and transport.

5.1 Product Design / Development

• ·         Shelf life trials required to confirm compliance with microbiological, chemical and organoleptic criteria.
• ·         NPD to control special handling requirements e.g. allergens.
• ·         Packaging to be confirmed as suitable for use and legal.
• ·         Validation of product claims e.g. nutrition.
• ·         Communication of changes to formulation or process.

5.2 Handling Requirements for Specific Materials – Materials containing Allergens and Identity Preserved Materials

• ·         All allergen containing materials, intermediate and finished products need to be listed.
• ·         Document a risk assessment to identify and control routes of contamination.
• ·         Develop procedures of segregation, use of dedicated equipment and staff policies.
• ·         Any claims to be fully validated.
• ·         Cleaning methods, waste handling & spillage controls to be validated.
• ·         Staff training required in allergen handling.
• ·         Non-conformities specifically involving allergens to be reviewed.
• ·         Risk assessment is required for raw materials requiring ID preservation.
• ·         Risk assessment is required of routes of contamination of ID preserved materials.

5.3 Foreign Body Detection

• ·         Foreign body detection is required unless it is otherwise justified.
• ·         Monitoring check frequency and sensitivity to be defined with trained personnel and documentation.

 5.4 Product Packaging

• ·         Evidence to confirm suitability for use e.g. certificates of conformity required.
• ·         Coloured liners of sufficient gauge to prevent contamination are required.

5.5 Product Inspection and Laboratory Testing

• ·         Test results to be recorded.
• ·         Test results to be analysed for trends and action taken.
• ·         There is a requirement for organoleptic tests.
• ·         Ongoing shelf life assessment is required.
• ·         Laboratory testing for pathogen testing to be subcontracted or laboratory must be remote from manufacturing.
• ·         Minimise risk of cross contamination from laboratory e.g. security, access, colour coding workwear, waste controls etc.
• ·         Procedures for reliability of results – recognised methods, documented methods, staff training, ring testing, equipment calibration.

5.6 Control of Non-conforming Product No major changes.
5.7 Product Release No major changes. 6.1 Control of Operations

• ·         All CCPs to be transferred to day to day production controls.
• ·         Process monitoring to be carried out by trained staff.
• ·         Procedure to be in place to ensure product is packed into correct packaging.

 6.2 Quantity – Weight, Volume and Number Control No major changes.
 6.3 Calibration and Control of Measuring and Monitoring Devices

• ·         Details of calibration procedures has been clarified e.g. list of equipment, identified & labelled, checked & adjusted based on risk assessment.

7.1 Training

• ·         Competency for specific roles to be documented.
• ·         Monitoring of training requirement and effectiveness.
• ·         Training in relevant language.
• ·         Specific details to be recorded on training records – name, date, duration, course contents, training provider.

 7.2 Access and Movement of Personnel

• ·         Site plan required showing access points and travel routes.
• ·         There are specific design and layout requirements.
• ·         Staff / visitor training on site access, movement and hazard procedures.

7.3 Personal Hygiene

• ·         Staff compliance to hygiene rules to be checked regularly.
• ·         Visitors to be controlled by wearing gloves / non handling of food if not complying to hygiene requirement of fingernails.
• ·         Coloured plasters e.g. blue (different from product) to be available.

7.4 Medical Screening

• ·         Procedure for action to be taken in the case of infectious disease to be communicated to staff. 7.5 Protective Clothing
• ·         Policy to be documented.
• ·         Protective clothing to be provided in sufficient numbers.
• ·         Design to prevent product contamination.
• ·         Clean and dirty clothing to be segregated
• ·         If laundering in-house, validate the effectiveness of process.
• ·         Gloves to be suitable for food use, disposable, distinctive colour, intact.
• ·         High risk clothing shall be removed and stored in a designated changing area.