BRC Issue 8 - What are the key changes?

BRC Issue 8 – What are the Key Changes?

The BRC Global Standard for Food Safety is recognized around the world as a basis for food safety and quality management. Check out the key changes to the requirements to comply:

Senior Management Commitment:

Overview - This section has been expanded to ensure that all production sites develop and implement robust monitoring programs. This is to enable manufacturers to take timely corrective action to avoid product contamination.

Details -

  • Senior management must define and maintain a clear plan for the continued improvement of food safety and quality assurance. This shall include:
    • All sections of a site that impact product safety;
    • An action plan detailing how the activities will be undertaken and measured, with intended timescales;
    • A review of the effectiveness of complete activities including systems for HACCP, food defence and authenticity.
  • Site meetings about food safety, legality, integrity and quality issues must occur at least once a month with the findings then reported to senior management.
  • Establish a confidential reporting system and process to enable all staff the opportunity to disclose their food safety, legality, integrity and quality concerns. 

HACCP/Food Safety Plan:

Overview - The terminology is now aligned with the Codex Alimentarius.

Details -

  • The HACCP food safety plan must cover all types of hazards, e.g. microbiological, physical contamination etc.
  • Electronic documents and records must be securely stored and backed up.
  • The program shall include at least four different audit dates spread throughout the year. Audits shall include:
    • HACCP or food safety plan with implementation activities.
    • Prerequisite programs e.g. hygiene, pest control.
    • Food defence and food fraud prevention plans procedures.
    • Procedures to achieve the BRC Global Standard.
  • The raw material risk assessment plan shall be updated if there is a change in the material, the processing procedure or supplier; if, a new risk occurs; following a product recall/withdrawal; at least every three years.
  • Supplier performance reviews must be documented.
  • The management, approval and monitoring of outsourced processing is now included in the Standard to ensure safety is not compromised.
  • Sites must have a procedure for the completion of root cause analysis to implement improvements and prevent recurrence of non-conformities, i.e. where product safety is at risk.
  • All sites must have a documented traceability procedure. As a minimum, this should include: how the traceability system works and the labeling and records required. 

Product Security and Food Defence:

Overview - The need to prevent malicious contamination has increased. As such, Issue 8 has significantly revised risk assessment requirements.  

Details -

  • Systems shall protect raw materials, products, premises and brands from malicious actions.
  • The company shall undertake a documented risk assessment of internal and external threats. This becomes the basis of a threat assessment plan which needs to be regularly reviewed to adapt to changing circumstances.
  • Physical risk areas, e.g. external storage areas, need to have secure, controlled access by authorized personnel. A visitor recording system must be established. Plus, staff must be trained in site security procedures and food defence.
  • Elevated walkways, near production lines, must be designed to prevent product contamination.
  • All production equipment shall be inspected by an authorized employee who will confirm the removal of all contamination hazards.

Product Inspection Equipment:

Overview – Issue 8 includes more detailed information about the operation of foreign-body detection, checkweighers and labeling equipment.   

Details -

  • All sites must establish and implement corrective action and reporting procedures in the event of a contaminant detection and/or online verification system failing. Action shall include re-inspection of all products since the last successful inspection test.
  • The testing of in-line metal detectors is to be completed during line start-ups and at the end of production periods.
  • Changes to all equipment settings which impact the integrity and safety of the product must only be completed by trained and authorized personnel. Also, controls shall be password protected or otherwise restricted. 
  • A new requirement is for checkweighers to be managed in accordance with legal requirements. This includes testing for operational effectiveness and recording test results. 

Product Labeling:

Overview - A high number of product recalls stem from labeling errors. Analysis of incorrectly labeled products show that the main issues are errors made in the original label information, changes to ingredients/suppliers, or packaging process mistakes.

Details -

  • Ensuring accurate, up-to-date information for effective ‘change control’ at goods receipt. This means that only the correct version of materials is accepted onsite.
  • As highlighted in the Product Inspection Equipment section above, the control of onsite printing, e.g. data codes, is conducted by authorized personnel.
  • Online verification equipment, e.g. bar code scanners, will need to be set up and tested. At a minimum, the testing must be completed at the start and end of the production run.
  • During the vertical audit, the auditor will confirm the accuracy of labels plus the labeling process.
  • Customer cooking instructions must be validated to ensure that the product is safe-to-consume.
  • Establish a documented vulnerability risk assessment plan, which is constantly updated, to reflect any changes in the risk to raw materials.
  • New requirement to create a procedure to manage obsolete packaging, including labels. This includes the correct disposal of packaging to prevent re-use.
  • Verifying print information now includes checking allergen information.
  • To ensure the correct labeling of products, all relevant staff must have received training on labeling and packing processes. 

In addition to the changes cited above, there are now new requirements on reviewing the results of laboratory tests and extra detail to prevent pathogen contamination of products. Amendments have also been made to areas including physical environment, e.g. protecting glass windows against breakage, cleaning systems, risk-based environmental monitoring and pest management to ensure that product safety is continually upheld. 

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