BRC v8 Review of Changes
What changes does the new BRC v8 have in store for us? In the article below I will briefly cover the proposed changes to the audit protocol, the layout of the standard and some key changes to clauses.
Please bear in mind that currently the BRC v8 is a draft version so many of these changes may not go through or be further amended. I will look at these closer again when the standard is published so follow my blog for any updates.
First let us look at the audit protocol. Previous versions of the standard provided two options for unannounced audits:
· Option 1 - A single unannounced audit
· Option 2 - A split audit with an unannounced audit of good manufacturing practices and a later, announced audit primarily to review records and procedures.
Option 2, the unannounced audit has consistently proven to be unpopular, with very few sites selecting to be audited in this way. It has therefore been removed from Issue 8.
Also the way traded goods are tackled has changed. The traded goods module will remain voluntary and any site with applicable products may opt into these additional requirements to demonstrate to customers that good management practices are in place, relating to the traded goods.
However, the requirements of this module were included as an integral part of the main standard (section 9), therefore any non-conformances against the requirements of the traded goods module will be included in the assessment of the site’s grade.
It is an interesting step on behalf of BRC, however I wonder if the manufacturing sites which dab in traded goods will be reluctant to include these in the scope to reduce any non-conformances from this module that will adversely affect the final score.
Another novelty introduced are "statements of intent". Each main section will now have a state of intent to set out the expected outcome of compliance with the requirements of the section. The idea is that this will help to achieve the stated objective of the requirement.
The standard layout will now include colour coding determining whether evidence will be sought on the factory floor, within documentation or both. This is a similar approach as in Tesco's TFMS standard, stating what type of evidence would be sought by the auditor.
In terms of clause layout, a number of clauses have been moved following the sections reorganisation. This is bad news for all people who organised their QMS in line with BRC clause numbering. The requirements in sections 1 – 7 are applicable to all types of operations. Where a site’s products require high risk, high care or ambient high care production facilities, these requirements are listed in section 8. Any site that requires high risk, high care or ambient high care facilities is required to meet the requirements of this section.
Finally, below I am including a couple of pointers where significant changes from version 7 are proposed. This is not an exhaustive list and the significance of the changes is arbitrary but it might give you a heads up in regards to the direction in which changes are heading and save you going through 81 pages of the draft.
Personally, after reviewing the standard I believe the majority of manufacturers who already supply retailers like Tesco, Sainsbury or M&S will find that the new BRC standard is aimed at closing the gap between the previous version and retail codes of practice. Therefore, as such it should not create too big a disruption to those operators. However, small companies with limited budgets and resources, the B2B sector, ingredient and food service manufacturers might find some of the below changes challenging. In the long run, this may turn out to be a positive step on the way of closing the gap between primary suppliers and further links in the chain of custody. However, the question is, who will meet the cost of these changes in the low margin world of B2B operations.
The Senior Management Section was significantly boosted with requirements being added around formal evidence of pro food safety culture. The requirement for a business to have a documented strategic plan for the development and continuing improvement of food safety culture was added. This included the review of the effectiveness of activities listed in the plan.
An update of the requirement for a having demonstrable meeting programme (at least monthly) which enables food safety, legality, integrity and quality issues to be brought to the attention of senior management. This is further enforced by the clause about Employees to be aware of the need to report any such issues.
An added requirement for having a whistle blower system and having a process in place to review any concerns raised.
Finally, it seems that auditors will focus more on how the BRC logo is used by the business being audited. If a business is found not complying with section 4.6 of the standard this might result in a non-conformance to the business.
Some changes to HACCP / Food safety plan which I presume were brought to meet requirements of PCQI in America and reduce some ambiguity around interpretation.
Codex Alimentarius HACCP principles should now be INCORPORATED into the system where in the previous version the wording was BASED ON.
Also, there seems to be additional focus on the HACCP team leader having IN DEPTH knowledge of HACCP including specific training if required (eg. PCQI in the USA).
The HACCP review process should now include emergence of a new risk (e.g. known adulteration of an ingredient or other relevant, published information, for example, a recall of a similar product. This clause effectively brings Horizon Scan systems into the HACCP area so it will be interesting to see what type of evidence will be required by auditors.
Food safety and quality management systems are catching up with the 21st century with number of references to electronic systems, so hopefully no more auditors who prefer everything printed. However, documents stored in electronic form must be stored securely (eg authorised access, control of amendments, password protected) and backed up to prevent loss.
Requirements relevant to Internal audits are now less woolly after the clause got a significant revamp tightening controls and new requirements:
- Programme must include at least 4 different audit dates spread throughout the year.
- Number of areas to be audited was defined in more detail
- Each internal audit within the programme shall have a defined scope and consider a defined activity or section of the food safety plan or HACCP plan
- The frequency of audits apart from being risk assessed must be covered at least once each year (as opposed to annually in previous version)
- Internal audit reports will now have to include objective evidence of the findings
During the BRC version change from 6 to 7, the Raw Material and supplier section received a significant revamp. In version 8, the changes are not as fundamental but rather build on the legacy of the last couple of years. Raw material risk assessments should be expanded to include risk for raw material variety or species cross-contamination. Considerations must also be given to risks associated with specific product groups e.g. animals, fish and seafood which are subjected to legislative controls or associated with prohibited substances (eg. pharmaceuticals, veterinary medicines, heavy metals or pesticides).
The minimum frequency of raw material risk assessments was increased from annually to every 3 years which many organisations will welcome but additional stipulations were added for triggered review including:
- change in a raw material, raw material processing or supplier of the raw material,
- if a new risk emerges,
- following a product recall or withdrawal, where a specific raw material is implicated.
The supplier audits section has been bulked up with requirements for when 2nd or 3rd party audits are used. Companies are asked to demonstrate: competency of auditor, confirm that the scope of the audit includes product safety, traceability, HACCP review and good manufacturing practices. The site will be required to obtain and review a copy of the full audit report
SAQs scope must include product safety, traceability, HACCP and good manufacturing practices. Furthermore, SAQs must be reviewed and verified by a demonstrably competent person.
Maximum frequency of SAQs is limited to 3 years and suppliers shall be required to notify the site of any significant changes in the interim.
Food Safety Consultants and off-site packaging have now been classified as suppliers of services with all the implications around approval and monitoring of service suppliers.
Site Security and Food defense clauses have been significantly changed with new requirements focused around monitoring, prevention and tampering controls. Staff movement and site access controls were tightened. This includes external storage like tanks, silos, intake pipes etc.
The CIP section has been expanded significantly with the following requirements: validation of the system, availability of system schematics during audit, risk assessment for systems which use rinse solution recovery and requirement for having critical limits for CIP. These are listed as: times, detergent concentrations, temperatures and flow rate or pressure. CIP critical limits must be included in the validation.
Environmental monitoring must be in place in all production areas with open, ready-to-eat products. Sampling protocol, sampling point locations and frequencies must be based on the risk assessment.
The environmental programme must be reviewed at least annually or triggered reviews should be carried out in number of prescribed events.
Where cooking instructions are provided to ensure product safety, they shall be fully validated.
Requirement of ongoing shelf life assessment has been expanded to ongoing shelf life validation with additional implications in regard to what should be controlled.
A new clause has been added stipulating required controls for operation and testing of in line check weighers.
A new section 8 of the standard has been created and made applicable to all areas classified as High Risk, High Care and Ambient High Care. A number of clauses from historical sections 1-7 have now been moved to section 8.
New clauses focus on barrier control e.g. when equipment is removed from the area, the site shall have a documented procedure to ensure the cleanliness and removal of contamination hazards before being accepted back into the area.
Where portable equipment (e.g. handheld devices) is used in high risk or high care areas it is a requirement that these items are visually distinctive and dedicated for use in that area OR there shall be specific procedures (e.g. a full clean) to ensure this does not result in contamination.
Another clause which could result in the need for significant investment for some manufacturers is the new requirement for CIP systems used for cleaning high risk or high care areas. These systems are to be dedicated for use in that area only and separated from those used in low risk areas.
Earlier I mentioned section 9 which tackles traded goods. This section reiterates some of the typical BRC requirements and makes them specific to traded goods. Key areas covered are:
> Supplier approval, Monitoring and Review
> Records required
> Product Inspection and laboratory testing
> Product Claims
> Product legality
I hope you enjoyed this review. For those who want to go themselves through 81 pages of the draft link to the BRC, the website is below. I look forward to your comments either on my website, LinkedIn or Facebook.