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BRC Food Safety Standard, Issue 7 Requirements

Program Changes

On January 7, 2015, the British Retail Consortium (BRC) made available the Global Standard for Food Safety, issue 7. This new Standard along with all other BRC Global Standards are available for free electronic download from the BRC Bookshop.

The BRC Academy and BRC Approved Training Providers (ATP’s) are currently conducting training to issue 7 requirements. All new and recertifying sites to the BRC Food Safety Standard shall be required to certify under the requirements of issue 7 beginning July 1, 2015. Contact CERT ID for a list of ATP's.

The majority of Audit Protocol requirements remain the same for (re)certifying sites with updates to scope exclusion, grading, unannounced audit options, voluntary modules, and the Enrolment Program (renamed Global Markets Program).

Scope exclusion

Increased limitations to scope exclusion apply to issue 7 and only allow for products to be excluded from scope where the excluded products are clearly differentiated from products within the scope of certification AND the excluded products are produced in a physically segregated area of the site.

The BRC logo may not be used by sites where exclusions are permitted.

Grading

Two new grades are introduced in issue 7 (AA and D) along with redistribution of grading criteria for certification. Sites achieving 5 or fewer minor non-conformances can achieve the top grade of AA or AA+ where the unannounced audit option is selected.

Grading criteria was redistributed for A – D grades. Refer to Part III Audit Protocol of Food Safety Standard issue 7 for details on the non-conformance distribution for grading criteria.

Unannounced Audit

Unannounced audits remain a voluntary option in issue 7, but the requirement for a qualifying audit to participate in the program was removed. All sites are now eligible to participate in unannounced audits for certification; however, sites not previously certified may need to wait up to 12 months from application submission before the on-site audit is scheduled.

Voluntary Modules

Voluntary modules are new to the Food Safety Standard. This option provides sites a convenient way to achieve customer requirements, reduce audit redundancy, and enable certification via one audit report and certificate.

The development of voluntary modules and associated criteria are separate from the Food Safety Standard and can be located by visiting the BRC Global Standards website.

Global Markets Program (previously Enrolment Program)

One area of focus in updating the requirements of issue 7 was to update the Standard to enable greater accessibility to smaller sites and facilities with a food safety and quality management system in development. This is largely achieved through a tiered audit process known as the Global Markets program where sites may achieve basic or intermediate recognition to requirements of the Food Safety Standard.

Refer to Part III Audit Protocol of Food Safety Standard issue 7 for details on the requirements and benefits of the BRC Global Market Program.

Standard Requirement Changes

Issue 7 requirements were updated with a focus on improved transparency in the supply chain, food fraud and substitution risk assessment, reduction in product recalls attributed to incorrect labelling, brand protection, and legal compliance.

As a result, two new fundamental sections and five new sections were added to BRC’s Food Safety Standard.

3.5.1, Supplier and Raw Material Approval and Performance Monitoring

New Fundamental Section

Section 3.5.1 was upgraded to a fundamental section. The statement of intent did not change significantly other than to include authenticity of raw materials and packaging as risk assessment and supplier approval criteria. In this upgraded section, there are new requirements for sites to know the identity of the last manufacturer or packer where raw materials are purchased from agents and brokers and sites are required to obtain information from the agent/ broker or supplier to enable approval.

3.12, Customer Focus and Communication

New Section

Section 3.12 statement of intent requires a company to ensure that customer-specific policies and requirements are understood, implemented and communicated to all relevant staff and suppliers.

4.13, Management of Surplus Food and Products for Animal Feed

New Section

Section 4.13 statement of intent requires effective processes to ensure the safety and legality of site by-products. New requirements of this section focus on brand protection requiring sites to receive approval and comply with customer requirements where customer-branded surplus or out-of-specification product are used for alternative distribution.

5.2, Product Labelling

New Section

Section 5.2 statement of intent requires product labelling to comply with legal requirements and contain information for safe handling, display, storage and preparation of food product within the supply chain or by the customer. Labelling requirements from issue 6 were carried over to this new section and supplemented with new requirements for reviewing labels when changes occur to raw materials or product formulation and mechanisms for providing accurate information and updates where product labeling is the responsibility of the customer or a third party.

5.4, Produce Authenticity, Claims and Chain of Custody

New Section

Section 5.4 statement of intent requires systems to minimize the risk of purchasing fraudulent or adulterated raw materials and ensure that all product description and claims are legal, accurate and verified. Under issue 7, companies shall be required to have a process for acquiring information on adulteration and substitution threats of raw materials within the supply chain, documented risk assessment of known threats for raw material groups used by the company, and an assurance testing process where risk is identified.

Section requirements clarify differences between claims (e.g., identity preserved, assured status) and require sites to maintain the certification status for claims about methods of production (e.g., organic, Halal, Kosher).

6.2, Labelling and Pack Control

New Fundamental Section

Section 6.2 statement of intent requires controls of product labelling activities to ensure products are correctly labelled and coded. Packaging requirements from issue 6 were brought forward into this new section with additional requirements for allocation of packaging materials to packing lines, control in the packaging area to ensure packaging is available for immediate use only, and procedures to ensure correct set-up and rejection of on-line vision equipment used to check product labels and printing.

Additional Key Changes

New clauses in issue 7, which represent additional key changes include:

4.2.3 New clause

The requirement for locked external storage tanks, silos and intake pipes with external openings.

4.3.7 New clause

Requirements for a documented risk assessment and effective methods to prevent pathogen cross-contamination of finished product from raw materials, process and personnel flow, utilities, and air in ambient high-care areas.

Ambient High-Care Area is defined as an area maintained to a high standard where practices relating to the production of ambient finished product minimize contamination by pathogenic microorganism.

Refer to Appendix 2 of issue 7 for clarification and examples of products applicable to ambient high-care requirements.

4.7.5 New clause

The requirement for maintenance activities performed in high-risk and high-care areas to follow segregation requirements and where possible, utilize dedicated tools and equipment.

4.14.11 New clause

The requirement for employees to be knowledgeable of the signs of pest control activity and report evidence to the designated manager.

7.4.5 New clause

The requirement for protective clothing changes at a defined minimum frequency based on risk and minimum daily requirement for high-care/ high-risk areas.

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