By Richard Leathers, Food Safety Management Services Lead at Campden BRI
The eagerly anticipated BRC version 8 standard is being released in August 2018, with first audits being conducted against this from 1 February 2019. The BRC is the largest of the commercial standards, with over 19,000 food certificates issued annually by 1,500 auditors working for 64 certification bodies.
The standard is updated based on current trends and issues in the food industry, and aims to encourage the development of product safety culture, expand requirements for environmental monitoring, and ensure compatibility with the Global Food Safety Initiative. Consideration is also given to areas of high (and low) areas of non- conformances experienced during audits under previous BRC standards.
One of the most noticeable visible changes to version 8 is that there are now nine sections instead of the historical seven. In addition to the previous sections on Senior Management Commitment; HACCP, food safety & QMS, site standards, product control, process control and personnel, there are now sections on production risk zones and traded goods.
Regarding the new and significantly updated clauses that will have an impact and will require action and attention on certificated sites, the earliest new addition is the introduction of food safety and quality culture as a compulsory requirement.
Previously, this has been a voluntary requirement for companies but the importance of food safety and quality culture for all manufacturers was recognised when drafting the updated standard. Auditors will not be attempting to evaluate culture at a site; rather, the purpose is to encourage businesses to consider the importance of culture and therefore develop plans aimed at improving food safety culture.
This should include implementation of these plans and evaluating their success to drive continuous improvement. These become measurable objective requirements that can be audited. Other additional clauses to consider include clause 1.1.6, which requires companies to have a confidential reporting system for staff.
Some of the significant areas of non-conformance during recent BRC audits concern supplier approval and monitoring. At present, these are covered by a single clause but, in version 8, they are being separated into initial supplier approval and ongoing supplier monitoring, which will allow additional focus and direction for auditors and manufacturers.
Food defence and the potential for deliberate malicious contamination from both internal and external sources will now need to be risk assessed, defined, documented, controlled, monitored and reviewed. Many sites are looking at combining this with the requirements for food fraud because the methodology and principles defined in the TACCP guidance document are similar. Campden BRI’s guideline TACCP also covers both food fraud and food defence.
A whole new section on environmental monitoring requires risk-based programmes to be in place for pathogens or spoilage organisms for all production areas with open and ready-to-eat products. The individual clauses detail some very specific protocols and systems to be in place in this area, which may involve significant work for many sites.
There are also many areas and sections of the updated standard that are subtler but no less significant to manufacturers. Requirements such as the need to validate cooking instructions and shelf-life; training on labelling procedures; cyber security related to documents, records and equipment settings; understanding the significance of laboratory results; traceability procedures; and defining root cause analysis will all need to be worked on from release of the standard right through to first audits starting in February 2019.
For more information please contact Simon Lusher, Head of Food & Agri on +44 (0) 20 7459 5550.