Professional Documents
Culture Documents
Guide To Key Changes: Od Safety 8
Guide To Key Changes: Od Safety 8
FO 8
D
AR
GL
AL STAND
OB
GLOBAL STANDARD
AL STAN
FOOD SAFETY ISSUE 8
GUIDE TO KEY
CHANGES
OB
D
L
A
G
D
FO 7
OD SAFETY
WWW.BRCGLOBALSTANDARDS.COM 1
LIABILITY
BRC Global Standards1 publishes information and expresses opinions in good faith, but accepts no liability for any error or
omission in any such information or opinion, including any information or opinion contained in this publication.
Whilst BRC Global Standards has endeavoured to ensure that the information in this publication is accurate, it shall not be liable for
any damages (including without limitation damages for pure economic loss or loss of business or loss of profits or depletion of
goodwill or otherwise in each case, whether direct, indirect or consequential) or any claims for consequential compensation
whatsoever (howsoever caused) arising in contract, tort (including negligence or breach of statutory duty), misrepresentation,
restitution or otherwise, in connection with this publication or any information contained in it, or from any action or decision taken
as a result of reading this publication or any such information.
All warranties, conditions and other terms implied by statute or common law are, to the fullest extent permitted by law, excluded.
Nothing excludes or limits the liability of BRC Global Standards for death or personal injury caused by its negligence, for fraud or
fraudulent misrepresentation or for any matter which it would be illegal for it to exclude or attempt to exclude liability for.
The Global Standard for Food Safety Issue 8 Guide to Key Changes and the terms of the disclaimer set out above shall be
construed in accordance with English law and shall be subject to the non-exclusive jurisdiction of the English Courts.
COPYRIGHT
© BRC Global Standards 2018
All rights reserved. No part of this publication may be transmitted or reproduced in any form (including photocopying or storage
in any medium by electronic means) without the written permission of the copyright owner. Application for permission should
be addressed to the Operations Director of Global Standards at BRC Global Standards (contact details below). Full
acknowledgement of the author and source must be given.
The contents of this publication cannot be reproduced for the purposes of training or any other commercial activity.
No part of this publication may be translated without the written permission of the copyright owner.
Warning: Any unauthorised act in relation to a copyright work may result in both a civil claim for damages and criminal
prosecution.
Email: enquiries@brcglobalstandards.com
Website: www.brcglobalstandards.com
INTRODUCTION 4
WWW.BRCGLOBALSTANDARDS.COM 3
INTRODUCTION
BRC Global Standards published Issue 8 of the BRC Global Standard for Food Safety (hereafter referred to as the Standard) in
August 2018 and the new Standard will be used for all audits conducted from 1 February 2019. Certificates issued against Issue 7
will remain valid for the duration indicated on the certificate.
This document is intended to provide an introduction to the new Issue 8 and a guide to the changes (including the reasons) since
Issue 7. It provides a full list of all the changes to the requirements and should be used as a reference by companies who need to
update their quality systems in preparation for an audit against Issue 8. A full interpretation guideline which provides guidance on
all the clauses is also available, together with a number of topic-specific guidelines. All these documents can be obtained from
BRC Participate (www.brcparticipate.com) or purchased separately from the BRC bookshop (www.brcbookshop.com).
The feedback on Issue 7 was generally very positive and use of the Standard shows continued growth. The consultation and
review of emerging food safety concerns identified a number of opportunities for further development. The key objectives
identified for the working groups were to:
• ensure global applicability and continued alignment with GFSI benchmark requirements, including:
–– environmental monitoring
–– food defence/product security
• continue activities to reduce the burden of duplicate audits of certificated sites
• consider any potential implications of the US Food Safety Modernization Act (FSMA) requirements
• encourage the development of a product safety culture
• review the scope of the Standard
• add clarity to the requirements for high-risk, high-care and ambient high-care production zones
• review issues, incidents and recalls, including product packing and labelling.
The detail of the Standard was developed using two multi-stakeholder working groups: one in North America and one in Europe.
Each group was made up of industry representatives from retailers, certification bodies, trade associations, food manufacturers
and, in Europe, the accreditation body, the UK Accreditation Service (UKAS).
The draft Standard was released in November 2017. All of the comments received on the draft were reviewed before the final
version was produced. BRC Global Standards would like to thank all of those people who have contributed to the development
of Issue 8 of the Standard.
ENVIRONMENTAL MONITORING
The use of monitoring techniques within the factory is an important tool for identifying potential product contamination risks,
especially risks associated with micro-organisms (both pathogens and spoilage organisms). Compared with Issue 7, the
requirements in Issue 8 have been extensively expanded to encourage sites to develop rigorous monitoring programmes,
enabling them to take timely corrective action before product contamination occurs.
4 WWW.BRCGLOBALSTANDARDS.COM
HACCP/FOOD SAFETY PLAN
The working group felt that it was appropriate to review the wording for section 2 concerning the HACCP food safety plan.
Some countries (e.g. the US) have introduced regulatory requirements that incorporate all of the HACCP processes outlined
by the Codex Alimentarius but use different terminology.
Sites are not required to use the specific terminology of the Standard, but the expectation is that the requirements of the Standard
will be fully met.
The scope of the product security/food defence risk assessment is exactly the same as the process flow diagram referred to in
clause 2.5.1. It therefore includes all of the stages when the product is under the management control of the company.
PRODUCT LABELLING
An analysis of product recall and withdrawal data shows that the underlying cause of the greatest number of problems is still
associated with the labelling and packing of products. Incorrectly labelled products are usually the result of: errors made in the
original label information; subsequent changes to ingredients or suppliers (which are not reflected on the label); or errors made
during the packing process. To attempt to focus on the issue, the Standard has updated some of the requirements relating to
pack and label control. These include:
• ensuring ‘change control’ at goods receipt. Goods receipt staff need accurate, up-to-date information so that only the correct
version of materials (e.g. packaging and labels) are accepted on site
• control of on-site printing (e.g. date codes) to ensure that only authorised staff can amend these, and verification that the
inputted information is accurate
• where sites have invested in online verification equipment (e.g. bar code scanners), these need to be set up and tested to
ensure that sites can be confident of the control and monitoring they provide
• during the vertical audit, comparison by the auditor of a sample of product labels with information in the specification and
recipe to confirm the accuracy of those labels. The auditor will also inspect the processes used by the site to establish label
information.
ADDITIONAL MODULES
Issue 7 was designed to enable the addition of voluntary modules to the routine audit, to enable sites to demonstrate compliance
with specific sets of requirements to meet specific market or customer requirements. This process will continue for Issue 8.
TRADED PRODUCTS
Issue 7 introduced a traded goods module for sites that store and sell food products that are not manufactured, processed or
packed on site. Issue 8 has incorporated these requirements into the main text of the Standard (section 9). This has the
advantage of locating the text within the main document, thus allowing the module to be accredited at the same time as the rest
of the Standard.
Section 9 will remain voluntary and any site with applicable products may opt into these additional requirements to demonstrate
to customers that good management practices relating to traded products are in place. Sites wishing to be audited to section 9
(the traded products requirements) should notify their chosen certification body in advance of the audit.
COLOUR-CODING OF REQUIREMENTS
Production processes represent the key activities on site. The audit process therefore gives specific emphasis to the practical
implementation of food safety procedures within the factory and general good manufacturing practices. Auditing these areas
forms a significant proportion of the audit (around 50% of the audit time is spent auditing production and site facilities,
interviewing staff, observing processes and reviewing documentation in production areas with the relevant staff).
Production areas include factory production, storage, dispatch, engineering, on-site laboratory facilities and external areas such
as site security.
WWW.BRCGLOBALSTANDARDS.COM 5
As an aid to this process, the requirements within the Standard have been colour-coded. Colour-coding shows the activities that
would usually be audited as part of the assessment of the production areas and facilities, and those that would form part of an
audit of records, systems and documentation.
DOCUMENTED PROCEDURES
In many places within the Standard there is a requirement for the sites to develop procedures, plans or records. Issue 8 doesn’t
specifically state that these should be documented, as this would require repeating the term ‘documented’ in many of the clauses.
However, the definitions in the Standard glossary (e.g. procedure) clearly indicate that a documented system is required, as the
company needs to be able to demonstrate that systems are in place, working consistently and that documents are available for
reference when required. These documents can be hard copy (i.e. paper-based) or electronic.
UNANNOUNCED AUDITS
Previous versions of the Standard have provided two options for unannounced audits:
The option 2 split audit has consistently proven to be unpopular, with very few sites selecting to be audited in this way. It has
therefore been removed from the Standard.
The unannounced audit programme remains voluntary and sites can still continue to opt for an announced or an
unannounced audit.
The contents of the interim report will be strictly limited to the date of the audit, details of the audit scope and the non-conformities
found. It will not include grading or certification details, as these cannot be established until the site has completed the corrective
actions associated with any non-conformities and provided evidence of these corrective actions to the certification body.
The interim report will be available to the site and any organisation the site opts to share the report with.
The full report will still be uploaded to the BRC Global Standards Directory within 49 days of the completion of the audit.
6 WWW.BRCGLOBALSTANDARDS.COM
DETAILED CHANGES TO THE
REQUIREMENTS
The following tables highlight the changes to the requirements between Issue 7 and Issue 8 and provide a brief commentary on
the reasons for each change, where applicable.
Changes from Issue 7 have been highlighted in red text in the column headed ‘Issue 8’. Please note, however, that it is the
responsibility of the site to study all the requirements of the Standard to ensure that these are understood and that suitable
processes are in place to ensure compliance.
1.1.1 The site shall have a 1.1.1 The site shall have a ‘Authentic’ added to
documented policy which documented policy which reflect the need for
states the site’s intention to states the site’s intention to the prevention of
meet its obligation to meet its obligation to food fraud to be
produce safe and legal produce safe, legal and included within the
products to the specified authentic products to the company’s
quality and its specified quality, and its activities.
responsibility to its responsibility to its
customers. This shall be: customers. This shall be:
WWW.BRCGLOBALSTANDARDS.COM 7
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
8 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
WWW.BRCGLOBALSTANDARDS.COM 9
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
1.1.4 The site shall have a 1.1.5 The site shall have a Text added to
demonstrable meeting demonstrable meeting provide clarity
programme which enables programme which enables relating to the
food safety, legality and food safety, legality, mechanisms for
quality issues to be brought integrity and quality issues reporting and
to the attention of senior to be brought to the dealing with those
management at least attention of senior issues relating to
monthly and allows for the management. These product safety
resolution of issues meetings shall occur at which require
requiring immediate action. least monthly. immediate action.
Employees shall be aware
of the need to report any
evidence of unsafe or
out-of-specification
product or raw materials, to
a designated manager to
enable the resolution of
issues requiring immediate
action.
10 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
1.1.7 The site shall have a 1.1.9 The site shall have a
genuine, original hard copy genuine, original hard copy
or electronic version of the or electronic version of the
current Standard available current Standard available
and be aware of any and be aware of any
changes to the Standard or changes to the Standard or
protocol that are published protocol that are published
on the BRC website. on the BRC Global
Standards website.
WWW.BRCGLOBALSTANDARDS.COM 11
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
12 WWW.BRCGLOBALSTANDARDS.COM
1.2 ORGANISATIONAL STRUCTURE, RESPONSIBILITIES AND MANAGEMENT
AUTHORITY
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
The company shall have a clear organisational The company shall have a clear organisational
structure and lines of communication to enable structure and lines of communication to enable
effective management of product safety, legality effective management of product safety, legality
and quality. and quality.
1.2.1 The company shall have an 1.2.1 The company shall have an
organisation chart organisation chart
demonstrating the demonstrating the
management structure of management structure of
the company. The the company. The
responsibilities for the responsibilities for the
management of activities management of activities
which ensure food safety, which ensure food safety,
legality and quality shall be integrity, legality and quality
clearly allocated and shall be clearly allocated
understood by the and understood by the
managers responsible. managers responsible.
It shall be clearly It shall be clearly
documented who documented who
deputises in the absence of deputises in the absence of
the responsible person. the responsible person.
WWW.BRCGLOBALSTANDARDS.COM 13
2 THE FOOD SAFETY PLAN – HACCP
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
The company shall have a fully implemented and The company shall have a fully implemented and Some countries
effective food safety plan based on Codex effective food safety plan incorporating the (e.g. the US) have
Alimentarius HACCP principles. Codex Alimentarius HACCP principles. introduced
regulatory
requirements that
incorporate all of the
HACCP processes
outlined by the
Codex Alimentarius
but use different
terminology.
The specific
terminology within
the Standard, such
as HACCP,
prerequisites or
critical control
points, are intended
to utilise the most
commonly used
global terminology
to describe
expectations. Sites
are not required to
use the specific
terminology of the
Standard, but are
expected to fully
meet the
requirements.
14 WWW.BRCGLOBALSTANDARDS.COM
2.1 THE HACCP FOOD SAFETY TEAM (EQUIVALENT TO CODEX ALIMENTARIUS
STEP 1)
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
2.1.1 The HACCP plan shall be 2.1.1 The HACCP or food safety Team leader’s
developed and managed plan shall be developed knowledge,
by a multi-disciplinary food and managed by a experience and
safety team that includes multi-disciplinary food training expanded.
those responsible for safety team that includes
quality/technical, those responsible for
production operations, quality assurance,
engineering and other technical management,
relevant functions. production operations,
engineering and other
The team leader shall have
relevant functions.
an in-depth knowledge of
HACCP and be able to The team leader shall have
demonstrate competence an in-depth knowledge of
and experience. Codex HACCP principles
(or equivalent) and be able
The team members shall
to demonstrate
have specific knowledge
competence, experience
of HACCP and relevant
and training. Where there is
knowledge of product,
a legal requirement for
process and associated
specific training, this shall
hazards.
be in place.
In the event of the site not
The team members shall
having appropriate
have specific knowledge of
in-house knowledge,
HACCP and relevant
external expertise may be
knowledge of products,
used, but day-to-day
processes and associated
management of the food
hazards.
safety system shall remain
the responsibility of the In the event of the site not
company. having the appropriate
in-house knowledge,
external expertise may be
used, but day-to-day
management of the food
safety system shall remain
the responsibility of the
company.
2.1.2 The scope of each HACCP 2.1.2 The scope of each HACCP
plan, including the or food safety plan,
products and processes including the products and
covered, shall be defined. processes covered, shall
be defined.
WWW.BRCGLOBALSTANDARDS.COM 15
2.2 PREREQUISITE PROGRAMMES
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
2.2.1 The site shall establish and 2.2.1 The site shall establish and
maintain environmental maintain environmental
and operational and operational
programmes necessary to programmes necessary to
create an environment create an environment
suitable to produce safe suitable to produce safe
and legal food products and legal food products
(prerequisite programmes). (prerequisite programmes).
As a guide these may As a guide these may
include the following, include the following,
although this is not an although this is not an
exhaustive list: exhaustive list:
16 WWW.BRCGLOBALSTANDARDS.COM
2.3 DESCRIBE THE PRODUCT (EQUIVALENT TO CODEX ALIMENTARIUS STEP 2)
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
2.3.1 A full description for each 2.3.1 A full description for each
product or group of product or group of
products shall be products shall be
developed, which includes developed, which includes
all relevant information on all relevant information on
food safety. As a guide, this food safety. As a guide, this
may include the following, may include the following,
although this is not an although this is not an
exhaustive list: exhaustive list:
WWW.BRCGLOBALSTANDARDS.COM 17
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
2.4.1 The intended use of the 2.4.1 The intended use of the
product by the customer, product by the customer,
and any known alternative and any known alternative
use, shall be described, use, shall be described,
defining the consumer defining the consumer
target groups, including target groups, including
the suitability of the product the suitability of the product
for vulnerable groups of the for vulnerable groups of the
population (e.g. infants, population (e.g. infants,
elderly, allergy sufferers). elderly, allergy sufferers).
18 WWW.BRCGLOBALSTANDARDS.COM
2.5 CONSTRUCT A PROCESS FLOW DIAGRAM (EQUIVALENT TO CODEX
ALIMENTARIUS STEP 4)
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
WWW.BRCGLOBALSTANDARDS.COM 19
2.6 VERIFY FLOW DIAGRAM (EQUIVALENT TO CODEX ALIMENTARIUS STEP 5)
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
2.6.1 The HACCP food safety 2.6.1 The HACCP food safety Colour-coding
team shall verify the team shall verify the amended to reflect
accuracy of the flow accuracy of the flow the fact that auditors
diagrams by on-site audit diagrams by on-site audit will compare the
and challenge at least and challenge at least flow diagram with
annually. Daily and annually. Daily and the actual practices
seasonal variations shall be seasonal variations shall be operating in the
considered and evaluated. considered and evaluated. production area.
Records of verified flow Records of verified flow
diagrams shall be diagrams shall be
maintained. maintained.
2.7 LIST ALL POTENTIAL HAZARDS ASSOCIATED WITH EACH PROCESS STEP,
CONDUCT A HAZARD ANALYSIS AND CONSIDER ANY MEASURES TO
CONTROL IDENTIFIED HAZARDS (EQUIVALENT TO CODEX ALIMENTARIUS
STEP 6, PRINCIPLE 1)
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
2.7.1 The HACCP food safety 2.7.1 The HACCP food safety Typical types of
team shall identify and team shall identify and hazard have been
record all the potential record all the potential added for clarity.
hazards that are reasonably hazards that are reasonably
expected to occur at each expected to occur at each
step in relation to product, step in relation to product,
process and facilities. process and facilities. This
This shall include hazards shall include hazards
present in raw materials, present in raw materials,
those introduced during those introduced during
the process or surviving the process or surviving
the process steps, and the process steps, and
allergen risks (refer to consideration of the
clause 5.3). It shall also take following types of hazard:
account of the preceding
and following steps in the • microbiological
process chain. • physical contamination
• chemical and
radiological
contamination
• fraud (e.g. substitution
or deliberate/intentional
adulteration)
• malicious contamination
of products
• allergen risks
(see clause 5.3).
It shall also take account of
the preceding and
following steps in the
process chain.
20 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
2.7.2 The HACCP food safety 2.7.2 The HACCP food safety
team shall conduct a team shall conduct a
hazard analysis to identify hazard analysis to identify
hazards which need to be hazards which need to be
prevented, eliminated or prevented, eliminated or
reduced to acceptable reduced to acceptable
levels. Consideration shall levels. Consideration shall
be given to the following: be given to the following:
2.7.3 The HACCP food safety 2.7.3 The HACCP food safety
team shall consider the team shall consider the
control measures control measures
necessary to prevent or necessary to prevent or
eliminate a food safety eliminate a food safety
hazard or reduce it to an hazard or reduce it to an
acceptable level. Where acceptable level. Where
the control is achieved the control is achieved
through existing through existing
prerequisite programmes, prerequisite programmes,
this shall be stated and the this shall be stated and the
adequacy of the adequacy of the
programme to control the programme to control the
specific hazard validated. specific hazard validated.
Consideration may be Consideration may be
given to using more than given to using more than
one control measure. one control measure.
WWW.BRCGLOBALSTANDARDS.COM 21
2.8 DETERMINE THE CRITICAL CONTROL POINTS (CCPS) (EQUIVALENT TO
CODEX ALIMENTARIUS STEP 7, PRINCIPLE 2)
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
2.8.1 For each hazard that 2.8.1 For each hazard that
requires control, control requires control, control
points shall be reviewed to points shall be reviewed to
identify those that are identify those that are
critical. This requires a critical. This requires a
logical approach and may logical approach and may
be facilitated by use of a be facilitated by use of a
decision tree. Critical decision tree. Critical
control points (CCPs) shall control points (CCPs) shall
be those control points be those control points
which are required in order which are required in order
to prevent or eliminate a to prevent or eliminate a
food safety hazard or food safety hazard or
reduce it to an acceptable reduce it to an acceptable
level. If a hazard is identified level. If a hazard is identified
at a step where control is at a step where control is
necessary for safety but the necessary for safety but the
control does not exist, the control does not exist, the
product or process shall be product or process shall be
modified at that step, or at modified at that step, or at
an earlier step, to provide a an earlier step, to provide a
control measure. control measure.
22 WWW.BRCGLOBALSTANDARDS.COM
2.9 ESTABLISH CRITICAL LIMITS FOR EACH CCP (EQUIVALENT TO CODEX
ALIMENTARIUS STEP 8, PRINCIPLE 3)
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
2.9.1 For each CCP, the 2.9.1 For each CCP, the
appropriate critical limits appropriate critical limits
shall be defined in order to shall be defined in order to
identify clearly whether the identify clearly whether the
process is in or out of process is in or out of
control. Critical limits control. Critical limits
shall be: shall be:
2.9.2 The HACCP food safety 2.9.2 The HACCP food safety
team shall validate each team shall validate each
CCP. Documented CCP. Documented
evidence shall show that evidence shall show that
the control measures the control measures
selected and critical limits selected and critical limits
identified are capable of identified are capable of
consistently controlling the consistently controlling the
hazard to the specified hazard to the specified
acceptable level. acceptable level.
WWW.BRCGLOBALSTANDARDS.COM 23
2.10 ESTABLISH A MONITORING SYSTEM FOR EACH CCP (EQUIVALENT TO
CODEX ALIMENTARIUS STEP 9, PRINCIPLE 4)
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
24 WWW.BRCGLOBALSTANDARDS.COM
2.11 ESTABLISH A CORRECTIVE ACTION PLAN (EQUIVALENT TO CODEX
ALIMENTARIUS STEP 10, PRINCIPLE 5)
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
2.11.1 The HACCP food safety 2.11.1 The HACCP food safety
team shall specify and team shall specify and
document the corrective document the corrective
action to be taken when action to be taken when
monitored results indicate monitored results indicate
a failure to meet a control a failure to meet a control
limit, or when monitored limit, or when monitored
results indicate a trend results indicate a trend
towards loss of control. towards loss of control.
This shall include the action This shall include the action
to be taken by nominated to be taken by nominated
personnel with regard to personnel with regard to
any products that have any products that have
been manufactured during been manufactured during
the period when the the period when the
process was out of control. process was out of control.
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
WWW.BRCGLOBALSTANDARDS.COM 25
2.13 HACCP DOCUMENTATION AND RECORD-KEEPING (EQUIVALENT TO
CODEX ALIMENTARIUS STEP 12, PRINCIPLE 7)
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
26 WWW.BRCGLOBALSTANDARDS.COM
2.14 REVIEW THE HACCP PLAN
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
2.14.1 The HACCP food safety 2.14.1 The HACCP food safety Updated to reflect
team shall review the team shall review the the GFSI benchmark
HACCP plan and HACCP or food safety plan requirement.
prerequisite programmes and prerequisite
at least annually and prior programmes at least
to any changes which may annually and prior to any
affect product safety. As a changes which may affect
guide, these may include food safety. As a guide,
the following, although this these may include the
is not an exhaustive list: following, although this is
not an exhaustive list:
• change in raw materials
or supplier of raw • change in raw materials
materials or supplier of raw
• change in ingredients/ materials
recipe • change in ingredients/
• change in processing recipe
conditions, process flow • change in processing
or equipment conditions, process flow
• change in packaging, or equipment
storage or distribution • change in packaging,
conditions storage or distribution
• change in consumer conditions
use • change in consumer use
• emergence of a new risk • emergence of a new risk
(e.g. known adulteration (e.g. known adulteration
of an ingredient) of an ingredient or other
• following a recall relevant, published
• new developments in information, such as the
scientific information recall of a similar
associated with product)
ingredients, process or • review following a recall
product. • new developments in
scientific information
Appropriate changes
associated with
resulting from the review
ingredients, process or
shall be incorporated into
product.
the HACCP plan and/or
prerequisite programmes, Appropriate changes
fully documented and resulting from the review
validation recorded. shall be incorporated into
the HACCP or food safety
plan and/or prerequisite
programmes, fully
documented and the
validation recorded.
Where appropriate, the
changes shall also be
reflected in the company’s
product safety policy and
food safety objectives.
WWW.BRCGLOBALSTANDARDS.COM 27
3 FOOD SAFETY AND QUALITY MANAGEMENT SYSTEM
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
The company’s processes and procedures to The company’s processes and procedures to
meet the requirements of this Standard shall be meet the requirements of this Standard shall be
documented to allow consistent application, documented to allow consistent application,
facilitate training, and support due diligence in facilitate training, and support due diligence in
the production of a safe product. the production of a safe product.
3.1.2 The food safety and quality 3.1.2 The food safety and quality
manual shall be fully manual shall be fully
implemented and the implemented and the
manual or relevant manual or relevant
components shall be components shall be
readily available to readily available to
relevant staff. relevant staff.
3.1.3 All procedures and work 3.1.3 All procedures and work
instructions shall be clearly instructions shall be clearly
legible, unambiguous, in legible, unambiguous, in
appropriate languages and appropriate languages and
sufficiently detailed to sufficiently detailed to
enable their correct enable their correct
application by appropriate application by appropriate
staff. This shall include the staff. This shall include the
use of photographs, use of photographs,
diagrams or other pictorial diagrams or other pictorial
instructions where written instructions where written
communication alone is communication alone is
not sufficient (e.g. there are not sufficient (e.g. there are
issues of literacy or foreign issues of literacy or foreign
language). language).
28 WWW.BRCGLOBALSTANDARDS.COM
3.2 DOCUMENTATION CONTROL (NOW DOCUMENT CONTROL)
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
The company shall operate an effective The company shall operate an effective
document control system to ensure that only the document control system to ensure that only the
correct versions of documents, including correct versions of documents, including
recording forms, are available and in use. recording forms, are available and in use.
3.2.1 The company shall have a 3.2.1 The company shall have a Effective
procedure to manage procedure to manage management of
documents which form part documents which form part documentation
of the food safety and of the food safety and must include
quality system. This shall quality system. This shall electronic systems
include: include: as well as printed
documents.
• a list of all controlled • a list of all controlled
documents indicating documents indicating
the latest version the latest version
number number
• the method for the • the method for the
identification and identification and
authorisation of authorisation of
controlled documents controlled documents
• a record of the reason • a record of the reason
for any changes or for any changes or
amendments to amendments to
documents documents
• the system for the • the system for the
replacement of existing replacement of existing
documents when these documents when these
are updated. are updated.
Where documents are
stored in electronic form
these shall also be:
• stored securely
(e.g. with authorised
access, control of
amendments, or
password protected)
• backed up to prevent
loss.
WWW.BRCGLOBALSTANDARDS.COM 29
3.3 RECORD COMPLETION AND MAINTENANCE
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
The site shall maintain genuine records to The site shall maintain genuine records to
demonstrate the effective control of product demonstrate the effective control of product
safety, legality and quality. safety, legality and quality.
30 WWW.BRCGLOBALSTANDARDS.COM
3.4 INTERNAL AUDITS
WWW.BRCGLOBALSTANDARDS.COM 31
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
3.4.3 The internal audit 3.4.3 The internal audit Slightly amended –
programme shall be fully programme shall be fully recording objective
implemented. Internal audit implemented. Internal audit evidence is an
reports shall identify reports shall identify important feature of
conformity as well as conformity as well as audits, as this
non-conformity and the non-conformity and provides due
results shall be reported to include objective evidence diligence
the personnel responsible of the findings. information which
for the activity audited. may be required at a
The results shall be
Corrective actions and later date.
reported to the personnel
timescales for their
responsible for the activity
implementation shall be
audited.
agreed and completion of
the actions verified. Corrective and preventive
actions, and timescales for
their implementation, shall
be agreed and their
completion verified.
3.4.4 In addition to the internal 3.4.4 In addition to the internal These inspections
audit programme there audit programme, there are in addition to the
shall be a programme of shall be a separate internal audit
documented inspections programme of programme outlined
to ensure that the factory documented inspections in clauses 3.4.1–
environment and to ensure that the factory 3.4.3.
processing equipment is environment and
Sites may find it
maintained in a suitable processing equipment are
useful to consider
condition for food maintained in a suitable
the glossary
production. These condition for food
definition of an
inspections shall include: production. At a minimum,
inspection as
these inspections shall
• hygiene inspections to include:
outlined in the
assess cleaning and Standard.
housekeeping • hygiene inspections to
performance assess cleaning and
• fabrication inspections housekeeping
to identify risks to the performance
product from the • fabrication inspections
building or equipment. to identify risks to the
product from the
The frequency of these
building or equipment.
inspections shall be based
on risk but will be no less The frequency of these
than once per month in inspections shall be based
open product areas. on risk but will be no less
than once per month in
open product areas.
32 WWW.BRCGLOBALSTANDARDS.COM
3.5 SUPPLIER AND RAW MATERIAL APPROVAL AND PERFORMANCE
MONITORING
3.5.1 MANAGEMENT OF SUPPLIERS OF RAW MATERIALS AND PACKAGING
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
The company shall have an effective supplier The company shall have an effective supplier The working group
approval and monitoring system to ensure that approval and monitoring system to ensure that reviewed the
any potential risks from raw materials (including any potential risks from raw materials (including glossary definition
packaging) to the safety, authenticity, legality and primary packaging) to the safety, authenticity, of raw material to
quality of the final product are understood and legality and quality of the final product are ensure that it was
managed. understood and managed. consistently applied
throughout the
Standard,
particularly in this
section.
WWW.BRCGLOBALSTANDARDS.COM 33
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
3.5.1.2 The company shall have a 3.5.1.2 The company shall have a Initial supplier
documented supplier documented supplier approval and
approval and ongoing approval procedure to ongoing monitoring
monitoring procedure to ensure that all suppliers of and approval
ensure that all suppliers of raw materials, including processes have
raw materials, including primary packaging, been divided into
packaging, effectively effectively manage risks to separate clauses to
manage risks to raw raw material quality and reflect the fact that
material quality and safety safety and are operating there are often
and are operating effective effective traceability different
traceability processes. processes. The approval requirements for
The approval and procedure shall be based these activities.
monitoring procedure shall on risk and include either Ongoing monitoring
be based on risk and one or a combination of: and approval is
include one or a now covered in
combination of: • a valid certification to clause 3.5.1.3.
the applicable BRC
• certification (e.g. to BRC Global Standard or Certificates used as
Global Standards or GFSI-benchmarked evidence in supplier
other GFSI-recognised standard. The scope of approval processes
scheme) the certification shall must be valid and
• supplier audits, with a include the raw materials the accuracy of the
scope to include purchased information received
product safety, • supplier audits, with a from the supplier
traceability, HACCP scope to include must be confirmed.
review and good product safety, For example, the
manufacturing traceability, HACCP BRC Directory
practices, undertaken review and good (www.brcdirectory.
by an experienced and manufacturing com) can be used to
demonstrably practices, undertaken confirm the
competent product by an experienced and supplier’s
safety auditor demonstrably certification status
competent product and that the product
or, for suppliers assessed
safety auditor. Where scope includes the
as low risk only, supplier
the supplier audit is raw materials
questionnaires.
completed by a second purchased by the
or third party, the site.
company shall be
able to:
34 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
3.5.1.2 cont. Where approval is based 3.5.1.2 cont. –– demonstrate the The requirements
on questionnaires, these competency of the have been amended
shall be reissued at least auditor to recognise that
every 3 years and suppliers –– confirm that the some supplier
will be required to notify the scope of the audit audits may be
site of any significant includes product completed by third
changes in the interim. safety, traceability, parties. These
HACCP review and audits may be
The site shall have an
good manufacturing accepted in the
up-to-date list of approved
practices absence of the site
suppliers.
–– obtain and review a completing its own
copy of the full audit audit, providing that:
report
• the competency
or of the auditor is
appropriate for
• where a valid risk-based the type of
justification is provided
product and
and the supplier is
standard of audit
assessed as low risk
conducted
only, a completed
supplier questionnaire • at a minimum,
the scope of the
may be used for initial
audit addresses
approval. The
product safety,
questionnaire shall have
traceability,
a scope that includes
HACCP and
product safety,
good
traceability, HACCP
manufacturing
review and good
practices
manufacturing
practices, and it shall • a copy of the full
audit report is
have been reviewed and
available – not
verified by a
just a certificate.
demonstrably
competent person. Finally, the
requirements have
also been amended
for low-risk products
to be initially
approved by
supplier
questionnaire.
WWW.BRCGLOBALSTANDARDS.COM 35
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
36 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
3.5.1.3 Where raw materials are 3.5.1.5 Where raw materials Amended to make it
purchased from agents or (including primary clear that this clause
brokers, the site shall know packaging) are purchased applies whenever a
the identity of the last from companies that are food raw material is
manufacturer or packer, or not the manufacturer, purchased from an
for bulk commodity packer or consolidator organisation that is
products the consolidation (e.g. purchased from an not the
place of the raw material. agent, broker or manufacturer,
wholesaler), the site shall processor, packer
Information to enable the
know the identity of the last or consolidator.
approval of the
manufacturer or packer, or
manufacturer, packer or
for bulk commodity
consolidator, as in clause
products the consolidation
3.5.1.2, shall be obtained
place of the raw material.
from the agent/broker or
directly from the supplier, Information to enable the
unless the agent/broker is approval of the
themselves certificated to manufacturer, packer or
the BRC Global Standard consolidator, as in clauses
for Agents and Brokers. 3.5.1.1 and 3.5.1.2, shall be
obtained from the agent/
broker or directly from the
supplier, unless the agent/
broker is themselves
certificated to a BRC
Standard (e.g. BRC Global
Standard for Agents and
Brokers) or a standard
benchmarked by GFSI.
WWW.BRCGLOBALSTANDARDS.COM 37
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
38 WWW.BRCGLOBALSTANDARDS.COM
3.5.2 RAW MATERIAL AND PACKAGING ACCEPTANCE, MONITORING AND MANAGEMENT PROCEDURES
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
Controls on the acceptance of raw materials Controls on the acceptance of raw materials
including packaging shall ensure that these do (including primary packaging) shall ensure that
not compromise the safety, legality or quality of these do not compromise the safety, legality or
products and where appropriate any claims of quality of products and where appropriate any
authenticity. claims of authenticity.
3.5.2.1 The company shall have a 3.5.2.1 The company shall have a ‘Documented’
documented procedure for procedure for the removed – see
the acceptance of raw acceptance of raw ‘Documented
materials and packaging materials and primary procedures’ in the
on receipt based upon the packaging on receipt Introduction for a full
risk assessment (clause based upon the risk explanation.
3.5.1.1). Raw material assessment (clause
including packaging 3.5.1.1). Acceptance of raw
acceptance and its release materials (including
for use shall be based on primary packaging) and
one or a combination of: their release for use shall be
based on either one or a
• product sampling and combination of:
testing
• visual inspection on • product sampling and
receipt testing
• certificates of analysis • visual inspection on
– specific to the receipt
consignment • certificates of analysis
• certificates of (specific to the
conformance. consignment)
A list of raw materials • certificates of
conformance.
including packaging and
the requirements to be met A list of raw materials
for acceptance shall be (including primary
available. The parameters packaging) and the
for acceptance and requirements to be met for
frequency of testing shall acceptance shall be
be clearly defined, available. The parameters
implemented and for acceptance and
reviewed. frequency of testing shall
be clearly defined,
implemented and
reviewed.
WWW.BRCGLOBALSTANDARDS.COM 39
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
40 WWW.BRCGLOBALSTANDARDS.COM
3.5.3 MANAGEMENT OF SUPPLIERS OF SERVICES
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
The company shall be able to demonstrate that The company shall be able to demonstrate that
where services are outsourced the service is where services are outsourced, the service is
appropriate and any risks presented to food appropriate and any risks presented to food
safety, legality and quality have been evaluated to safety, legality and quality have been evaluated to
ensure effective controls are in place. ensure effective controls are in place.
WWW.BRCGLOBALSTANDARDS.COM 41
3.5.4 MANAGEMENT OF OUTSOURCED PROCESSING AND PACKING (NOW MANAGEMENT OF OUTSOURCED
PROCESSING)
ISSUE 7 ISSUE 8 COMMENTS
STATEMENT OF INTENT STATEMENT OF INTENT
Where any process step in the manufacture or Where any process step in the manufacture of a Outsourced or
packing of a product which is included within the product is outsourced to a third party or subcontracted
scope of certification is subcontracted to a third undertaken at another site, this shall be managed processes occur
party or undertaken at another site, this shall be to ensure it does not compromise the safety, when a partially
managed to ensure it does not compromise the legality, quality or authenticity of the product. processed product
safety, legality, quality or authenticity of the is sent to another
product. site for a process
step(s) before being
returned to the site
for completion of
the production/
packing operation.
It is vital that the site
manages this
process to ensure
that product safety
is maintained and
that customers have
visibility of these
activities when they
occur.
Packing of products
by third parties (e.g.
contract packing)
has been removed
from this section as
this should not form
part of the scope of
the audit (the
packing site is
encouraged to have
its own
certification).
3.5.4.1 The company shall be able 3.5.4.1 The company shall be able
to demonstrate that where to demonstrate that, where
part of the production part of the production
process or final packing is process or any part of the
outsourced and final packing is outsourced
undertaken off-site this has and undertaken off-site,
been declared to the brand this has been declared to
owner and, where required, the brand owner and,
approval granted. where required, approval
granted.
42 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
3.5.4.2 The company shall ensure 3.5.4.2 The company shall ensure This requirement
that subcontractors are that outsourced mirrors the wording
approved and monitored processors are approved used in Issue 8,
by successful completion and monitored, to ensure clause 3.5.1.2 for the
of either: that they effectively approval of
manage risks to product suppliers of raw
• certification to the safety and quality and are materials.
applicable BRC Global
operating effective
Standard for Food
traceability processes.
Safety or other
GFSI‑recognised The approval and
scheme monitoring procedure shall
• a documented site audit be based on risk and
with a scope to include include either one or a
product safety, combination of:
traceability, HACCP
review and good • a valid certification to
the applicable BRC
manufacturing practices
Global Standard or
by an experienced and
GFSI-benchmarked
demonstrably
standard. The scope of
competent product
the certification shall
safety auditor.
include the raw materials
purchased
or
WWW.BRCGLOBALSTANDARDS.COM 43
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
• be undertaken in • be undertaken in
accordance with accordance with
established contracts established contracts
which clearly define any which clearly define any
processing and/or processing and/or
packing requirements packing requirements
and product and product
specification specification
• maintain product • maintain product
traceability. traceability.
44 WWW.BRCGLOBALSTANDARDS.COM
3.6 SPECIFICATIONS
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
Specifications shall exist for raw materials Specifications shall exist for raw materials
including packaging, finished products and any (including primary packaging), finished products
product or service which could affect the integrity and any product or service which could affect the
of the finished product. integrity of the finished product.
WWW.BRCGLOBALSTANDARDS.COM 45
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
3.6.3 The company shall seek 3.6.3 Where the company is Slight amendment
formal agreement of manufacturing customer- to clarify that formal
specifications with relevant branded products, it shall agreement should
parties. Where seek formal agreement of be between the site
specifications are not the finished product and the brand
formally agreed then the specifications. Where owner of the
company shall be able to specifications are not product.
demonstrate that it has formally agreed then the
taken steps to ensure company shall be able to
formal agreement is in demonstrate that it has
place. taken steps to ensure
formal agreement is in
place.
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
The site shall be able to demonstrate that it uses The site shall be able to demonstrate that it uses
the information from identified failures in the food the information from identified failures in the food
safety and quality management system to make safety and quality management system to make
necessary corrections and prevent recurrence. necessary corrections and prevent recurrence.
3.7.1 The site shall have a 3.7.1 The site shall have a
documented procedure for procedure for handling and
handling and correcting correcting failures
failures identified in the identified in the food safety
food safety and quality and quality management
system. system.
46 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
WWW.BRCGLOBALSTANDARDS.COM 47
3.8 CONTROL OF NON-CONFORMING PRODUCT
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
The site shall ensure that any out-of-specification The site shall ensure that any out-of-specification
product is effectively managed to prevent product is effectively managed to prevent
unauthorised release. unauthorised release.
48 WWW.BRCGLOBALSTANDARDS.COM
3.9 TRACEABILITY
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
The site shall be able to trace all raw material The site shall be able to trace all raw material
product lots (including packaging) from its product lots (including primary packaging) from
suppliers through all stages of processing and its suppliers through all stages of processing and
dispatch to its customers and vice versa. dispatch to its customers and vice versa.
WWW.BRCGLOBALSTANDARDS.COM 49
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
3.9.2 The site shall test the 3.9.3 The site shall test the
traceability system across traceability system across
the range of product the range of product
groups to ensure groups to ensure
traceability can be traceability can be
determined from raw determined from the
material including primary supplier of raw material
packaging to finished (including primary
product and vice versa, packaging) to the finished
including quantity check/ product and vice versa,
mass balance. This shall including quantity check/
occur at a predetermined mass balance.
frequency, as a minimum
The traceability test shall
annually, and results shall
include a summary of the
be retained for inspection.
documents that should be
Full traceability should be
referenced during the test,
achievable within 4 hours.
and clearly show the links
between them. The test
shall occur at a
predetermined frequency,
at a minimum annually, and
results shall be retained for
inspection. Traceability
should be achievable
within 4 hours.
50 WWW.BRCGLOBALSTANDARDS.COM
3.10 COMPLAINT-HANDLING
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
Customer complaints shall be handled effectively Customer complaints shall be handled effectively
and information used to reduce recurring and information used to reduce recurring
complaint levels. complaint levels.
WWW.BRCGLOBALSTANDARDS.COM 51
3.11 MANAGEMENT OF INCIDENTS, PRODUCT WITHDRAWAL AND PRODUCT
RECALL
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
The company shall have a plan and system in The company shall have a plan and system in
place to manage incidents effectively and enable place to manage incidents effectively and enable
the withdrawal and recall of products should this the withdrawal and recall of products should this
be required. be required.
3.11.1 The company shall have 3.11.1 The company shall have New bullet point
documented procedures procedures designed to added to reflect
designed to report and report and effectively the increasing
effectively manage manage incidents and prevalence of
incidents and potential potential emergency cyber-crimes.
emergency situations that situations that impact food
impact food safety, legality safety, legality or quality.
or quality. This shall include This shall include
consideration of consideration of
contingency plans to contingency plans to
maintain product safety, maintain product safety,
quality and legality. quality and legality.
Incidents may include: Incidents may include:
52 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
3.11.2 The company shall have a 3.11.2 The company shall have a Timings of
documented product documented product decisions and
withdrawal and recall withdrawal and recall actions can
procedure. This shall procedure. This shall provide due
include as a minimum: include, at a minimum: diligence
WWW.BRCGLOBALSTANDARDS.COM 53
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
3.11.3 The product recall and 3.11.3 The product recall and
withdrawal procedures shall withdrawal procedures shall
be tested, at least annually, be tested, at least annually,
in a way that ensures their in a way that ensures their
effective operation. Results effective operation. Results
of the test shall be retained of the test shall be retained
and shall include timings of and shall include timings of
key activities. The results of key activities. The results of
the test and of any actual the test and of any actual
recall shall be used to review recall shall be used to review
the procedure and the procedure and
implement improvements implement improvements
as necessary. as necessary.
3.11.4 In the event of a product 3.11.4 In the event of a significant Clause amended
recall, the certification body food safety incident, to make it clear
issuing the current including a product recall that the
certificate for the site or regulatory food safety certification body
against this Standard shall non-conformity (e.g. a should be
be informed within 3 regulatory enforcement contacted in the
working days of the notice), the certification event of a
decision to issue a recall. body issuing the current significant food
certificate for the site safety incident,
against this Standard shall not just a recall.
be informed within 3
working days.
54 WWW.BRCGLOBALSTANDARDS.COM
3.12 REMOVED
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
The company shall ensure that any customer- This section has
specific policies or requirements are understood, been removed as
implemented and clearly communicated to it is particularly
relevant staff and, where appropriate, suppliers of difficult to audit
raw materials, packaging and services. (relies on auditors
knowing all the
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS
customers and their
3.12.1 Where a company is specific policies).
requested to follow specific
BRC Global
customer requirements,
Standards will
codes of practice, methods
continue to develop
of working etc., these shall
methods to assist
be made known to relevant
specifiers in
staff within the site and
addressing
implemented.
concerns that relate
3.12.2 Effective processes shall to the auditing of
be in place for individual codes of
communicating customer- practice.
specific requirements to
the suppliers of raw
materials and services as
applicable.
WWW.BRCGLOBALSTANDARDS.COM 55
4 SITE STANDARDS
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
The production site shall be of suitable size, The production site shall be of suitable size,
location and construction, and be maintained to location and construction, and be maintained to
reduce the risk of contamination and facilitate the reduce the risk of contamination and facilitate the
production of safe and legal finished products. production of safe and legal finished products.
4.1.2 The external areas shall be 4.1.2 The external areas shall be
maintained in good order. maintained in good order.
Where buildings are Where grassed or planted
surrounded by grassed or areas are located near
planted areas, they shall be buildings, they shall be
regularly tended and well regularly tended and well
maintained. External traffic maintained. External traffic
routes under site control routes under site control
shall be suitably surfaced shall be suitably surfaced
and maintained in good and maintained in good
repair to avoid repair to mitigate the risk of
contamination of the contamination of the
product. product.
4.1.3 The building fabric shall be 4.1.3 The building fabric shall be
maintained to minimise maintained to minimise
potential for product potential for product
contamination (e.g. contamination (e.g.
elimination of bird roosting elimination of bird-roosting
sites, sealing gaps around sites, sealing gaps around
pipes to prevent pest entry, pipes to prevent pest entry,
ingress of water and other ingress of water and other
contaminants). contaminants).
56 WWW.BRCGLOBALSTANDARDS.COM
4.2 SECURITY (NOW SITE SECURITY AND FOOD DEFENCE)
WWW.BRCGLOBALSTANDARDS.COM 57
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.2.2 Measures shall be in place 4.2.2 Where raw materials or New clause 4.2.2 for
to ensure only authorised products are identified as Issue 8. Part of
personnel have access to being at particular risk, the Issue 7 clause 4.2.2
production and storage threat assessment plan has been moved to
areas, and access to the shall include controls to Issue 8 clause 4.2.3.
site by employees, mitigate these risks. Where
contractors and visitors prevention is not sufficient
shall be controlled. A visitor or possible, systems shall
reporting system shall be in be in place to identify any
place. Staff shall be trained tampering.
in site security procedures
These controls shall be
and encouraged to report
monitored, the results
unidentified or unknown
documented, and the
visitors.
controls reviewed at least
annually.
4.2.3 External storage tanks, 4.2.3 Areas where a significant The information in
silos and any intake pipes risk is identified shall be Issue 7 clause 4.2.3
with an external opening defined, monitored and has been
shall be locked. controlled. These shall transferred to the
include external storage interpretation
and intake points for guideline for Issue 8.
products and raw materials This is because the
(including packaging). new clause 4.2.3 in
Issue 8 has a wider
Policies and systems shall
remit. The original
be in place to ensure that
clause in Issue 7 is
only authorised personnel
an example of the
have access to production
action that might be
and storage areas, and that
taken to address a
access to the site by
risk within the new
employees, contractors
clause.
and visitors is controlled.
A visitor recording system
shall be in place.
Staff shall be trained in site
security procedures and
food defence.
58 WWW.BRCGLOBALSTANDARDS.COM
4.3 LAYOUT, PRODUCT FLOW AND SEGREGATION
WWW.BRCGLOBALSTANDARDS.COM 59
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.3.2 The site map(s) shall 4.3.1 There shall be a map of the
define: site. At a minimum, this
map shall define:
• access points for
personnel • access points for
• access points for raw personnel
materials (including • access points for raw
packaging) materials (including
• routes of movement for packaging), semi-
personnel finished products and
• routes of movement for open products
raw materials • routes of movement for
• routes for the removal of personnel
waste • routes of movement for
• routes for the movement raw materials (including
of rework packaging)
• location of any staff • routes for the removal of
facilities including waste
changing rooms, toilets, • routes for the movement
canteens and smoking of rework
areas • location of any staff
• production process facilities, including
flow. changing rooms, toilets,
canteens and smoking
areas
• production process
flows.
60 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
WWW.BRCGLOBALSTANDARDS.COM 61
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
62 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
The fabrication of the site, buildings and facilities The fabrication of the site, buildings and facilities
shall be suitable for the intended purpose. shall be suitable for the intended purpose.
4.4.1 Walls shall be finished and 4.4.1 Walls shall be finished and
maintained to prevent the maintained to prevent the
accumulation of dirt, accumulation of dirt,
minimise condensation minimise condensation
and mould growth, and and mould growth, and
facilitate cleaning. facilitate cleaning.
WWW.BRCGLOBALSTANDARDS.COM 63
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
64 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.4.9 Doors shall be maintained 4.4.8 Doors (both internal and Clarification added
in good condition: external) shall be to ensure that all
maintained in good doors are correctly
• External doors and dock condition. At a minimum: managed.
levellers shall be close
fitting or adequately • external doors and dock
proofed. levellers shall be close
• External doors to open fitting or adequately
product areas shall not proofed
be opened during • external doors to open
production periods product areas shall not
except in emergencies. be opened during
production periods
Where external doors to
except in emergencies
enclosed product areas are
opened, suitable • where external doors to
enclosed product areas
precautions shall be taken
are opened, suitable
to prevent pest ingress.
precautions shall be
taken to prevent pest
ingress.
WWW.BRCGLOBALSTANDARDS.COM 65
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
66 WWW.BRCGLOBALSTANDARDS.COM
4.5 UTILITIES – WATER, ICE, AIR AND OTHER GASES
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
Utilities used within the production and storage Utilities used within the production and storage
areas shall be monitored to effectively control the areas shall be monitored to effectively control the
risk of product contamination. risk of product contamination.
4.5.1 All water used as a raw 4.5.1 All water (including ice and All water, whether in
material in the manufacture steam) used as a raw liquid form, ice or
of processed food, the material in the manufacture steam, requires the
preparation of product, of processed food, the control when used
hand-washing or for preparation of product, as a raw material or
equipment or plant hand-washing or for comes into direct
cleaning shall be supplied equipment or plant contact with
in sufficient quantity, be cleaning shall be supplied product.
potable at point of use or in sufficient quantity, be
pose no risk of potable at point of use or
contamination according pose no risk of
to applicable legislation. contamination according
The microbiological and to applicable legislation.
chemical quality of water The microbiological and
shall be analysed at least chemical quality of water
annually. The sampling shall be analysed at least
points, scope of the test annually. The sampling
and frequency of analysis points, scope of the test
shall be based on risk, and frequency of analysis
taking into account the shall be based on risk,
source of the water, on-site taking into account the
storage and distribution source of the water, on-site
facilities, previous sample storage and distribution
history and usage. facilities, previous sample
history and usage.
WWW.BRCGLOBALSTANDARDS.COM 67
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.5.4 Air, other gases and steam 4.5.3 Air and other gases used Steam removed
used directly in contact as an ingredient or that are from this clause as
with, or as an ingredient in, in direct contact with this is fully covered
products shall be products shall be by Issue 8,
monitored to ensure this monitored to ensure this clause 4.5.1.
does not represent a does not represent a Additional wording
contamination risk. contamination risk. provided for clarity.
Compressed air used Compressed air that is in
directly in contact with the direct contact with the
product shall be filtered. product shall be filtered at
point of use.
4.6 EQUIPMENT
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
All food-processing equipment shall be suitable All food-processing equipment shall be suitable
for the intended purpose and shall be used to for the intended purpose and shall be used to
minimise the risk of contamination of product. minimise the risk of contamination of product.
68 WWW.BRCGLOBALSTANDARDS.COM
4.7 MAINTENANCE
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
An effective maintenance programme shall be in An effective maintenance programme shall be in
operation for plant and equipment to prevent operation for plant and equipment to prevent
contamination and reduce the potential for contamination and reduce the potential for
breakdowns. breakdowns.
WWW.BRCGLOBALSTANDARDS.COM 69
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.7.4 The site shall ensure that 4.7.4 The site shall ensure that To avoid potential
the safety or legality of the safety or legality of contamination,
product is not jeopardised products is not jeopardised good practice is to
during maintenance and during maintenance and inspect equipment
subsequent cleaning subsequent cleaning prior to its
operations. Maintenance operations. Maintenance acceptance back
work shall be followed by a work shall be followed by a into production.
documented hygiene documented hygiene
clearance procedure, clearance procedure.
which records that product
Equipment and machinery
contamination hazards
shall be inspected by an
have been removed from
authorised member of staff
machinery and equipment.
to confirm the removal of
contamination hazards,
before being accepted
back into operation.
4.7.6 Materials used for 4.7.5 Materials and parts used Clause rephrased to
equipment and plant for equipment and plant add clarity to the
maintenance and that pose maintenance shall be of an expectations.
a risk by direct or indirect appropriate grade or
contact with raw materials, quality.
intermediate and finished
Those materials (such as
products, such as
lubricating oil) that pose a
lubricating oil, shall be food
risk by direct or indirect
grade and of a known
contact with raw materials
allergen status.
(including primary
packaging), intermediate
products and finished
products shall be food
grade and of a known
allergen status.
70 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
Staff facilities shall be sufficient to accommodate Staff facilities shall be sufficient to accommodate
the required number of personnel, and shall be the required number of personnel, and shall be
designed and operated to minimise the risk of designed and operated to minimise the risk of
product contamination. The facilities shall be product contamination. The facilities shall be
maintained in good and clean condition. maintained in good and clean condition.
WWW.BRCGLOBALSTANDARDS.COM 71
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.8.3 Outdoor clothing and other 4.8.3 Outdoor clothing and other
personal items shall be personal items shall be
stored separately from stored separately from
production clothing within production clothing within
the changing facilities. the changing facilities.
Facilities shall be available Facilities shall be available
to separate clean and dirty to separate clean and dirty
production clothing. production clothing.
72 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
WWW.BRCGLOBALSTANDARDS.COM 73
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
74 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
WWW.BRCGLOBALSTANDARDS.COM 75
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.8.9 All food brought into 4.8.7 All food brought into
manufacturing premises by manufacturing premises by
staff shall be appropriately staff shall be appropriately
stored in a clean and stored in a clean and
hygienic state. No food hygienic state. No food
shall be taken into storage, shall be taken into storage,
processing or production processing or production
areas. Where eating of food areas. Where eating of food
is allowed outside during is allowed outside during
breaks, this shall be in breaks, this shall be in
suitable designated areas suitable designated areas
with appropriate control of with appropriate control of
waste. waste.
76 WWW.BRCGLOBALSTANDARDS.COM
4.9 CHEMICAL AND PHYSICAL PRODUCT CONTAMINATION CONTROL: RAW
MATERIAL HANDLING, PREPARATION, PROCESSING, PACKING AND STORAGE
AREAS
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
Appropriate facilities and procedures shall be in Appropriate facilities and procedures shall be in
place to control the risk of chemical or physical place to control the risk of chemical or physical
contamination of product. contamination of product.
WWW.BRCGLOBALSTANDARDS.COM 77
4.9.2 METAL CONTROL
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
78 WWW.BRCGLOBALSTANDARDS.COM
4.9.3 GLASS, BRITTLE PLASTIC, CERAMICS AND SIMILAR MATERIALS
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
WWW.BRCGLOBALSTANDARDS.COM 79
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
80 WWW.BRCGLOBALSTANDARDS.COM
4.9.4 PRODUCTS PACKED INTO GLASS OR OTHER BRITTLE CONTAINERS
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
WWW.BRCGLOBALSTANDARDS.COM 81
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.9.5 WOOD
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.9.5.1 Wood should not be used 4.9.5.1 Wood should not be used
in open product areas in open product areas
except where this is a except where this is a
process requirement process requirement (e.g.
(e.g. maturation of maturation of products in
products in wood). Where wood). Where the use of
the use of wood cannot be wood cannot be avoided,
avoided, the condition of the condition of wood shall
wood shall be continually be continually monitored to
monitored to ensure it is in ensure it is in good
good condition and free condition and free from
from damage or splinters damage or splinters which
which could contaminate could contaminate
products. products.
82 WWW.BRCGLOBALSTANDARDS.COM
4.9.6 OTHER PHYSICAL CONTAMINANTS
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
WWW.BRCGLOBALSTANDARDS.COM 83
4.10 FOREIGN-BODY DETECTION AND REMOVAL EQUIPMENT
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
The risk of product contamination shall be The risk of product contamination shall be
reduced or eliminated by the effective use of reduced or eliminated by the effective use of
equipment to remove or detect foreign bodies. equipment to remove or detect foreign bodies.
• filters • filters
• sieves • sieves
• metal detection • metal detection
• magnets • magnets
• optical sorting • optical sorting
equipment equipment
• X-ray detection • X-ray detection
equipment equipment
• other physical • other physical
separation equipment separation equipment
(e.g. gravity separation, (e.g. gravity separation,
fluid bed technology). fluid bed technology).
4.10.1.2 The type, location and 4.10.1.2 The type, location and
sensitivity of the detection sensitivity of the detection
and/or removal method and/or removal method
shall be specified as part of shall be specified as part of
the site’s documented the site’s documented
system. Industry best system. Industry best
practice shall be applied practice shall be applied
with regard to the nature of with regard to the nature of
the ingredient, material, the ingredient, material,
product and/or the packed product and/or the packed
product. The location of product. The location of
the equipment or any other the equipment or any other
factors influencing the factors influencing the
sensitivity of the equipment sensitivity of the equipment
shall be validated and shall be validated and
justified. justified.
84 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.10.1.3 The site shall ensure that 4.10.1.3 The site shall ensure that Additional text
the frequency of the testing the frequency of the testing relocated from Issue
of the foreign-body of the foreign-body 7, clause 4.10.3.5 to
detection and/or removal detection and/or removal emphasise that
equipment is defined and equipment is defined and corrective actions
takes into consideration: takes into consideration: are required
whenever there is a
• specific customer • specific customer failure of the
requirements requirements
foreign-body
• the site’s ability to • the site’s ability to detector/removal
identify, hold and identify, hold and
equipment (it was
prevent the release of prevent the release of
previously located in
any affected materials, any affected materials,
the section dealing
should the equipment should the equipment
only with metal
fail. fail.
detectors).
The site shall establish and
implement corrective
action and reporting
procedures in the event of
a failure of the foreign-body
detector and/or removal
equipment. Action shall
include a combination of
isolation, quarantining and
re-inspection of all
products produced since
the last successful test or
inspection.
WWW.BRCGLOBALSTANDARDS.COM 85
4.10.2 FILTERS AND SIEVES
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.10.2.1 Filters and sieves used for 4.10.2.1 Filters and sieves used for Final sentence
foreign-body control shall foreign-body control shall removed as it
be of a specified mesh size be of a specified mesh size overlaps with clause
or gauge and designed to or gauge and designed to 4.10.1.4, which
provide the maximum provide the maximum applies to all foreign
practical protection for the practical protection for the bodies.
product. Material retained product.
or removed by the system
shall be examined and
recorded to identify
contamination risks.
4.10.2.2 Filters and sieves shall be 4.10.2.2 Filters and sieves shall be
regularly inspected or regularly inspected or
tested for damage on a tested for damage at a
documented frequency documented frequency
based on risk. Records based on risk. Records
shall be maintained of the shall be maintained of the
checks. Where defective checks. Where defective
filters or sieves are filters or sieves are
identified this shall be identified this shall be
recorded and the potential recorded and the potential
for contamination of for contamination of
products investigated and products investigated and
appropriate action taken. appropriate action taken.
86 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.10.3.2 The metal detector or X-ray 4.10.3.2 The metal detector or X-ray
equipment shall equipment shall
incorporate one of the incorporate one of the
following: following:
4.10.3.3 The site shall establish and 4.10.3.3 The site shall establish and As per previous
implement documented implement procedures for comments – the
procedures for the the operation and testing of glossary in the
operation and testing of the the metal detection or X-ray Standard confirms
metal detection or X-ray equipment. This shall that all procedures
equipment. This shall include, at a minimum: must be
include as a minimum: documented;
• responsibilities for the therefore it is not
• responsibilities for the testing of equipment
necessary to state
testing of equipment • the operating ‘documented’ in
• the operating effectiveness and
every clause, as the
effectiveness and sensitivity of the
glossary has already
sensitivity of the equipment and any
confirmed this as a
equipment and any variation to this for
requirement.
variation to this for particular products
particular products • the methods and
• the methods and frequency of checking
frequency of checking the detector
the detector • recording of the results
• recording of the results of checks.
of checks.
WWW.BRCGLOBALSTANDARDS.COM 87
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.10.3.4 Metal detector checking 4.10.3.4 Metal detector testing Slight rewording to
procedures shall be based procedures shall, at a clarify expectations.
on good practice and shall minimum, include:
as a minimum include the
following: • use of test pieces
incorporating a sphere
• Use of test pieces of metal of a known
incorporating a sphere diameter selected on
of metal of a known the basis of risk. The test
diameter selected on pieces shall be marked
the basis of risk. The test with the size and type of
pieces shall be marked test material contained
with the size and type of • tests carried out using
test material contained. separate test pieces
• Tests carried out using containing ferrous
separate test pieces metal, stainless steel
containing ferrous and typically non-
metal, stainless steel ferrous metal, unless the
and typically non- product is within a foil
ferrous metal, unless the container where a
product is within a foil ferrous-only test may be
container where ferrous applicable
only may be applicable. • a test to prove that both
• A test that both the the detection and
detection and rejection rejection mechanisms
mechanisms are are working effectively
working effectively under normal working
under normal working conditions
conditions. • tests of the metal
• Checks that test the detector by passing
memory/reset function successive test packs
of the metal detector by through the unit at
passing successive test typical line operating
packs through the unit speed
at typical line operating • checks of failsafe
speed. systems fitted to the
• Checks of failsafe detection and rejection
systems fitted to the systems.
detection and rejection
In addition, where metal
systems.
detectors are incorporated
In addition, where metal on conveyors, the test
detectors are incorporated piece shall be passed as
on conveyors, the test close as possible to the
piece shall be passed as centre of the metal detector
close as possible to the aperture. Wherever
centre of the metal detector possible, the test piece
aperture and wherever shall be inserted within a
possible be carried out by clearly identified sample
inserting the test piece pack of the food being
within a clearly identified produced at the time of the
sample pack of the food test.
being produced at the time
of the test.
88 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.10.3.4 cont. Where in-line metal 4.10.3.4 cont. Where in-line metal
detectors are used the test detectors are used, the test
piece shall be placed in the piece shall be placed in the
product flow wherever this product flow wherever this
is possible and the correct is possible and the correct
timing of the rejection timing of the rejection
system to remove identified system to remove identified
contamination shall be contamination shall be
validated. validated. Testing of in-line
metal detectors shall be
completed during both line
start-up and at the end of
the production period.
4.10.4 MAGNETS
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.10.4.1 The type, location and 4.10.4.1 The type, location and
strength of magnets shall strength of magnets shall
be fully documented. be fully documented.
Documented procedures Procedures shall be in
shall be in place for the place for the inspection,
inspection, cleaning, cleaning, strength testing
strength testing and and integrity checks.
integrity checks. Records Records of all checks shall
of all checks shall be be maintained.
maintained.
WWW.BRCGLOBALSTANDARDS.COM 89
4.10.5 OPTICAL SORTING EQUIPMENT
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.10.5.1 Each unit shall be checked 4.10.5.1 Each unit shall be checked
in accordance with the in accordance with the
manufacturer’s instructions manufacturer’s instructions
or recommendations. or recommendations.
Checks shall be Checks shall be
documented. documented.
4.10.6 CONTAINER CLEANLINESS – GLASS JARS, CANS AND OTHER RIGID CONTAINERS
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
90 WWW.BRCGLOBALSTANDARDS.COM
4.11 HOUSEKEEPING AND HYGIENE
WWW.BRCGLOBALSTANDARDS.COM 91
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.11.3 As a minimum for food 4.11.3 Limits of acceptable and To assist sites with
contact surfaces, unacceptable cleaning the application of
processing equipment and performance shall be controls for
for environmental cleaning defined for food contact products requiring
in high-care/high-risk surfaces and processing high-risk, high-care
areas, limits of acceptable equipment. These limits and ambient
and unacceptable cleaning shall be based on the high-care
performance shall be potential hazards relevant processing
defined. This shall be to the product or environments,
based on the potential processing area Issue 8 contains a
hazards (e.g. (e.g. microbiological, new section
microbiological, allergen, allergen, foreign-body (section 8) which
foreign-body contamination or product- collates all of these
contamination or product- to-product contamination). requirements.
to-product contamination). Therefore, acceptable
See Issue 8,
Acceptable levels of levels of cleaning may be
clause 8.5.2.
cleaning may be defined by defined by visual
visual appearance, ATP appearance, ATP
bioluminescence bioluminescence
techniques (see glossary), techniques (see glossary),
microbiological testing or microbiological testing,
chemical testing as allergen testing or chemical
appropriate. Where testing as appropriate.
cleaning procedures are
The site shall define the
part of a defined
corrective action to be
prerequisite plan to control
taken when monitored
the risk of a specific hazard
results are outside of the
the cleaning and
acceptable limits.
disinfection procedures
and frequency shall be Where cleaning
validated and records procedures are part of a
maintained. This shall defined prerequisite plan to
include the risk from control the risk of a specific
cleaning chemical residues hazard, the cleaning and
on food contact surfaces. disinfection procedures
and their frequency shall be
validated and records
maintained. This shall
include the risk from
cleaning chemical residues
on food contact surfaces.
92 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.11.6 Cleaning equipment shall 4.11.6 Cleaning equipment To assist sites with
be: shall be: the application of
controls for
• hygienically designed • hygienically designed products requiring
and fit for purpose and fit for purpose
high-risk, high-care
• suitably identified for • suitably identified for and ambient
intended use (e.g. intended use
high-care
colour coded or (e.g. colour-coded or
processing
labelled) labelled)
environments,
• cleaned and stored in a • cleaned and stored in a
Issue 8 contains a
hygienic manner to hygienic manner to
new section
prevent contamination. prevent contamination.
(section 8) which
Equipment used for collates all of these
cleaning in high-care and requirements.
high-risk areas shall be
See Issue 8,
visually distinctive and
clause 8.5.3.
dedicated for use in that
area.
WWW.BRCGLOBALSTANDARDS.COM 93
4.11.7 CLEANING IN PLACE (CIP)
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.11.7.1 Cleaning-in-place (CIP) 4.11.7.1 All CIP equipment shall be Section 4.11.7 has
facilities, where used, shall designed and constructed been substantively
be monitored and to ensure effective rewritten to add
maintained to ensure their operation. This shall clarity to the
effective operation. include: requirements.
94 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
WWW.BRCGLOBALSTANDARDS.COM 95
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.11.7.3 The CIP equipment shall be 4.11.7.3 The CIP equipment shall be
operated to ensure maintained by suitably
effective cleaning is carried trained staff to ensure
out: effective cleaning is carried
out. This shall include:
• The process
parameters, time, • detergent
detergent concentrations shall be
concentrations, flow checked routinely
rate and temperatures • recovered post-rinse
shall be defined to solutions shall be
ensure removal of the monitored for build-up
appropriate target of carry-over from the
hazard (e.g. soil, detergent tanks
allergens, vegetative • filters, where fitted, shall
micro-organisms, be cleaned and
spores). This shall be inspected at a defined
validated and records of frequency
the validation • where used, flexible
maintained. hoses shall be stored
• Detergent hygienically when not in
concentrations shall be use, and inspected at a
checked routinely. defined frequency to
• CIP process verification ensure that they are in
shall be undertaken by good condition.
analysis of rinse waters
and/or first product
through the line for the
presence of cleaning
fluids or by tests of ATP
(bioluminescence
techniques), allergens
or micro-organisms as
appropriate.
• Detergent tanks shall be
kept stocked up and a
log maintained of when
these are drained,
cleaned, filled and
emptied. Recovered
post-rinse solutions
shall be monitored for a
build-up of carry-over
from the detergent
tanks.
• Filters, where fitted, shall
be cleaned and
inspected at a defined
frequency.
96 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
• monitoring of process
parameters defined in
clause 4.11.7.2
• ensuring correct
connections, piping and
settings are in place
• confirming the process
is operating correctly
(e.g. valves opening/
closing sequentially)
• ensuring effective
completion of the
cleaning cycle
• monitoring for effective
results, including
draining where required.
Procedures shall define the
action to be taken if
monitoring indicates that
processing is outside the
defined limits.
WWW.BRCGLOBALSTANDARDS.COM 97
4.11.8 ENVIRONMENTAL MONITORING
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
Risk-based environmental monitoring Issue 8 of the
programmes shall be in place for pathogens or Standard contains
spoilage organisms. At a minimum, these shall an entirely new
include all production areas with open and section (4.11.8) on
ready-to-eat products. the requirements for
environmental
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS
monitoring.
4.11.8.1 The design of the
These have been
environmental monitoring
added to ensure
programme shall be based
that where sites
on risk, and at a minimum
have production
include:
areas containing
• sampling protocol open products,
• identification of sample there is suitable
locations monitoring (and
• frequency of tests where needed,
• target organism(s) (e.g. control) of
pathogens, spoilage micro‑organisms
organisms and/or (pathogen and/or
indicator organisms) spoilage) that may
• test methods (e.g. settle be present in the
plates, rapid testing and factory and could
swabs) therefore represent
• recording and a risk to product.
evaluation of results.
The programme and its
associated procedures
shall be documented.
98 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
• changes in processing
conditions, process flow
or equipment
• new developments in
scientific information
• failures of the
programme to identify a
significant issue (e.g.
regulatory authority
tests identifying positive
results which the site
programme did not)
• product failures
(products with positive
tests)
• consistently negative
results (e.g. a site with a
long history of negative
results should review its
programme to consider
whether the correct
parts of the factory are
being tested, whether
the testing is being
conducted correctly,
whether the tests are for
the appropriate
organisms, etc.).
WWW.BRCGLOBALSTANDARDS.COM 99
4.12 WASTE/WASTE DISPOSAL
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
Waste disposal shall be managed in accordance Waste disposal shall be managed in accordance
with legal requirements and to prevent with legal requirements and to prevent
accumulation, risk of contamination and the accumulation, risk of contamination and the
attraction of pests. attraction of pests.
4.12.2 External waste collection 4.12.2 Internal and external waste Minor amendment
containers and rooms collection containers and to highlight that all
housing waste facilities rooms housing waste waste containers
shall be managed to facilities shall be managed need to be
minimise risk. These to minimise risk. These managed to ensure
shall be: shall be: that they cannot be
a source of product
• clearly identified • clearly identified contamination.
• designed for ease of use • designed for ease of use
and effective cleaning and effective cleaning
• well maintained to allow • well maintained to allow
cleaning and, where cleaning and, where
required, disinfection required, disinfection
• emptied at appropriate • emptied at appropriate
frequencies frequencies.
• covered or doors kept
External waste containers
closed as appropriate.
shall be covered or doors
kept closed as appropriate.
100 WWW.BRCGLOBALSTANDARDS.COM
4.13 MANAGEMENT OF SURPLUS FOOD AND PRODUCTS FOR ANIMAL FEED
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
Effective processes shall be in place to ensure the Effective processes shall be in place to ensure the
safety and legality of by-products of the primary safety and legality of by-products of the primary
processing activity of the site. processing activity of the site.
WWW.BRCGLOBALSTANDARDS.COM 101
4.14 PEST CONTROL (NOW PEST MANAGEMENT)
102 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.14.2 The site shall either 4.14.2 The site shall either
contract the services of a contract the services of a
competent pest control competent pest
organisation, or shall have management organisation
appropriately trained staff, or have appropriately
for the regular inspection trained staff for the regular
and treatment of the site to inspection and treatment of
deter and eradicate the site to deter and
infestation. The frequency eradicate infestation.
of inspections shall be
The frequency of
determined by risk
inspections shall be
assessment and shall be
determined by risk
documented. Where the
assessment and shall be
services of a pest control
documented. The risk
contractor are employed,
assessment shall be
the service scope shall be
reviewed whenever:
clearly defined and reflect
the activities of the site. • there are changes to the
building or production
processes which could
have an impact on the
pest management
programme
• there has been a
significant pest issue.
Where the services of a
pest management
contractor are employed,
the service scope shall be
clearly defined and reflect
the activities of the site.
Service provision
regardless of the source
shall meet with all
applicable regulatory
requirements.
WWW.BRCGLOBALSTANDARDS.COM 103
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.14.3 Where a site undertakes its 4.14.3 Where a site undertakes its
own pest control, it shall be own pest management, it
able to effectively shall be able to effectively
demonstrate that: demonstrate that:
104 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
WWW.BRCGLOBALSTANDARDS.COM 105
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
106 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
WWW.BRCGLOBALSTANDARDS.COM 107
4.15 STORAGE FACILITIES
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
All facilities used for the storage of raw materials, All facilities used for the storage of raw materials,
packaging, in-process products and finished packaging, in-process products and finished
products shall be suitable for its purpose. products shall be suitable for purpose.
108 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.15.6 The site shall facilitate 4.15.6 The site shall facilitate
correct stock rotation of raw correct stock rotation of raw
materials, intermediate materials, intermediate
products and finished products and finished
products in storage and products in storage and
ensure materials are used in ensure that materials are
the correct order in relation used in the correct order in
to their manufacturing date relation to their
and within the prescribed manufacturing date and
shelf life. within the prescribed
shelf life.
WWW.BRCGLOBALSTANDARDS.COM 109
4.16 DISPATCH AND TRANSPORT
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
Procedures shall be in place to ensure that the Procedures shall be in place to ensure that the
management of dispatch and of the vehicles and management of dispatch and of the vehicles and
containers used for transporting products from containers used for transporting products from
the site do not present a risk to the safety, security the site do not present a risk to the safety, security
or quality of the products. or quality of the products.
110 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.16.2 All vehicles or containers 4.16.2 All vehicles or containers Vehicles used for
used for the dispatch of used for the transport of the transport of raw
products shall be raw materials and the materials also form
inspected prior to loading dispatch of products shall an important aspect
to ensure that they are fit for be fit for purpose. This shall of transport control.
purpose. This shall ensure ensure that they are:
All sites need to
that they are:
• in a clean condition check raw-material
• in a clean condition • free from strong odours vehicles (usually as
• free from strong odours which may cause taint to part of the goods
which may cause taint to products receipt process) to
products • in a suitable condition to ensure that they are
• in a suitable condition to prevent damage to suitable and that
prevent damage to products during transit there is no obvious
products during transit • equipped to ensure any source of
• equipped to ensure any temperature contamination (such
temperature requirements can be as spillages, pest
requirements can be maintained throughout activity or taints).
maintained. transportation. However, this
inspection will have
Records of inspections Records of inspections
an even greater
shall be maintained. shall be maintained.
relevance where the
site is also
responsible for the
raw-material
vehicles (e.g.
fresh-produce pack
houses that arrange
transport from farm
to pack house).
WWW.BRCGLOBALSTANDARDS.COM 111
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.16.5 The company shall have 4.16.5 The company shall have
documented procedures procedures for the
for the transport of transport of products,
products, which shall which shall include:
include:
• any restrictions on the
• any restrictions on the use of mixed loads
use of mixed loads • requirements for the
• requirements for the security of products
security of products during transit,
during transit, particularly when
particularly when vehicles are parked and
vehicles are parked and unattended
unattended • clear instructions in the
• clear instructions in the case of vehicle
case of vehicle breakdown, accident or
breakdown, accident or failure of refrigeration
failure of refrigeration systems, which ensure
systems, which ensure that the safety of the
the safety of the products is assessed
products is assessed and records maintained.
and records maintained.
112 WWW.BRCGLOBALSTANDARDS.COM
5 PRODUCT CONTROL
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
Product design and development procedures Product design and development procedures
shall be in place for new products or processes shall be in place for new products or processes
and any changes to product, packaging or and any changes to product, packaging or
manufacturing processes to ensure that safe and manufacturing processes to ensure that safe and
legal products are produced. legal products are produced.
5.1.1 The company shall provide 5.1.1 The company shall provide
clear guidelines on any clear guidelines on any
restrictions to the scope restrictions to the scope
of new product of new product
developments to control developments to control
the introduction of hazards the introduction of hazards
which would be which would be
unacceptable to the site or unacceptable to the site or
customers (e.g. the customers (e.g. the
introduction of allergens, introduction of allergens,
glass packaging or glass packaging or
microbiological risks). microbiological risks).
5.1.2 All new products and 5.1.2 All new products and
changes to product changes to product
formulation, packaging or formulation, packaging or
methods of processing methods of processing
shall be formally approved shall be formally approved
by the HACCP team leader by the HACCP team leader
or authorised HACCP or authorised HACCP
committee member. This committee member. This
shall ensure that hazards shall ensure that hazards
have been assessed and have been assessed and
suitable controls, identified suitable controls, identified
through the HACCP through the HACCP
system, are implemented. system, are implemented.
This approval shall be This approval shall be
granted before products granted before products
are introduced into the are introduced into the
factory environment. factory environment.
WWW.BRCGLOBALSTANDARDS.COM 113
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
114 WWW.BRCGLOBALSTANDARDS.COM
5.2 PRODUCT LABELLING
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
Product labelling shall comply with the Product labelling shall comply with the
appropriate legal requirements and contain appropriate legal requirements and contain
information to enable the safe handling, display, information to enable the safe handling, display,
storage and preparation of the product within the storage and preparation of the product within the
food supply chain or by the customer. food supply chain or by the customer.
WWW.BRCGLOBALSTANDARDS.COM 115
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
5.2.4 Where the label information 5.2.4 Where the label information
is the responsibility of a is the responsibility of a
customer or a nominated customer or a nominated
third party the company third party, the company
shall provide: shall provide information:
116 WWW.BRCGLOBALSTANDARDS.COM
5.3 MANAGEMENT OF ALLERGENS
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
The site shall have a system for the management The site shall have a system for the management
of allergenic materials which minimises the risk of of allergenic materials which minimises the risk of
allergen contamination of products and meets allergen contamination of products and meets
legal requirements for labelling in the country legal requirements for labelling in the country
of sale. of sale.
5.3.1 The site shall carry out an 5.3.1 The site shall carry out an
assessment of raw assessment of raw
materials to establish the materials to establish the
presence and likelihood of presence and likelihood of
contamination by allergens. contamination by allergens
This shall include review of (see glossary). This shall
raw material specifications include a review of the raw
and, where required, obtain material specifications and,
additional information from where required, the
suppliers, for example acquisition of additional
through questionnaires to information from suppliers
understand the allergen (e.g. through
status of the raw material, questionnaires to
its ingredients and the understand the allergen
factory in which it is status of the raw material,
produced. its ingredients and the
factory in which it is
produced).
5.3.2 The company shall identify 5.3.2 The company shall identify
and list allergen-containing and list allergen-containing
materials handled on site. materials handled on site.
This shall include raw This shall include raw
materials, processing aids, materials, processing aids,
intermediate and finished intermediate and finished
products, and any new products, and any new
product development product development
ingredients or products. ingredients or products.
WWW.BRCGLOBALSTANDARDS.COM 117
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
118 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
WWW.BRCGLOBALSTANDARDS.COM 119
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
5.3.6 Where the nature of the 5.3.6 Where a justified, risk- Allergen warnings
production process is such based assessment should be used only
that cross-contamination demonstrates that the when there is a
from an allergen cannot be nature of the production justified reason.
prevented, a warning process is such that Allergen cross-
should be included on the cross-contamination contamination
label. National guidelines (cross-contact) from an (cross-contact)
or codes of practice shall allergen cannot be warning labels
be used when making such prevented, a warning (e.g. may contain
a warning statement. should be included on the allergen X) should
label. National guidelines not be used to avoid
or codes of practice shall good production
be used when making such processes that
a warning statement. minimise the risk
of cross-
contamination
(cross-contact).
120 WWW.BRCGLOBALSTANDARDS.COM
5.4 PRODUCT AUTHENTICITY, CLAIMS AND CHAIN OF CUSTODY
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
Systems shall be in place to minimise the risk of Systems shall be in place to minimise the risk of
purchasing fraudulent or adulterated food raw purchasing fraudulent or adulterated food raw
materials and to ensure that all product materials and to ensure that all product
descriptions and claims are legal, accurate and descriptions and claims are legal, accurate and
verified. verified.
5.4.1 The company shall have 5.4.1 The company shall have
processes in place to processes in place to
access information on access information on
historical and developing historical and developing
threats to the supply chain threats to the supply chain
which may present a risk of which may present a risk of
adulteration or substitution adulteration or substitution
of raw materials. Such of raw materials (i.e.
information may come fraudulent raw materials).
from: Such information may
come from, for example:
• trade associations
• government sources • trade associations
• private resource • government sources
centres. • private resource
centres.
WWW.BRCGLOBALSTANDARDS.COM 121
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
5.4.2 A documented vulnerability 5.4.2 A documented vulnerability The key output from
assessment shall be assessment shall be the vulnerability risk
carried out on all food raw carried out on all food raw assessment is a
materials or groups of raw materials or groups of raw documented
materials to assess the materials to assess the vulnerability
potential risk of adulteration potential risk of adulteration assessment plan,
or substitution. This shall or substitution. This shall which is kept up to
take into account: take into account: date to reflect any
changes in the risk
• historical evidence of • historical evidence of to raw materials.
substitution or substitution or
adulteration adulteration This plan will also
• economic factors which • economic factors which include details of
may make adulteration may make adulteration any controls or
or substitution more or substitution more actions taken,
attractive attractive where a raw material
• ease of access to raw • ease of access to raw is identified as being
materials through the materials through the at risk (see Issue 8,
supply chain supply chain clause 5.4.3).
• sophistication of routine • sophistication of routine
testing to identify testing to identify
adulterants adulterants
• nature of the raw • the nature of the raw
material. material.
The vulnerability The output from this
assessment shall be kept assessment shall be a
under review to reflect documented vulnerability
changing economic assessment plan. This plan
circumstances and market shall be kept under review
intelligence which may alter to reflect changing
the potential risk. It shall be economic circumstances
formally reviewed annually. and market intelligence
which may alter the
potential risks. It shall be
formally reviewed annually.
5.4.3 Where raw materials are 5.4.3 Where raw materials are
identified as being at identified as being at
particular risk of particular risk of
adulteration or substitution adulteration or substitution,
appropriate assurance the vulnerability
and/or testing processes assessment plan shall
shall be in place to reduce include appropriate
the risk. assurance and/or testing
processes to mitigate the
identified risks.
122 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
5.4.5 Where claims are made 5.4.5 Where claims are made
about the methods of about the methods of
production (e.g. organic, production (e.g. organic,
Halal, Kosher) the site shall halal, kosher) the site shall
maintain the necessary maintain the necessary
certification status in order certification status in order
to make such a claim. to make such a claim.
5.4.6 The process flow for the 5.4.6 The process flow for the
production of products production of products
where claims are made where claims are made
shall be documented and shall be documented and
potential areas for potential areas for
contamination or loss of contamination or loss of
identity identified. identity identified.
Appropriate controls shall Appropriate controls shall
be established to ensure be established to ensure
the integrity of the the integrity of the
product claims. product claims.
WWW.BRCGLOBALSTANDARDS.COM 123
5.5 PRODUCT PACKAGING
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
Product packaging shall be appropriate for the Product packaging shall be appropriate for the
intended use and shall be stored under intended use and shall be stored under
conditions to prevent contamination and conditions to prevent contamination and
minimise deterioration. minimise deterioration.
5.5.2 Product liners and bags 5.5.2 Product liners and bags
purchased by the company purchased by the company
for use in direct contact for use in direct contact
with ingredients, or work in with ingredients, or work in
process, shall be process, shall be
appropriately coloured and appropriately coloured
resistant to tearing to (e.g. contrasting colour to
prevent accidental the product) and resistant
contamination. to tearing to prevent
accidental contamination.
124 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
WWW.BRCGLOBALSTANDARDS.COM 125
5.6 PRODUCT INSPECTION AND LABORATORY TESTING
5.6.1.2 Test and inspection results 5.6.1.2 Test and inspection results
shall be recorded and shall be recorded and
reviewed regularly to reviewed regularly to
identify trends. The identify trends. The
significance of external significance of external
laboratory results shall be laboratory results shall be
understood and acted understood and acted
upon accordingly. upon accordingly.
Appropriate actions shall Appropriate actions shall
be implemented promptly be implemented promptly
to address any to address any
unsatisfactory results or unsatisfactory results or
trends. trends.
126 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
5.6.1.3 The site shall ensure that a 5.6.1.3 The site shall ensure that a Rephrased to
system of ongoing shelf-life system of validation and provide clarity and
assessment is in place. ongoing verification of the to distinguish this
This shall be based on risk shelf life is in place. This requirement from
and shall include sensory shall be based on risk and the shelf-life
analysis and, as applicable, shall include sensory assessments
microbiological testing and analysis and, as applicable, completed in
relevant chemical factors microbiological testing and Issue 8, clause 5.1.4.
such as pH and aw. relevant chemical factors
Records and results from such as pH and aw.
shelf-life tests shall verify Records and results from
the shelf-life period shelf-life tests shall verify
indicated on the product. the shelf-life period
indicated on the product.
WWW.BRCGLOBALSTANDARDS.COM 127
ISSUE 7 ISSUE 8 COMMENTS
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS
128 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8 COMMENTS
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS
WWW.BRCGLOBALSTANDARDS.COM 129
5.7 PRODUCT RELEASE
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
The site shall ensure that pet food products are New section for pet
safe and fit for intended use. food manufacturers
to ensure that Issue
8 aligns with good
practice and the
new GFSI
benchmark for pet
food.
130 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
• identification of
medication-containing
materials handled on
site. These can be raw
materials, processing
aids, intermediate and
finished products,
rework or any new
product or product
development
ingredients
• mechanisms to ensure
the correct
concentrations of
medicinal substances in
finished products
• procedures (e.g.
cleaning procedures) to
prevent contamination
of non-medicated pet
food with materials
containing medicinal
substances
• specific procedures to
ensure the correct
labelling of medicated
pet food.
WWW.BRCGLOBALSTANDARDS.COM 131
6 PROCESS CONTROL
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
The site shall operate to documented procedures The site shall operate to procedures and/or work
and/or work instructions that ensure the instructions that ensure the production of
production of consistently safe and legal product consistently safe and legal product with the
with the desired quality characteristics, in full desired quality characteristics, in full compliance
compliance with the HACCP food safety plan. with the HACCP food safety plan.
132 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
WWW.BRCGLOBALSTANDARDS.COM 133
6.2 LABELLING AND PACK CONTROL
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
The management controls of product labelling The management controls of product labelling
activities shall ensure that products will be activities shall ensure that products will be
correctly labelled and coded. correctly labelled and coded.
134 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
WWW.BRCGLOBALSTANDARDS.COM 135
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
136 WWW.BRCGLOBALSTANDARDS.COM
6.3 QUANTITY – WEIGHT, VOLUME AND NUMBER CONTROL
6.3.2 Where the quantity of the 6.3.2 Where the quantity of the
product is not governed by product is not governed by
legislative requirements legislative requirements
(e.g. bulk quantity), the (e.g. bulk quantity), the
product must conform to product must conform to
customer requirements customer requirements
and records shall be and records shall be
maintained. maintained.
• consideration of any
legal requirements
• responsibilities for
testing the equipment
• operating effectiveness
and any variations for
particular products
• methods and frequency
of testing the check
weighers
• records of the test
results.
WWW.BRCGLOBALSTANDARDS.COM 137
6.4 CALIBRATION AND CONTROL OF MEASURING AND MONITORING DEVICES
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
The site shall be able to demonstrate that The site shall be able to demonstrate that
measuring equipment is sufficiently accurate and measuring equipment is sufficiently accurate and
reliable to provide confidence in measurement reliable to provide confidence in measurement
results. results.
6.4.1 The site shall identify and 6.4.1 The site shall identify and
control measuring control measuring
equipment used to monitor equipment used to monitor
critical control points, critical control points and
product safety and legality. product safety, legality and
This shall include as a quality. This shall include, at
minimum: a minimum:
• at a predetermined • at a predetermined
frequency, based on risk frequency, based on risk
assessment assessment
• to a defined method • to a defined method
traceable to a traceable to a
recognised national or recognised national or
international standard international standard
where possible. where possible.
Results shall be Results shall be
documented. Equipment documented. Equipment
shall be readable and be of shall be readable and be of
a suitable accuracy for the a suitable accuracy for the
measurements it is required measurements it is required
to perform. to perform.
138 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
WWW.BRCGLOBALSTANDARDS.COM 139
7 PERSONNEL
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
The company shall ensure that all personnel The company shall ensure that all personnel
performing work that affects product safety, performing work that affects product safety,
legality and quality are demonstrably competent legality and quality are demonstrably competent
to carry out their activity, through training, work to carry out their activity, through training, work
experience or qualification. experience or qualification.
7.1.3 The site shall put in place 7.1.3 The site shall put in place
documented programmes documented programmes
covering the training needs covering the training needs
of relevant personnel. of relevant personnel.
These shall include as a These shall include, at a
minimum: minimum:
140 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
7.1.5 Records of all training shall 7.1.6 Records of all training shall A new bullet point
be available. This shall be available. These shall has been added
include as a minimum: include, at a minimum: so that when
internal training is
• the name of the trainee • the name of the trainee completed, there
and confirmation of and confirmation of
should be
attendance attendance
reference to the
• the date and duration of • the date and duration of
work instruction or
the training the training
procedure. This is
• the title or course • the title or course
an important aid to
contents, as appropriate contents, as appropriate
change control
• the training provider. • the training provider
(i.e. when the
Where training is • for internal courses, a
procedure is
reference to the material,
undertaken by agencies on updated or
work instruction or
behalf of the company, changes, it
procedure that is used in
records of the training shall becomes
the training.
be available. immediately
Where training is apparent who will
undertaken by agencies on need to be
behalf of the company, re-trained in the
records of the training shall new content).
be available.
7.1.6 The company shall routinely 7.1.7 The company shall routinely
review the competencies of review the competencies of
its staff. As appropriate, it its staff. As appropriate, it
shall provide relevant shall provide relevant
training. This may be in the training. This may be in the
form of training, refresher form of training, refresher
training, coaching, training, coaching,
mentoring or on-the-job mentoring or on-the-job
experience. experience.
WWW.BRCGLOBALSTANDARDS.COM 141
7.2 PERSONAL HYGIENE: RAW MATERIAL HANDLING, PREPARATION,
PROCESSING, PACKING AND STORAGE AREAS
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
The site’s personal hygiene standards shall be The site’s personal hygiene standards shall be
developed to minimise the risk of product developed to minimise the risk of product
contamination from personnel, be appropriate to contamination from personnel, be appropriate to
the products produced and be adopted by all the products produced and be adopted by all
personnel, including agency-supplied staff, personnel, including agency-supplied staff,
contractors and visitors to the production facility. contractors and visitors to the production facility.
142 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
7.2.3 All cuts and grazes on 7.2.3 All cuts and grazes on
exposed skin shall be exposed skin shall be
covered by an covered by an
appropriately coloured appropriately coloured
plaster that is different from plaster that is different from
the product colour the product colour
(preferably blue) and (preferably blue) and
contains a metal detectable contains a metal detectable
strip. These shall be site strip. These shall be
issued and monitored. site-issued and monitored.
Where appropriate, in Where appropriate, in
addition to the plaster, addition to the plaster,
a glove shall be worn. a glove shall be worn.
WWW.BRCGLOBALSTANDARDS.COM 143
7.3 MEDICAL SCREENING
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
The company shall have procedures in place to The company shall have procedures in place to
ensure that employees, agency staff, contractors ensure that employees, agency staff, contractors
or visitors are not a source of transmission of or visitors are not a source of transmission of
food-borne diseases to products. food-borne diseases to products.
7.3.1 The site shall make 7.3.1 The site shall make
employees aware of the employees aware of the
symptoms of infection, symptoms of infection,
disease or condition which disease or condition which
would prevent a person would prevent a person
working with open food. working with open food.
The site shall have a The site shall have a
procedure which enables procedure which enables
notification by employees, notification by employees,
including temporary including temporary
employees, of any relevant employees, of any relevant
symptoms, infection, symptoms, infection,
disease or condition with disease or condition with
which they may have been which they may have been
in contact or be suffering in contact or be suffering
from. from.
7.3.2 Where there may be a risk 7.3.2 Where there may be a risk
to product safety, visitors to product safety, visitors
and contractors shall be and contractors shall be
made aware of the types of made aware of the types of
symptoms, infection, symptoms, infection,
disease or condition which disease or condition which
would prevent a person would prevent a person
visiting areas with open visiting areas with open
food. Where permitted by food. Where permitted by
law, visitors shall be law, visitors shall be
required to complete a required to complete a
health questionnaire or health questionnaire or
otherwise confirm that they otherwise confirm that they
are not suffering from any are not suffering from any
symptoms which may put symptoms which may put
product safety at risk, prior product safety at risk, prior
to entering the raw material, to entering the raw material,
preparation, processing, preparation, processing,
packing and storage areas. packing and storage areas.
144 WWW.BRCGLOBALSTANDARDS.COM
7.4 PROTECTIVE CLOTHING: EMPLOYEES OR VISITORS TO PRODUCTION
AREAS
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
Suitable site-issued protective clothing shall be Suitable site-issued protective clothing shall be
worn by employees, contractors or visitors worn by employees, contractors or visitors
working in or entering production areas. working in or entering production areas.
WWW.BRCGLOBALSTANDARDS.COM 145
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
146 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
7.4.6 If gloves are used, they 7.4.5 If gloves are used, they
shall be replaced regularly. shall be replaced regularly.
Where appropriate, gloves Where appropriate, gloves
shall be suitable for food shall be suitable for food
use, of a disposable type, use, of a disposable type,
of a distinctive colour (blue of a distinctive colour (blue
where possible), be intact where possible), be intact
and not shed loose fibres. and not shed loose fibres.
WWW.BRCGLOBALSTANDARDS.COM 147
8 HIGH-RISK, HIGH-CARE AND AMBIENT HIGH-CARE PRODUCTION
RISK ZONES (NEW)
Please note that for the purposes of this document we have repeated the high-risk, high-care and ambient high-care clauses that
were located in different sections of Issue 7 for easy comparison with the wording for Issue 8.
Where a site produces products that require handling in high-risk, high-care and/or ambient high-care production facilities (see
Appendix 2 in the Standard for the definition of products that require these facilities), all the relevant requirements from sections
1–7 of the Standard must be fulfilled in addition to the requirements in this section.
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
The site shall be able to demonstrate that New statement of
production facilities and controls are suitable to intent for section 8.
prevent pathogen contamination of products.
4.3.1 There shall be a map of the 8.1.1 The map of the site (see Relocated from
site which designates areas clause 4.3.1) shall include Issue 7, clause 4.3.1.
(zones) where product is at areas (zones) where the Reference to
different levels of risk from product is at different levels Appendix 2 is to the
contamination; that is: of risk from contamination. appendix in the
The map shall show: Standard (not
• high-risk areas reproduced here).
• high-care areas • high-risk areas
• ambient high-care areas • high-care areas
• low-risk areas • ambient high-care areas
• enclosed product areas • low-risk areas
• non-product areas. • enclosed product areas
See Appendix 2 for • non-product areas.
guidelines on defining the See Appendix 2 for
production risk zones. guidelines on defining the
production risk zones.
This zoning shall be taken
into account when This zoning shall be taken
determining the into account when
prerequisite programmes determining the
for the particular areas of prerequisite programmes
the site. for the particular areas of
the site.
148 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.3.5 Where high-risk areas are 8.1.2 Where high-risk areas are Relocated from
part of the manufacturing part of the manufacturing Issue 7, clause 4.3.5.
site, there shall be physical site, there shall be physical
segregation between these segregation between these
areas and other parts of the areas and other parts of the
site. Segregation shall take site. Segregation shall take
into account the flow of into account the flow of
product, nature of materials product, the nature of the
(including packaging), materials (including
equipment, personnel, packaging), the
waste, airflow, air quality equipment, the personnel,
and utilities provision the disposal of waste, the
(including drains). The flow of air, the air quality,
location of transfer points and the provision of utilities
shall not compromise the (including drains). The
segregation between location of transfer points
high-risk areas and other shall not compromise the
areas of the factory. segregation between
Practices shall be in place high-risk areas and other
to minimise risk of product areas of the factory.
contamination (e.g. the Practices shall be in place
disinfection of materials to minimise the risk of
on entry). product contamination
(e.g. the disinfection of
materials on entry).
4.3.6 Where high-care areas are 8.1.3 Where high-care areas are Relocated from
part of the manufacturing part of the manufacturing Issue 7, clause 4.3.6.
site there should be site, there should be
physical segregation physical segregation
between these areas and between these areas and
other parts of the site. other parts of the site.
Segregation shall take into Segregation shall take into
account the flow of account the flow of
product, nature of materials product, the nature of
(including packaging), materials (including
equipment, personnel, packaging), the
waste, airflow, air quality equipment, the personnel,
and utilities provision the disposal of waste, the
(including drains). Where flow of air, the air quality,
physical barriers are not in and the provision of utilities
place, the site shall have (including drains). Where
undertaken a documented physical barriers are not in
risk assessment of the place, the site shall have
potential for cross- undertaken a documented
contamination, and risk assessment of the
effective, validated potential for cross-
processes shall be in place contamination, and
to protect products from effective, validated
contamination. processes shall be in place
to protect products from
contamination.
WWW.BRCGLOBALSTANDARDS.COM 149
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.3.7 Where ambient high-care 8.1.4 Where ambient high-care Relocated from
areas are required a areas are required, a Issue 7, clause 4.3.7.
documented risk documented risk
assessment shall be assessment shall be
completed to determine completed to determine
the risk of cross- the risk of cross-
contamination with contamination with
pathogens. The risk pathogens. The risk
assessment shall take into assessment shall take into
account the potential account the potential
sources of microbiological sources of microbiological
contamination and include: contamination and include:
150 WWW.BRCGLOBALSTANDARDS.COM
8.2 BUILDING FABRIC IN HIGH-RISK AND HIGH-CARE ZONES
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.4.4 Where sites include 8.2.1 Where sites include Relocated from
high-risk or high-care high-risk or high-care Issue 7, clause 4.4.4.
facilities, there shall be a facilities, there shall be a
map of the drains for these map of the drains for these
areas which shows the areas which shows the
direction of flow and direction of flow and the
location of any equipment location of any equipment
fitted to prevent the back-up fitted to prevent the back-up
of waste water. The flow of of waste water. The flow
drains shall not present a from drains shall not present
risk of contamination of the a risk of contamination to
high-risk/care area. the high-risk/care area.
4.4.13 High-risk areas shall be 8.2.2 High-risk areas shall be Relocated from
supplied with sufficient supplied with sufficient Issue 7,
changes of filtered air. The changes of filtered air. The clause 4.4.13.
filter specification used and filter specification used and
frequency of air changes frequency of air changes
shall be documented. This shall be documented,
shall be based on a risk based on a risk assessment
assessment, taking into that takes into account the
account the source of the air source of the air and the
and the requirement to requirement to maintain a
maintain a positive air positive air pressure relative
pressure relative to the to the surrounding areas.
surrounding areas.
WWW.BRCGLOBALSTANDARDS.COM 151
8.3 MAINTENANCE IN HIGH-RISK AND HIGH-CARE ZONES
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
• have specific
procedures (e.g. a full
clean) to ensure that
their use does not result
in contamination.
152 WWW.BRCGLOBALSTANDARDS.COM
8.4 STAFF FACILITIES FOR HIGH-RISK AND HIGH-CARE ZONES
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
WWW.BRCGLOBALSTANDARDS.COM 153
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
154 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
WWW.BRCGLOBALSTANDARDS.COM 155
8.5 HOUSEKEEPING AND HYGIENE IN HIGH-RISK AND HIGH-CARE ZONES
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
156 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.11.3 As a minimum for food 8.5.2 Microbiological limits for Acceptable limits for
contact surfaces, acceptable and cleaning of high-risk
processing equipment and unacceptable cleaning and high-care areas
for environmental cleaning performance shall be were previously
in high-care/high-risk defined for high-risk/ covered within
areas, limits of acceptable high-care production risk Issue 7, section 4.11,
and unacceptable cleaning zones. but these have now
performance shall be been transferred to
These limits shall be based
defined. This shall be this new section.
on the potential hazards
based on the potential
relevant to the product or
hazards (e.g.
processing area. Therefore,
microbiological, allergen,
acceptable levels of
foreign-body
cleaning may be defined by
contamination or product-
visual appearance, ATP
to-product contamination).
bioluminescence
Acceptable levels of
techniques (see glossary),
cleaning may be defined by
microbiological testing,
visual appearance, ATP
allergen testing or chemical
bioluminescence
testing as appropriate.
techniques (see glossary),
The site shall define the
microbiological testing or
corrective action to be
chemical testing as
taken when monitored
appropriate. Where
results are outside of the
cleaning procedures are
acceptable limits.
part of a defined
prerequisite plan to control Where cleaning
the risk of a specific hazard procedures are part of a
the cleaning and defined prerequisite plan to
disinfection procedures control the risk of a specific
and frequency shall be hazard, the cleaning and
validated and records disinfection procedures
maintained. This shall and frequencies shall be
include the risk from validated and records
cleaning chemical residues maintained. This shall
on food contact surfaces. include the risk from
cleaning chemical residues
on food contact surfaces.
WWW.BRCGLOBALSTANDARDS.COM 157
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
4.11.6 Cleaning equipment shall 8.5.3 Equipment used for Cleaning equipment
be: cleaning in high-care and for high-risk and
high-risk areas shall be high-care areas was
• hygienically designed visually distinctive and previously covered
and fit for purpose
dedicated for use in that within Issue 7,
• suitably identified for area. section 4.11, but this
intended use (e.g.
has now been
colour coded or
transferred to this
labelled)
new section.
• cleaned and stored in a
hygienic manner to
prevent contamination.
Equipment used for
cleaning in high-care and
high-risk areas shall be
visually distinctive and
dedicated for use in that
area.
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
158 WWW.BRCGLOBALSTANDARDS.COM
8.7 PROTECTIVE CLOTHING IN HIGH-RISK AND HIGH-CARE ZONES
7.4.4 Where protective clothing 8.7.2 Where protective clothing Laundries for
for high-care or high-risk for high-care or high-risk high-risk and
areas is cleaned by a areas is cleaned by a high-care areas
contracted or in-house contracted or in-house were previously
laundry, this shall be laundry, the laundry shall covered within
audited either directly or by be audited either directly Issue 7, clause 7.4.4,
a third party. The frequency or by a third party. The but these have now
of these audits should be frequency of these audits been transferred to
based on risk. shall be based on risk. this new section.
WWW.BRCGLOBALSTANDARDS.COM 159
ISSUE 7 ISSUE 8 COMMENTS
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS
7.4.5 Protective clothing shall be 8.7.3 Protective clothing for use Changes of
changed at an appropriate in high-risk and high-care protective clothing
frequency, based on risk. areas shall be changed at for high-risk and
For high-risk and high-care an appropriate frequency high-care areas
areas the protective based on risk, and at a were previously
clothing shall be changed minimum daily. covered within Issue
at least daily. 7, clause 7.4.5, but
these have now
been transferred to
this new section.
160 WWW.BRCGLOBALSTANDARDS.COM
9 REQUIREMENTS FOR TRADED PRODUCTS (PREVIOUSLY
8 REQUIREMENTS OF THE TRADED GOODS MODULE)
Where a site purchases and sells food products that would normally fall within the scope of the Standard and are stored at the
site’s facilities, but which are not manufactured, further processed or packed at the site being audited, the site’s management of
these products is covered by the requirements in this section.
All the relevant requirements from sections 1 to 8 must also be fulfilled in addition to the requirements outlined in this section.
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
The company shall operate procedures for The company shall operate procedures for All clauses in the
approval of the last manufacturer or packer of approval of the last manufacturer or packer of traded goods
food products which are traded to ensure that food products which are traded to ensure that module have been
traded food products are safe, legal and traded food products are safe, legal and amended to reflect
manufactured in accordance with any defined manufactured in accordance with any defined the new section (i.e.
product specifications. product specifications. previous clause
numbers in the
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS
module were in the
8.1.1 The company shall have a 9.1.1 The company shall have a format 8.*.*; these
documented supplier documented supplier have now been
approval procedure which approval procedure which amended to 9.*.*).
identifies the process for identifies the process for
initial and ongoing initial and ongoing
approval of suppliers and approval of suppliers and
the manufacturer/ the manufacturer/
processor of each product processor of each product
traded. The requirements traded. The requirements
shall be based on the shall be based on the
results of a risk assessment results of a risk assessment
which shall include which shall include
consideration of: consideration of:
WWW.BRCGLOBALSTANDARDS.COM 161
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
8.1.2 The process for the initial 9.1.2 The company shall have a
and ongoing approval of procedure for the initial and
the manufacturers of ongoing approval of
products shall be based on: manufacturers of products.
This approval procedure
• certification of the shall be based on risk and
manufacturing/packing
include either one or a
site to the applicable
combination of:
BRC Global Standards
or other Global Food • a valid certification to
Safety Initiative (GFSI) the applicable BRC
benchmarked standard Global Standard or
GFSI-benchmarked
and/or
standard. The scope of
• supplier audit with a the certification shall
scope to include include the products
product safety, purchased
traceability testing and
HACCP (Hazard
• supplier audits, with a
scope to include
Analysis and Critical product safety,
Control Point) and good traceability, HACCP
manufacturing review and good
practices, undertaken manufacturing
by an experienced and practices, undertaken
demonstrably by an experienced and
competent product demonstrably
safety auditor. competent product
By exception only and safety auditor. Where
where a valid risk-based this supplier audit is
justification is provided, completed by a second
initial and ongoing or third party, the
approval may be based on: company shall be
able to:
• a historical trading –– demonstrate the
relationship supported competency of the
by documented auditor
evidence of –– confirm that the
performance reviews scope of the audit
demonstrating includes product
satisfactory safety, traceability,
performance HACCP review and
• a manufacturing-site good manufacturing
questionnaire which has practices
been reviewed and –– obtain and review a
verified by a copy of the full audit
demonstrably report
competent person
• a specific customer or
requirement to supply
product from a
manufacturer where
liability is with the
customer.
162 WWW.BRCGLOBALSTANDARDS.COM
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
WWW.BRCGLOBALSTANDARDS.COM 163
ISSUE 7 ISSUE 8
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
164 WWW.BRCGLOBALSTANDARDS.COM
9.2 SPECIFICATIONS (PREVIOUSLY 8.2)
8.2.2 The company shall seek formal 9.2.2 The company shall seek formal
agreement of the agreement of the
specifications with relevant specifications with relevant
parties. Where specifications parties. Where specifications
are not formally agreed, the are not formally agreed, the
company shall be able to company shall be able to
demonstrate that it has taken demonstrate that it has taken
steps to ensure formal steps to ensure formal
agreement is in place. agreement is in place.
WWW.BRCGLOBALSTANDARDS.COM 165
9.3 PRODUCT INSPECTION AND LABORATORY TESTING (PREVIOUSLY 8.3)
8.3.1 The site shall have a 9.3.1 The site shall have a
product sampling or product sampling or
assurance programme to assurance programme to
verify that the products are verify that the products are
in accordance with buying in accordance with buying
specifications and meet specifications and meet
legal and safety legal and safety
requirements. requirements.
Where verification is based Where verification is based
on sampling, the sample on sampling, the sample
rate and assessment rate and assessment
process shall be risk- process shall be risk-
based. based.
Records of the results of Records of the results of
assessments or analysis assessments or analysis
shall be maintained. shall be maintained.
8.3.3 Where claims are made 9.3.3 Where claims are made
about the products being about the products being
handled, including the handled, including the
provenance, chain of provenance, chain of
custody, and assured or custody and assured or
‘identity preserved’ status ‘identity preserved’ status
of a product or raw of a product or raw
materials used, supporting materials used, supporting
information shall be information shall be
available from the supplier available from the supplier
or independently to verify or independently to verify
the claim. the claim.
166 WWW.BRCGLOBALSTANDARDS.COM
8.3.4 Where the company 9.3.4 Where the company
undertakes or undertakes or
subcontracts analyses subcontracts analyses
which are critical to product which are critical to product
safety or legality, the safety or legality, the
laboratory or laboratory or
subcontractors shall have subcontractors shall have
gained recognised gained recognised
laboratory accreditation or laboratory accreditation or
operate in accordance with operate in accordance with
the requirements and the requirements and
principles of ISO 17025. principles of ISO 17025.
Documented justification Documented justification
shall be available where shall be available where
non-accredited test non-accredited test
methods are used. methods are used.
8.3.5 Test and inspection results 9.3.5 Test and inspection results
shall be retained and shall be retained and
reviewed to identify trends. reviewed to identify trends.
Appropriate actions shall Appropriate actions shall
be implemented promptly be implemented promptly
to address any to address any
unsatisfactory results or unsatisfactory results or
trends. trends.
WWW.BRCGLOBALSTANDARDS.COM 167
9.4 PRODUCT LEGALITY (PREVIOUSLY 8.4)
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
The company shall have processes in place to The company shall have processes in place to
ensure that the food products traded comply with ensure that the food products traded comply with
the legal requirements in the country of sale the legal requirements in the country of sale
where known. where known.
8.4.1 The company shall have 9.4.1 The company shall have
documented processes to documented processes to
verify the legality of verify the legality of
products which are traded. products which are traded.
This shall include as These processes shall
applicable: include as appropriate:
168 WWW.BRCGLOBALSTANDARDS.COM
9.5 TRACEABILITY (PREVIOUSLY 8.5)
ISSUE 7 ISSUE 8
STATEMENT OF INTENT STATEMENT OF INTENT COMMENTS
The company shall be able to trace all product The company shall be able to trace all product
lots back to the last manufacturer and forward to lots back to the last manufacturer and forward to
the customer of the company. the customer of the company.
8.5.1 The site shall maintain a 9.5.1 The site shall maintain a
traceability system for all traceability system for all
batches of product which batches of product which
identifies the last identify the last
manufacturer or, in the case manufacturer or, in the case
of primary agricultural of primary agricultural
products, the packer or products, the packer or
place of last significant place of last significant
change to the product. change to the product.
Records shall also be Records shall also be
maintained to identify the maintained to identify the
recipient of each batch of recipient of each batch of
product from the company. product from the company.
8.5.2 The company shall test the 9.5.2 The company shall test the
traceability system at least traceability system at least
annually to ensure that annually to ensure that
traceability can be traceability can be
determined back to the last determined back to the last
manufacturer and forward manufacturer and forward
to the recipient of the to the recipient of the
product from the company. product from the company.
This shall include This shall include
identification of the identification of the
movement of the product movement of the product
through the chain from the through the chain from the
manufacturer to receipt by manufacturer to receipt by
the company (e.g. each the company (e.g. each
movement and intermediate movement and intermediate
place of storage). place of storage).
8.5.3 The traceability test shall 9.5.3 The traceability test shall
include the reconciliation of include the reconciliation of
quantities of product quantities of product
received by the company received by the company
for the chosen batch or for the chosen batch or
product lot. Traceability product lot. Traceability
should be achievable should be achievable
within 4 hours (1 day when within 4 hours (1 day when
information is required from information is required from
external parties). external parties).
WWW.BRCGLOBALSTANDARDS.COM 169
BRC Global Standards
Floor 2
7 Harp Lane
London EC3R 6DP
Tel: +44 (0) 20 3931 8150
Email: enquiries@brcglobalstandards.com