BRC Food Safety Issue 8—Key Changes & Timeline
On August 1, 2018, BRC published the much-awaited BRC Global Standard for Food Safety Issue 8. This new version of the standard will replace Issue 7 after a six month transition phase. Therefore, certification to Issue 8 commences from February 1, 2019. To get you prepared, this article outlines all the key changes that come with BRC Food Safety Issue 8.
What BRC Focused on for Food Safety Issue 8
Despite being an evolution from previous versions of the standard, the BRC Global Standard for Food Safety Issue 8 introduces quite a lot of significant changes compared to its predecessor Issue 7. Issue 8 now puts even greater emphasis on management commitment, requiring the site’s senior management to demonstrate that they are fully committed to the implementation of the standard as well as to processes which facilitate the continual improvement of food safety and quality management. This should go hand in hand with the development and establishment of an active food safety and quality culture (clause 1.1.2), supported by a solid quality management system.Furthermore, the BRC’s focus of attention has been on:
- expanding the requirements for environmental monitoring to reflect the increasing importance of this technique
- encouraging sites to further develop systems for security and food defence
- adding clarity to the requirements for high-risk, high-care and ambient high-care production risk zones
- providing greater clarity for sites manufacturing pet food
- ensuring global applicability and bench-marking to the Global Food Safety Initiative (GFSI)
Key Changes in BRC Food Safety Issue 8
Internal Audits Have to Be Spread Throughout the Year
Internal audits are a common area of non-conformities at BRC Food Safety audits. With Issue 8 it is now required to have a scheduled program of internal audits with at least four different audit dates spread throughout the year (clause 3.4.1). This is to prevent a tightly scheduled block of internal audits immediately prior to the certification audit. For each internal audit a clear scope needs to be defined, in order to ensure that all activities are covered at least once a year, with the actual audit frequency of each activity being based on the risks associated.
Establishment of a Confidential Reporting System
Section 1 of the standard stipulates that employees not only have to be aware of the need to report any evidence of unsafe or out-of-specification products or raw materials (clause 1.1.5), but also need to have access to a confidential reporting system that enables them to report any concerns relating to product safety, integrity, quality, and legality (clause 1.1.6). Therefore, a process for handling and documenting all the concerns addressed must be implemented and clearly communicated to all employees concerned.
Mandatory Food Safety Training for Team Leaders
BRC Food Safety Issue 8 introduces mandatory, demonstrable food safety training for food safety team leaders (clause 2.1.1). Being able to demonstrate competence and experience alone is not sufficient. Furthermore, all team members shall have specific knowledge of HACCP and relevant knowledge of products, processes and associated hazards.
Distinct Clauses for Supplier Approval & Supplier Monitoring
Previously combined under one clause, Supplier Approval (clause 18.104.22.168) and Supplier Monitoring (clause 22.214.171.124) have been split in BRC Food Safety Issue 8, recognizing that they are two distinct measure of supplier control. While Supplier Approval shall ensure that all suppliers of raw materials effectively manage risks and are operating effective traceability processes, Supplier Monitoring shall ensure the ongoing review of approved suppliers based on risk and defined performance criteria.
How, Why, and Where to Perform Root Cause Analysis
Root Cause Analysis has already been mentioned in versions 6 and 7 of the standard, without ever defining how, why, and where to perform it. BRC Food Safety Issue 8 now stipulates this with clause 3.7.3., which defines that, at a minimum, root cause analysis shall be used to implement ongoing improvements and to prevent recurrence of non-conformities when trends indicate a significant increase in a certain type of non-conformity or when a non-conformity places the safety, legality, or quality of a product at risk.
Recognition of Cyber Security Incidents
BRC Food Safety Issue 8 recognizes cyber security as a major risk factor in food safety and requires organizations to implement procedures to document and effectively manage cyber security incidents. Clause 3.11.1 now includes incidents regarding the „failure of, or attacks against, digital cyber security“ as a potential reason to consider the withdrawal or recall of products whenever a food’s safety, quality, or legality is at risk.
One of the big areas of change in Issue 8 is clause 4.11.8, which introduces Environmental Monitoring—an area where a lot of companies have a lack of both systems and controls. The clause defines that risk-based environmental monitoring programs have to be in place for pathogens or spoilage organisms and shall include at least all production areas with open and ready-to-eat products. The clause also outlines specifically what controls and measures have to be in place.
Product Control Clauses for Pet Food
Section 5 about Product Control now includes clauses dedicated specifically to pet food (clause 5.8), requiring the site to ensure that pet food products are safe and fit for the intended use. This, for instance, includes that sites producing pet food products for different animal species shall have specific procedures for the management of any ingredients, raw materials, products, or rework that could be harmful to a non-intended recipient species.
Full Validation of Cooking Instructions
Another new requirement in BRC Food Safety Issue 8 is that all cooking instructions provided with food products (e.g. on the packaging) must be fully validated. This is to ensure that foods prepared according to these instructions consistently result in a safe and ready-to-eat product.
New Section 8: High-Risk, High-Care, and Ambient High-Care Requirements
In BRC Food Safety Issue 8, all requirements for production facilities falling into the high-risk, high-care, and/or ambient high-care, which have previously been part of the sections 4 and 7, are now centralized in the newly introduced section 8. All clauses of section 8 need to be fulfilled in addition to all the relevant requirements form sections 1–7 and are intended to ensure that all sites are able to demonstrate that production facilities and controls are suitable to prevent pathogen contamination of products.
New Section 9: Requirements for Traded Products
Previously an additional, voluntary module, the requirements for traded products have now been included in BRC Food Safety Issue 8 in the newly introduced section 9. The requirements of section 9 apply where a site purchases and sells food products that would normally fall within the scope of the standard, but are only stored at the site’s facilities without being manufactured, processed, or packed there. Unlike in Issue 7, any non-conformities regarding traded products will now affect the overall grade.
Transition Timeline & Next Steps
BRC published the following timeline for the publication and implementation of its Global Standard for Food Safety Issue 8:
|August 1, 2018||publication of Food Safety Issue 8|
|September 2018||training of BRC approved training partners|
|October 2018||auditor and site training begins|
|February 1, 2019||audits to Food Safety Issue 8 commence|
Table 1: Timeline for the BRC Global Standard for Food Safety Issue 8
While this article serves you with all the information needed in order to quickly get your head around all the key changes in BRC’s food safety standard, I would highly recommend to download the full version of the BRC Global Standard for Food Safety Issue 8, which can be downloaded free of charge from the BRC Bookshop ».