BRC v9 - Quick Overview of Changes

I believe there can hardly be a dispute that the BRC Food Safety standard is fundamental to UK food industry. Changes introduced over years with new issues of the standard undoubtedly had a significant impact on how we run our food factories today. Looking at historical shifts I think the biggest change between versions was the move from issue 6 to 7. Following the "Horsegate" BRC evolved from a "cellular" approach of considering each site as an individual entity to forcing technical managers to consider their business position in a wider chain of custody. Sweeping changes to supplier approval requirements, the introduction of Fraud Vulnerability Assessments and the requirement of considering whether suppliers are approved to a GFSI standard were definitely a game-changers.

So let us have a look BRC Issue 9 and touch on a couple of interesting points introduced. Please bear in mind that in this article I am not conducting a full gap analysis but merely rasing couple of discussion points against some proposed changes.

Section 1 - Senior Management Commitment

It seems that BRC put a lot of consideration into this section. Previous issues treated section one as quite "woolly" where various levels of evidence could be used to satisfy the requirement. Clause 1.1.2 was now significantly expanded with manufacturers asked to have a multifaceted plan on how the culture change is to be delivered. There are clear stipulations of areas like communication on product food safety, training, feedback from employees and performance management of product safety. It is also quite clear that section one was now expanded to ensure that it covers not only food safety but also authenticity, legality and quality.

Another significant change is the introduction of new clauses which make sure that business is clear on skills and training levels required for activities associated with food safety, authenticity and legality enforcing a sufficient level of training provided to employees. The interesting point is a requirement for all relevant employees to have access to relevant documentation to be able to request an assessment of training needs for activities undertaken. This might signify that auditors will be focusing more on what training is required against what is provided. Where historically the focus was mainly around CCPs this now is likely to be expanded to other areas of QMS.

I have a feeling that the training departments will become very busy once v9 will be issued.

Section 2 Food Safety Plan - HACCP

It seems that the writers decided to increase focus on validation and documentation of the HACCP studies. The prerequisite programme was now expanded to include references to specific requirements for various sections of the standard e.g. hygiene, pest management etc.

HACCP documentation requirements were now expanded to include items historically only required for HC/HR sites e.g. a copy of any existing site HACCP plans, a map of the premises and equipment layout, water distribution diagram, indication of any areas (zones) Those should not come as a surprise to any manufacturers supplying retailers as those requirements were present in those CoPs for years now and BRC is playing a catch-up game. If anything I am surprised that BRC did not include drains layout in the same list.

Significant change is a requirement for validation of all critical limits BEFORE implementation or prior to any changes. The word validation now appears in quite a few clauses signifying that it will become a point of focus for the audits and sites ought to make sure they are on top of their schedules.

Section 2.14 covering triggered HACCP reviews was now completely struck off which is an interesting decision since it was well established across the industry. Some of the review requirements were now scattered across other clauses.

3. Food safety and quality management system

Section 3 is one of the biggest in the standard but with the exception of outsourced processes 3.5.4 and management of incidents 3.11.4 this section was not changed in a major way. Coupe minor changes include the expansion of Internal Audits scope with: the requirements covering product food safety, quality culture plan as well as assessment of the site’s conformity with their food safety and quality management systems.

Another minor change worth noting in section 3 is BRC attempt to further consolidate GFSI standards introducing additional requirements for suppliers who are not approved to GFSI approved scheme. Those now will not only have to be audited as per previous BRC issues but the scope of the audits was now expanded to cover Food Defence and Authenticity. Considering that supplier monitoring programmes usually are delivered over a number of years a transition period will need to be considered.

My "favourite" change is the expansion of clause 3.5.3.1 Existing requirements relevant to service providers were now stretched to cover "product safety consultants". This fairly generic statement, in the long run, might have an interesting impact on the industry which might try to self-regulate of who can actually call themselves a "food safety consultant"

3.5.4 Management of outsourced processing

I have singled out this part of section 3 as the proposed changes are significant. Where historically standard was not very descriptive on outsourced processing this time around a very detailed and clear definition of what is outsourced process was included (whole 15 lines) Following from detailed definition standard proceeds to establish a number of requirements that need to be met for the outsourced process. Amongst others, this includes the ability to be able to prove that the customers are aware of the outsourced process. Providers of the outsourced processes would have to be GFSI approved or physically audited. Outsourced processes and risks need to be captured in HACCP.

In essence, judging by the level of challenge and expanded definitions this will become one of the focus points during audits. I would advise all manufacturers to look at their process flows against the expanded definitions to ensure there are no hidden outsourced processes in their HACCP.

3.11 Management of incidents, product withdrawal and product recall

In the vast majority, the section is subjected to only small corrections. The big change is associated with clause 3.11.4 now asking for BRC to be advised about incidents associated with food safety. However where historically this was associated with recall or regulatory food safety non-conformity now this was expanded to include a food safety related withdrawal.

This is quite a controversial change as in many cases final decision of product withdrawal seats with the customer, not with a manufacturing site and is very subjective to the customer technologist handling the case. BRC asks the site not only to advise about the incident but also to provide sufficient information to enable the certification body to assess any effects of the incident on the ongoing validity of the current certificate.

Reading between the lines where historically site was at the risk of losing accreditation following the recall now this might occur as a result of a recall.

Based on experience and historical research I conducted on allergen incidents it is clear that withdrawal and/or their numbers are fairly obscure KPI that is seldom shared outside of the customer <=> supplier relationship. It will be interesting to see if this point will make it to the final version. I predict that this clause due to the withdrawal's subjectivity could end up causing a lot of tensions between customers, suppliers and certification bodies.

4.6 Equipment

This whole section was pretty much rewritten from scratch. Sweeping changes were introduced to how the equipment is introduced to site and managed. Sites supplying retail would probably have most of new requirements covered as they seem to migrate from retail CoPs into BRC. Smaller sites, B2B and Food Service could find some of the new points to be a challenge.

In essence, the section was expanded from 2 to 7 clauses advocating the risk assessment approach in the introduction and approval of new equipment. It also covers aspects of construction, hygiene and cross-contamination including chemical (e.g. from battery operated equipment)

5.9 Animal Converion

Introduction of a completely new section focused on sites conducting animal primary conversion (e.g. for red meat, poultry or fish) the following requirements apply, in addition to those within the rest of the Standard. 4 specific clauses were now added to the standard.

Clauses are predominantly discussing the risk assessment approach, fitness for human consumption, traceability, requirements for documented post-slaughter procedures and storage,

Conclusions:

In essence, although a number of changes is significant I would not describe the standard as revolutionary. BRC seems to continue its drive to enforce Food Culture across the industry in a sensible approach from top to down charging management teams in providing the right level of training and awareness to factory floor operatives.

The remaining changes are pretty much a catch-up game with retail CoPs. The big manufacturers will likely take those in stride but the smaller organizations might need to reconsider how they document/evidence some of the newly added clauses.

The change which has the potential to "shakedown" the industry is the risk of losing the certification status as a result of food safety withdrawal. Unlike recalls withdrawals, unfortunately, are quite common in the industry. This is because retail technologists tend to air on the side of caution to protect their brands. Even if the risk is negligible they can withdraw products to further reduce the potential exposure. This change can also become a double-edged sword with BRC or certification bodies being swamped with a high number of withdrawals to assess and consider.

If BRC will dig their hills in implementing this clause and actually enforcing potential losses of certification it might have another unintended consequence. If retailers and manufacturers will over time become more reluctant to withdraw the product in fear of potential consequences it might result in actually unsafe product ending up on the shelf.