The BRC FSMA Voluntary Module…
BRC have issued the BRC FSMA Voluntary Module – FSMA Preventive Controls Preparedness Module & Guidance for BRC-certified Facilities. The BRC FSMA Voluntary Module is designed to be bolted-on to your BRC audit, and covers all additional requirements, above and beyond the normal BRC standard – that are required to meet FSMA.
It will add about 3 or 4 hours to your typical audit time. You can choose to do it and add it onto your audit, without worrying that it may affect your audit score. Because it’s a voluntary module, the non-conformances raised against the clauses do not affect your audit score. Any non-conformities that are raised against the clauses in the module have to be completed and closed out, prior to the module being included on the certificate.
The module is free to download, you can get a copy of it here…
The module includes 10 pages of additional clauses. Each clause is referenced with the 21 CFR § section number, so you can relate it back to the FSMA rule. The BRC have then also provided guidance as to how to comply with this section of the rule and how it differs from the BRC requirements.
One thing they’ve not done, which I would have found useful, is to reference which part of the Food Safety standard the section would sit. This way, it would have been easier to make sure that the section is added to the right part of your BRC Quality Management System. In some cases, they have stated the clause in the normal standard that it refers to, but only if it’s part of the explanation for the guidance. It’s possible to work out where they go, but it would have been easier for the BRC to provide this for you, plus that way, it’s only being done once by the BRC, rather than by each site that wants to use the module.
There are only 23 additional requirements to meet the module. Quite a few of them are already implied in the BRC standard, so you may find that you are already meeting the requirement anyway. The points are also not complex, and the guidance provided by the BRC is easy to follow.
Looking at the BRC Directory is looks as if there are only a few sites that currently have the BRC FSMA Voluntary Module. It would be interesting to know what the FDA think of it, as it would seem sensible for them to use this module, along with the BRC standard as a way of approving facilities around the world, who want to import food into the U.S, rather than developing and implementing their own audit standard. Only time will tell.
If you have any questions about the BRC FSMA Voluntary Module, or if you’d like me to go into more detail about any of the section requirements – please let me know in the comments section below. Or, if you’ve taken this module, or are working towards it – please let me know how you’re doing, I’d love to hear how you get on!
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