BRCGS Food Safety
BRCGS Food Safety Issue 9
BRCGS Food Safety Issue 9 is now being audited. Catch up here on what’s been happening since it launched and what you can get your hands on to help you!
BRCGS Food Safety Issue 9 has arrived!
If your audit was on or after 1st February 2023, you’ll have now been audited to BRCGS Food Safety Issue 9.
Why not breeze through it like Lisa’s team at R&G Fresh did…
Just to let you know…
We had our BRC Unannounced Audit week before last, we only got 1 Minor NCR, and the auditor said it was the best conversion he’s seen so far from 8-9, so seeing as we’ve used quite a lot of your information & courses, I reckon you can take some of the credit for that too!
Lisa, R&G Fresh
BRCGS Food Safety Version 9 standards
Here are links to the latest food standard:
- BRCGS Issue 9 standard (the locked version is free).
- BRCGS Issue 9 interpretation guide.
- BRCGS Issue 9 key changes.
Note: the above are free to anyone with a BRCGS Participate login (approved sites).
BRCGS Food Safety Issue 9 training
Role-based training to explain the changes that took place from Issue 8 to Issue 9 of the food standard. Below, there’s a course for techies and other roles in your business that are directly impacted by the changes; senior managers, operations, engineering and procurement. The courses will teach each of these roles what the changes are that impact them, what they mean and how to implement them.
Book a call with Kassy
Would you like to discuss training for Issue 9? Then book a Teams call with Kassy – she can answer any questions you may have and help you to tailor a solution to suit your needs. Just fill in the form below and she’ll be in touch!
PLEASE NOTE: Our training is not approved by BRCGS. If it was, we’d have to work to their curriculum – which we don’t. Our curriculum allows the training we provide to be more helpful, actionable and affordable. If you want official BRCGS training which explains what the changes are, but not how to implement them – then please go to https://www.brcgs.com/training/ If you’re worried it’s not approved by BRCGS, don’t be – it wont impact your audit, it may even improve it!
Our BRCGS Food Safety Issue 9 Webinars
BRCGS Food Safety Issue 9 for techies webinar – 11th October 2022
This webinar was a huge succes, thank you to everyone who joined us live!
BRCGS Food Safety Issue 9 – transcript from the webinar
Welcome to an overview of the changes in Issue 9 for techies. This webinar is designed for techies who want an overview of the changes in BRCGS Food Safety from Issue 8 to Issue 9.
Full transparency before we start. We are not affiliated to BRCGS in any way, and we are not a BRCGS approved training provider. This is because we have chosen not to be, as we don’t want to have to stick to the curriculum provided by BRCGS, as we believe that this prevents the training from being actionable.
We also not going to be able to go through every change in the standard during this webinar, as this would take too long. What we will do is highlight to you, the key parts of the standard, that you need to focus on, ready for your next audit.
To enable this, we’ve gone through both the standard and the interpretation guide, for both Issue 8 and 9, and compared them line by line. We’ve not used the BRCGS key changes document for this, as we know that it doesn’t call out all the important changes to the level of detail that we would need.
This webinar will explain some of the outputs of that piece of work. We won’t be showing you extracts from the standard, as BRCGS wouldn’t allow us to do this for copyright reasons, and you’ll probably know by now – that we like to do things our way, as we like to make it simple and easy to understand.
We have an hour in total. The presentation will take about 40 minutes and then there will be 20 minutes for questions at the end. Please put your questions into the chat and we’ll pick out the most popular ones to answer at the end. Okay, with that being said, let’s crack on!
Key dates
The new standard was published on 1st August and will be audited from 1st February 2023. Therefore, if you have your audit on or from 1st February, you’ll be audited to Issue 9.
Changes to audit
Although the standard states that the audit options have been updated, looking at them it seems that the ones that were published during the pandemic, have just been incorporated into the new issue.
Scope
What has changed is the available scope and strangely they don’t seem to have made a point about this.
The permitted scopes now include the manufacturing of animal feed and products from primary animal conversion.
These aren’t listed clearly however in the categories, but the definition of animal primary conversion does state that it would fit within categories 1, 2 and 4. I would expect therefore, for animal feed to sit within a relevant category, for example, dried animal feed would sit within category 15 for dried products.
For me the interesting part about this change, is that it means it’s not just a human food standard anymore. Pet food was added for issue 8 and now animal feed has also been introduced. (Update 12.10.22 BRCGS have today clarified that the manufacture of animal feed hasn’t been added to the scope, they were in fact referring to by-products that are manufactured to be further processed into animal feed. This means these clauses apply to you if you produce by-products for this purpose.)
So, let’s go onto the changes, starting first with those that BRCGS have called out.
The changes
Audit options are one of the changes that BRCGS have highlighted, but we’ve already been through that – so let’s look at the others which are:
- Culture.
- Internal audits.
- Root cause analysis and preventive action.
- Incident management.
- Animal conversion and animal feed.
Let’s go through each one.
Culture
At first glance is looks like a small update to the standard, but in reality, it’s huge!
In issue 8 culture was contained to one clause – 1.1.2. In Issue 9 it’s starting to appear throughout the standard, starting with the quality policy, or as we like to call it the commitment policy.
The commitment policy tends to be seen as a piece of paper that gets reprinted once a year, just before the audit so that they site manager can sign it, ready for the audit. However, it’s meant to be so much more than that – which is why we call it the commitment policy. Because, it’s not about just quality, or even food safety, it’s about the business’ commitments. The fact that culture has to now feature in the commitment policy, means that BRCGS is saying that the culture needs to permeate through everything we do, every day.
This means that it must be woven into every part of the management system. This is why, we’ve now started to include culture, in every series of courses that we produce. The idea, is to make the aim of culture within each topic and every department super clear, so that everyone understands what it means. Which is a huge challenge!
This theory is then reinforced when you look at the change to clause 1.1.11. This clause now states that the senior management TEAM must present the culture plan at the audit. This change is massive and for me, it’s the best change in the standard. It means, that no longer is the audit and compliance to the standard a technical job. But it has to be a team effort. Each department lead, who sits on the senior management team, needs to know who culture impacts their department and what they’re departmental team are doing about it. I think things have moved on over the years, and it’s now understood that other members of management team needs to get involved in the audit. But it’s still led by technical, and it always will be – but this change means that every department now needs to be accountable for their own area. The senior manager, needs to present compliance to the senior management commitment section of the standard, without support from technical. The engineering manager, needs to present the equipment and maintenance sections of the standard. Procurement need to present the supplier management system, and so on.
If this is enforced, it’s going to be a game changer. Imagine giving accountability to the relevant department managers for their procedure and everything associated with it. This would mean, the senior manager on site would be accountable for topic 1 senior management commitment, and so they would be responsible for the compliance of that procedure, any non-conformances that arise from it, and any actions or improvements that need to be made to it. Imagine what that would be like, if the engineering manager was accountable for compliance to the equipment and maintenance sections of the standard, including the procedure and effective implementation of it. It would be amazing!
This is how we as a technical community need to start looking at it. It’s going to be a long journey and will take many years, but it all starts with a mindset shift. We like to be in control, and this is going to mean, we have to relinquish some of that control. We need to start thinking about being a support function, rather than the function that does it all.
Internal audit
Although the BRCGS have called this change out, to me there’s not a huge amount of change here.
There’s been a lot more text added, but there’s only a couple of changes:
- Auditors now need to be trained in soft skills, to help them to carry out a robust audit. And it’s been stressed again that auditors must be trained in the topic that they’re going to audit. To me, this is a huge problem, so I’m glad that they’re taking one step closer to tackling this. Training auditors on how to do an audit is obviously important, but it’s not the total solution. To do a robust audit, you need to understand the topic that you’re auditing. And this is something, that we just don’t do well in our industry.
- The other change is about the review of the results of the internal audit programme and the non-conformances that arise from it. This goes back to culture again. The senior management team, must have an awareness of how all the systems are performing. They don’t need to know the detail, but they do need to know if there’s a problem appearing, so that they can provide support to correct it, before it causes an issue.
This means, that fundamental systems like the internal audit programme and the non-conformance system, must be reported up through the business to management regularly. The information must be presented in a way that the management team can digest easily and quickly. The best way is using KPIs, so that they can visually see how the system is performing and pinpoint issues quickly, so that they can then drill down into that information where needed to find out what’s going wrong and fix it. This is what the changes to 3.4.3 and 3.4.4 are looking for.
Root cause analysis and preventive action
Although there’s not been a great deal of change in the requirements of root cause analysis, the relationship of it to culture has been stressed. In clause 1.1.12 the interpretation refers to how the sites attitude towards preventive action, will impact how non-conformances at audit will be managed. That a poor culture will mean that they’ll be treated as a tick box exercise to get the certificate.
Incident management
Again, there’s not huge changes to this section, so I’m not sure why BRCGS has highlighted this. The major changes are around when you must notify your certification body CB. The scope of incidents has also been expanded to include authenticity and legality issues. You must also test the incident procedure as a whole, not just the recall and withdrawal system and have a contingency plan in place for product contamination incidents.
Animal conversion and animal feed
A new section has been created for primary animal conversion, although I’m not sure why – as all the points within it, should have already been covered in the other relevant parts of the standard – if it was applied correctly. This only applies to sites who are slaughtering and in the UK these requirements would be governed by the FSA and DEFRA, so it’s likely that you’ll already have them in place.
The pet food section has also been updated, to include animal feed now.
Other changes
Right, let’s get onto the good bits. There is also a raft of other changes in the standard, that BRCGS haven’t referred to in their ‘what’s new for Issue 9’ section. You obviously need to action all the changes in the standard, but we want to share our thoughts with you, on what the key changes are. Let’s go over each one.
Senior management commitment
There are a number of changes in this section and relating to this section.
Culture is the obvious one. The management team, must now start to take culture seriously and think about how it can be integrated into everything that you do. The simple solution we’ve come up with is a culture scale that can be applied to any topic or department. If you’ve heard of a maturity matrix before, it’s very similar to this.
It defines what it a business would look, feel, and behave like, depending where they are on the culture scale. This makes it easy to understand and know what you need to do, to move along the culture scale – to improve culture. We’ve started working these into all of our subject matter courses, so there’s one in our maintenance course for example, which can be used with engineers.
Management of non-conformances is another key aspect of culture that you must think about, as it has such as direct correlation with culture. A business with a poor culture will have lots of overdue non-conformances, or non-conformances that keep getting coming up time and time again, because there’s not enough time to close them out properly. Business’ which have a positive culture, will spend more time on preventive action than corrective action, as they see the benefit in it.
Finally, the last part of the senior management section that needs attention is setting objectives, which of course must include culture, and then ensuring that there’s a programme of management meetings. The word ‘programme’ is key here, as management review shouldn’t be something that happens once a year to tick the box for audit. A structured approach is needed where information can be reviewed during shift huddles on the factory floor, which is then fed into daily morning meetings, which is then fed into monthly management meetings, which is then fed into quarterly business reviews and so on.
Product defence
Your product defence team, you may call them VACCP or TACCP team, must now be trained. Vulnerability in the upstream supply chain, or VACCP – is the defence of products from fraud. And, threats on site and in the downstream supply chain, or TACCP, is the defence of products from malicious contamination. It’s all defence, which is why we class it as one thing – product defence.
Anyhow, your team or teams must now be trained. This makes sense as it’s a sensible next step in the topics development. You have to have a trained HACCP team, so it makes sense that you must have a trained product defence team.
Supplier management
Although there’s not massive changes in this section, there’s a LOT:
- We don’t have enough time to go through them all, but the interesting ones are that the standard has now clarified that the product defence plan (or VACCP if that’s what you call it) must now integrate into your material risk assessment. So the outputs from your VACCP system, must be an input into your material risk assessment.
- Monitoring has been stressed again, so we need to have much more robust systems in place to gather data about our suppliers, so that it can be assessed. Service suppliers also now need to be monitored, after they’ve been approved.
- Finally, the list of service suppliers has been increased again, with consultants now being put back in again. They’ve also added training providers to the list, which as you can imagine I find really interesting!
It’s interesting because you wouldn’t normally have access to the information you need, to be able to approve or monitor a training provider. As a business, we’re going to create a pack for our customers, which includes a risk assessment, evidence that they can use to approve us and also data that they can use to monitor us. But that’s because we work so closely to the standard and we’re a small enough business to be flexible enough to do that. How companies like Highfield will react to this, I’m not sure. And if you think even further, BRCGS provide their own training – so how would you approve and monitor BRCGS as a training provider?
If you’re a Techni-K customer and want to approve us as a training provider, all the information you need to approve us can be found here.
Maintenance
The equipment section has been totally rewritten, so there are a lot of changes:
- Specifications are now needed for engineering materials and equipment.
- The requirements for direct contact materials have been improved, so you now need evidence for everything that touches the product.
- There’s a clause just about commissioning of new equipment, which is a whole new topic.
- And then, there’s a load of very specific requirements about equipment, which means you now need controls for moving equipment, out of use equipment, mobile equipment, and equipment that needs to be charged.
- And finally, you now need a performance review system which will monitor repairs and trend them, so that improvements can be made to the your planned preventive maintenance system where needed.
Product development
Although there’s no big changes to this topic, but there’s a lot of small changes. Here are just a few of the key ones:
- A procedure is now needed for product development.
- A procedure is needed for artwork approval.
- Specification reviews must now be recorded and there must be a log of amendments.
- All claims must be validated, which brings us on to the next big topic.
Authenticity claims
This is a small change which has huge implications.
There’s always been a clause in the standard that required the processing of products with claims to be validated. However, it was never really enforced. Probably because auditor’s interpretated the requirements to be about products which were approved by a separate certification scheme, such as organic. However, this clause (5.4.7) has now been updated and expanded. Nutritional validation requirements from clause 5.4.2 have been brought into the clause, and it’s been widened to include all claims. This means, that you must have a processing risk assessment and validation to prove all of your product claims. This takes the standard one step closer to customer codes of practice, as it’s moving towards an M&S integrity approach.
Therefore, you need to understand how the products that you make which have claims, could be impacted by cross contamination during the process, or if they could get mixed up by mistake. This is a very new subject and takes a little while to get your head around, so it’s not something I can explain quickly during this webinar. We do have a mini training for it thought, if this is something you’d like to do.
HACCP
There’s a couple of HACCP related changes which are:
- Information sources.
- Risk-based zones.
I’m a big fan of both of these changes, as I think they really help provide clarity. As techies we’ve always put a lot of time and energy into writing a scope, product description, the intended use and user and so on. But we don’t really use it for anything.
The site plans are the same. We spend ages drawing them and making them look like, but what are they used for?
That’s the theme of both of these changes, the information that we put into the front end of our HACCP (or product safety plan) should be used to extract the relevant hazards. The site plan, should be used to identify relevant hazards for cross contamination purposes.
For Issue 9 we also now need to have documented a risk assessment which details how we’ve defined the zones that we use on site. These zones are for example, low risk, high care, high risk or ambient high care. Issue 8 used to have a decision tree in it for working out your zones, but they’ve removed that and replaced it with explanations instead, probably because it didn’t make much sense. But removing it all together rather than fixing it, doesn’t help.
Waste
There’s a new clause for waste handling. This means that you now must risk assess how you’re going to store, segregate and move waste. This risk assessment needs to be documented and it must consider zones and the associated cross contamination risks.
Handheld equipment
Clause 4.9.6.2 in Issue 8 was just about pens. Now, this clause has been expanded to include all portable items. This means that you must identify what portable equipment is in use and then how you’re going to control it. Interestingly the interpretation of this clause says that the pens don’t have to be metal detectable unless you have detectors. Which is odd, as plasters have to be metal detectable even if you don’t have a detector.
Laboratory results
In Issue 8 the standard was updated to state that you must be able to understand laboratory results, so that you can interpret them and apply the necessary action. This time, for issue 9, the clause has been expanded to include measurement uncertainty and the interpretation has been expanded again to stress that results must be understood. This means that you now need to understand measurement uncertainty, as well as the results.
Laboratory standard testing
This is another big one. These clauses relate to both external testing and testing which is completed by your business internally. This isn’t just micro testing, but is any test which relates to product safety, legality or authenticity. So, this would mean, you’d need to apply it to allergen testing (think rapid swabs), weight for legal purposes or even species swabs for claims. You now need to apply laboratory standards to these tests, so that means that you must have robust procedures for them. The methods must be validated and you must have proficiency testing where it’s needed.
Process control
This isn’t a new requirement at all – but, it’s been updated so that means it’s going to receive a lot more attention at your next audit.
In 6.1.1 the clause has been expanded to state that a review of process specifications and associated documentation must be carried out before a change is made. This means that auditors are going to be asking for your last review, so you’re going to have to record the reviews, so that you have proof that they were done.
The interpretation to 6.1.2 has also been updated to stress the need for digital systems to be secure. As we move more into paperless systems, this becomes more and more important.
You need to think about where information is held in digital form and determine if it can be accessed by anyone who shouldn’t be able to get to it. Think about equipment settings, as well as records and documentation.
While you’re there, also think about digital signatures. It’s one point that seems to get missed. When you’re moving your paper-based checks, onto paperless systems, bear in mind they still need signing. This digital signature must be unique, so each person needs their own log in.
Printed packaging controls
Finally, the last important change is printed packaging controls. Again, the standard has taken one step closer to implementing customer codes of practice here.
You now need to be able to allocate and reconcile printed packaging. This means you must be able to count printed packaging, so that you can identify if unallocated packaging has been used by mistake. It’s not about being able to count it to the individual unit, but you must be able to establish if a mistake has been made. Your procedure needs to define how you’re going to do this and that an investigation will take place where a discrepancy is identified. Your auditor is now also going to check at least once changeover, so that they can make sure that you’re clearing down the line effectively.
And the last point is that packaging checks have now been expanded, to clarify when they must be completed – at the start, during the run at a set frequency, when a new batch of packaging is added and also at the end of the run.
That’s a lot of information to take in. We’ll send you a copy of this video, but let’s just summarise the key points and how we’ve tackled each one.
Senior management commitment
Setting the culture, the objectives and then putting a structure in place which ensures their success comes from the top down. 
So, your first task is to make sure that you have senior management working on the aspects that affect them. Remember, sites with a positive culture, will share compliance to the standard and this starts with senior management. You must get them on board, ensure that they understand culture, and how the changes in Issue 9 impact them.
This is why we’ve created a training course specifically for senior managers, called Issue 9 for senior managers. This course explains all the changes to Issue 9 within the senior management commitment section, including culture, so that each senior manager knows what they need to do for your next audit.
Supplier management and product defence
These two topics go hand in hand, as product defence should feed into supplier management.
You must train your product defence team and you need to take a really good look at how you monitor your suppliers.
Don’t forget if you use consultants or training providers you must now approve these too. We’ll be contacting all of our customers in November, to ensure that they’ve got everything they need from us, ready for their audit.
If you need help training your product defence team, please get in touch – we have a range of courses now, which are role based. This means you can train each member of your team, in exactly what they need to know, no more, no less. Providing role based training means that it cuts cost and the amount of time that it takes to train your team. And the really cool bit, is that each member of your team will know exactly what they’re responsible for, by the time they’ve completed the training – which ticks the culture box too.
On the culture subject, you need to ensure that you get procurement involved in supplier management and product defence too. They should be champions of this subject, as they’re accountable for suppliers.
That’s why we’ve created an issue 9 training course specifically for procurement, so we can help you to get the culture message across, so that they can help you with the implementation of this subject.
Maintenance
This topic is going to get a lot of attention at your next audit. So it’s the perfect time to train your engineering team on Issue 9. That way you can ensure that they understand what they’re accountable for (from a culture perspective) and they can lead the implementation of the changes in their area. Our training for this topic, is designed to ensure that your engineering lead will present this topic at your next audit, as they’ll understand that they’re accountable for it and responsible for it’s implementation.
Factory based changes
Your operational teams need to understand the changes that apply to them, which include:
- Portable handheld equipment.
- Waste handling.
- Laboratory standard testing.
- Process control.
- Printed packaging controls.
We’ve developed a training course, that specifically meets the needs of the operational teams. This course is five mini videos, so they learn what the changes are and why to do about them. That way you can leave your operational colleagues to get on with implementation of those changes, while you get on with the techie bits.
The techie bits!
That leaves you with the following topics to champion:
Product development – although if you have a development team, you could train them in this and then they could implement it themselves.
Authenticity claims – this needs careful thought and consideration. You need to establish what claims you have on site, which you should have done anyway for product defence and then work out if those claims are at risk. You’ll need to complete process risk assessment and identify what controls you need. Once you have the controls identified, you’ll then need to work with operations to implement them.
Laboratory results – if you’re not confident in reading results, now is the time to learn about this topic. You also need to understand measurement uncertainty, and you’ll need to speak to your lab to find out how they handle this for the results that they supply you with.
HACCP – and finally our favourite subject! The front end of your product safety plan needs a good review, as you need to think about whether you’ve used it to identify relevant hazards, that you’ve considered in your hazard assessment. You also need to document a risk-based zones assessment, and then use the site plan to consider hazards for your assessment.
Our Issue 9 for techies training, includes all the subjects that we’ve talked about today – it contains 30 units of training that you can pick from and complete in an order to suit you and at your own pace. We’ll also be launching all of this training individually too, so if you just want to do one or two units, you can do that as well.
BRCGS Food Safety Issue 9 for procurement webinar – 18th October 2022
This webinar is specifically designed for procurement team members and focuses on culture, supplier management and product defence in the upstream supply chain.
BRCGS Food Safety Issue 9 for engineers webinar – 25th October 2022
This webinar is specifically designed for members of the engineering team and focuses on culture, equipment and maintenance.
BRCGS Food Safety Issue 9 for operations webinar – 1st November 2022
This webinar is specifically designed for members of the operations team and focuses on culture, handheld equipment, lab standard testing, waste handling, process control and printed packaging controls.
Book a call with Kassy
Would you like to discuss training for Issue 9?
Then book a Teams call with Kassy – she can answer any questions you may have and help you to tailor a solution to suit your needs. Just fill in the form below and she’ll be in touch!
BRCGS Food Safety Issue 9 – live sessions: PLEASE NOTE THESE HAVE NOW ENDED
We’re running live sessions as part of our BRCGS Issue 9 training, on the following dates. The sessions will be monthly, until fortnightly is needed.
The themes will be updated based on the requirements of the group. If you’re booked on to our training and would like more information please email Kassy (kassy.marsh@techni-k.co.uk).
Dates and subjects for Issue 9 live
Thursday 20th October, 2pm – 3pm: complete
Thursday 17th November, 10am – 11am: culture surveys and data analysis.
Thursday 15th December, 2pm – 3pm: setting objectives, clause 1.1.3.
Thursday 12th January, 10am – 11am: converting your defined culture, into survey questions and an action plan.
Thursday 9th February, 2pm – 3pm: defining risk-based zones.
Thursday 9th March, 10am – 11am: supplier management.
Thursday 6th April, 2pm – 3pm: equipment (engineering).
Thursday 4th May, 10am – 11am: product defence.
BRCGS Food Safety Issue 9 audit – site feedback
Here we share what sites are finding when they complete their issue 9 audit, and their key learnings.
Please share you findings from your issue 9 audit, so that your fellow techies can benefit from your learnings. Remember, together we’re stronger!
Learning: Test the full incident management procedure (Jan)
The auditor stated that when trained for auditing against issue 9, they were expected to ask for evidence that both the recall/withdrawal procedure and the emergency situations procedure were tested annually. This came as a bit of a surprise as we had not tested the emergency situations procedure i.e. fire, flood etc.
Learning: Test the full incident management procedure (added 15/2/23)
- Supplier of services, greater focus placed on this, requested signed contracts etc. especially for IT systems and method of approval. The auditor went into great detail with contracts for the major retailers, wanted to see signed contracts that contained full product details, would not accept signed off specifications i.e. wanted to see the contract that included product being frozen and then sold on defrost, even though listed in specification and HACCP plan that had been signed off by retailer.
- The auditor had a printed copy of both the interpretation guidelines and the key changes, so was looking for the red text and concentrating on these changes.
- Also wanted to see completed examples of new equipment purchase specifications. Additional focus on portable equipment, ladders etc.
- I noticed when carrying out the gap analysis, using the issue 9 standard, that the interpretation guidelines have additional requirements that are not actually listed in the clause. You had covered off allergen training, as 7.1.4 only states staff trained in allergen awareness and trained on the sites allergen handling procedures but guidelines go further with regards to crisis management team etc. Another example is 4.3.1, site must assess production risk zones, a documented assessment is expected using the definitions from the standard.
Our 5 minors were as follows:
- 1.1.3 KPI’s for listeria swabs and finished product not included in minutes of last management meeting, (results reported weekly via email).
- Whistleblowing policy did not include the words “product safety, authenticity, or quality issues”, simply had generic terminology.
- Overdue hygiene audit for January (BRCGS audit was 06/02/23, so only by 1 week).
- A non-conformance report did not include additional product inspection and release, implied all product was disposed of.
- Modified atmosphere, CO2 gas checks, did not include all heads (products can use 2 – 4 heads), only one sample taken hourly from the line so potential to miss issues with the other heads.
Learning: Don’t forget the supporting systems (Added 6th March)
Advice from an auditor: Don’t forget the supporting systems. Operations are audited a lot and are used to it. However, the HR and NPD aren’t audited as often and they can be forgotten – check that your supporting departments know the changes (and have actually read them) and implemented the changes needed.
They also said not to forget that the whole product defence team now need to be trained, not just the technical representatives. This means you need a team approach for both your vulnerabilty assessment and your site product defence/ security threat assessment.
Learning: Reconciliation of printed film (Added 6th March)
Non-conformance from a recent audit: “Although the site are recording allocation of packing to the line and reconciliation of off line printed labels, the site were unable to demonstrate the recording of reconciliation of printed film within a timescale that prevents products being released from site.”
Learning: Chemical control (Added 25th April)
Two NCs from a BRCGS Issue 9 audit:
- “Chemical drums, were stored in Factory unsecure in a the chemical cradle.
- Flooring chemicals stored unsecure in Factory, left on a pallet by contractor.”
Learning: Commissioning new equipment (Added 3rd May)
We got caught on 4.4.11 with a single dirty strip curtain missed by the relevant team! We also got caught on 4.6.3 where we had not made a specific statement about commissioning new equipment in the FSQM. (the statement we had was not specific enough!)
Learning: Maintenance related issues (Added 19th May)
| Conformance no. | Clause | Detail |
| 1 | 4.6.5 | a) An obsolete fluid bed dryer was found stored at the main blending room covered by blue liner; however not completely and not sufficiently clean (it was dusty).
b)Obsolete stainless steel parts of equipment were found untidy stored on the floor at the mezzanine above the engineer workshop |
| 2 | 4.7.2 | A black sealant material, which was present at the internal surface of the left tablets’ exit of the saccharin tablets press during the production of the 3mm tablets batch L412 at 09.05.23 was found damaged (a piece of 2cm was found partly detached but not damaged/ deformed at the time of the observation); pre-start checks are performed and reported including the inspection of equipment for any foreign bodies/ damages and reported at every start-up and product/ shift change over |
| 3 | 4.9.6.3 | Use of clear cellotape was noticed a) at the garbage bin of the saccharin blending room, holding its label; the cellotape was also flaking, b) at the internal surface of the Perspex cover present at the top of the tablets dispensers’ feeding hopper of Line 4 (a small piece of 2 cm was hanging) |
| 4 | 4.11.2 | Non adequate cleaning was noticed since a) wall plaster pieces (3 dusty pieces of around 5cm diameter) were found been left at the left back side of the mezzanine’s floor corner (non-open product area); those were not cleaned after the recent wall drilling for extending the dust extraction network and b) dust (sweeteners’ powder mixed with air black dust) was found at the internal surface of the Perspex cover present at the top of the tablets dispensers’ feeding hopper of Line 4 (around a surface area of 10cm radius) |
The above NCs show how important it is to make sure that your engineering department knows the aspects of the standard that they’re responsible for. To train your engineering team on Issue 9 requirements, take a look at Issue 9 for Engineers.
Learning: Suppliers and recall (Added 11th Aug)
The 2 that we picked up as a result of the changes to the standard are as follows:
- There was no objective evidence to verify performance review/ records of all suppliers of services.
- There was no objective evidence to verify the site procedure for recall and withdrawal fully meets the requirements of clause 3.11.4 – we hadn’t amended to add the further reporting requirement within 21 days to the certification body!!
Learning: Include mobile floor cleaning (and other cleaning machines) in mobile equipment risk assessment
Would like to add our business NC following recent audit we had, in case someone will benefit from this learning:
Clause 4.6.6 Mobile equipment Risk Assessment do not detail mobile floor cleaning machines.
BRCGS common non conformances
BRCGS have published their annual report which includes information about what the most common non conformances are.
Use the link below to download the report and go to page 11 and 12 to view the details:
Hello,
I am looking for some assistance with clause 4.6.5.
Where it states the food contact equipment that has been stored but is not in daily use must be cleaned prior to use.
We do not operate on Sundays, so would this mean that all food contact equipment would need to be re-cleaned on a Monday morning before being used for production?
Thanks in advance
Lucy
Hi Lucy
You’d need to a risk assessment, which determines if it must be cleaned before use. If you were working in a high risk area it may need sanitising for example. But it would depend on the situation.
Kassy
Hi, the ‘get ready for issue 9’ that you sent out today 27/01/22 (very helpful and like that its in bite size chunks so can spread the load – ta!) states to check culture plan …. ‘2. Does the plan contain at least one action, which directly relates to compliance to the BRCGS standard,’ I have not been able to find a requirement for this in draft V9, am I missing something?
Hi Chris
This point seems to have raised some conversation – which is great. The more we talk about these aspects, the more clarity we get.
You’ve not missed a clause in the standard that says this, as such – it’s more about the intention of the clause. I’ll explain…
The purpose of the plan is to improve “food safety and quality culture”. If you think about why BRCGS want you to put culture in place, it’s to protect the product by ensuring that staff are compliant to the standard. This means your actions need to be able to relate back to the standard.
Let’s say that your culture survey identified that staff don’t feel that GMP in the factory is important and so you decide to improve the training in this area. You can relate the problem (GMP isn’t important) and the resolution (GMP training) back to complaince to the standard.
Many sites who have been doing staff surveys for a long time will have other actions on their plan, like making the work environment more appealing. This is a great action for the culture plan, but it’s not something you can relate back to compliance to the standard – as it relates to wellbeing not food safety.
I hope that helps.
Kassy
Do you know why the change from integrity to authenticity and what they are meaning by authenticity as it can mean a number of things?
The two terms are very similar, however integrity is wider than authenticity. It means to act ethically and honestly. Whereas authenticity is more focused on the product and meeting the claims on pack. In my view integrity is more behavioural, whereas authenticity is more physical (the product). I would think that when the term integrity was originally put into the standard is was done with the best intentions but without a great deal of thought. Now they’ve thought about it holistically and have clarified what they mean, so have opted for the term authenticity as the right one as it is more product focused.
We have also been told by our BRC auditor that a screenshot from the BRC directory is sufficient evidence of validity and that a copy of their certificate isn’t necessary as well.
The one good thing BRC ever did was the directory. You get a company’s up to date certification status direct from them. I wish other accreditation bodies had the same type of facility. Would make the life of us continually gathering evidence a bit easier!
There is a search facility on the FSSC22000 site so that validity of suppliers certificates can be validated.
Carrie, totally agree with you! Search is the best. Annoying that IFS website search sections still says it is in development (and has been for the last 6 months at least) whilst that is probably the second biggest food standard (certainly in Europe)…
Yes the search on FSSC22000 is great as is BRC although I have spotted a couple of errors against certificate and directory on expiry dates this last year.
Trust is good – checking up is better! I think there was an issue a few years ago with manufacturers fabricating certificates. I always refer to the BRC Directory, SALSA, ISO and FSSC
BRC controls always assume small companies and big companies have the same operating capabilities. So when something such as the unannounced audit scheme comes along, small companies will be severely impacted.
For example, one person responsible for all quality functions may likely be away – despite given a window of opportunity. It seems like a shift to ‘catching you out’ mentality is coming, and we will sadly see some casualties along the way of good processors who were simply not able to be staffed enough to cope with this.
I agree Ian. The audit is stressful enough regardless of how confident you are on your processes and people, so an attitude from the auditor of trying to find errors rather than establishing the strengths is having good technical people step down or even leave the industry; and just at a time when food safety is becoming more and more critical.
The standard already details that those in key roles must have a depute – that depute would be responsible during an unannounced audit if the primary role holder was not available. I appreciate that this makes thing complicated – we have a similar scenario where our deputes are confident and capable but are rarely involved in the actual 3rd party audits because they are deputising for the manager while they are with the auditor.
There is also the option to block key dates out – with valid reasons e.g. key team members have training courses.
Initially I felt like the unannounced scheme was a way to ‘catch us out’ but we are now a position where we have had more unannounced audits than announced and it has brought huge benefits to the business because standards are consistently high & our food safety culture is positive and all team members have bought into what the SMT are aiming to achieve.
I feel from your comment that ‘small company’ may not apply in your case.
When you are a department of 1 maybe 2 – these controls can be very unhelpful. The point I was trying to make is that the standard has no protocols for factoring in multi-sized companies.
Carol above, seems to have summarised it well. I know of three people leaving the industry just this year due to the inability to work with rigid tunnel-vision guidelines.
I couldn’t agree more Ian. I am the Technical Team at work, and also a carer for an elderly parent. With the work that operations do, there isn’t much at work that I do that won’t wait a day or two EXCEPT an unannounced audit. With the NHS under stress, mother’s hospital appointments and doctor’s appointments I dread unannounced audits. It isn’t control freakery, it is just doing the best for the company.
Strangely similar to my own situation.
We’re getting closer to the draft being released, any clues on whether we will be able to see the draft or how we can (legally) get hold of a copy? Do you think it will be available for comment?
Hi Julie,
So it should be published end Dec/Jan time. On the subject of being able to ‘legally’ get a copy – that’s a good question. The previous draft for Agents and Brokers was placed on the BRCGS website for comment, so hopefully they’ll do that again.
Kassy
LAB APPROVAL! This is definitely an area which needs improvement. We have had a non conformance several times now where our lab is UKAS accredited and has subcontracted work. We have received non conformances because we don’t have the details of the subcontracted lab and haven’t approved them however, subcontracting is covered by our labs UKAS accreditation therefore the subcontracted lab has gone through the correct approval procedure and have measures in place or else our lab would not have the UKAS accreditation. We have even had the subcontracted UKAS accredited labs accreditation to hand during the audit and still received a non conformance because the auditor was looking for the wrong test in the UKAS schedule, we also had a risk assessment in place which covered subcontracting by our approved lab.
It is almost as if BRCGS are not familiar with the UKAS standards which is ridiculous as the standards state that the lab must be UKAS accredited.
I agree Nikki. I’ve seen a site get an NC because they hadn’t verified the external UKAS labs results. And I’ve seen sites sending duplicate samples out to labs, so they can verify the lab results – which is just a waste of money. The NC was given against the clause for in-house lab results, where ring testing is needed. It’s subject that needs attention, not necessarily from the site or standards site, but definitely from auditor understanding. Lab controls are a huge subject and it’s a lot to expect auditors to be able to audit it effectively, without any specific training.
I’d be raising a complaint with my audit body if that was my audit. It’s clear there that in this instance that either the auditor doesn’t know what they are looking at, or the audit body is not managing the auditors correctly.
A non-existent NC is not something to accept idly.
I’m capable of getting my own NCs. I genuinely don’t need the help of an auditor’s incompetence.
They should add cctv footage record to assess GMP adherence for last week or any other day.
They should add contactless or less human handle processes during the Global pandemic
They should have add staff high care seggregation in pandamic make a clause on it
4.9.1.1- Caused a NC because the Non-food grade lubricants did not have proof they were suitable to be used in a food processing environment. Does anyone know where to buy non-food grade lubricants that are suitable to be used in a food processing environment? Thanks!
Hi Ivar, I’m not sure I understand. Do you mean you want to buy food grade lubricants? There are a number of large suppliers of these, although I can’t think of their names at the moment! Maybe other techies can help me?
Rocol and Ambersil supply food grade lubricants used in the food industry
they detail this on the technical data sheet also they provide an allergen and GMO statement to.
make sure you have the following from them for audit they supply them all.
Health & Safety Data Sheets
Technical Data sheets
allergens and GMO declaration
Thank you Natasha! Rocol was the one I was thinking of – but couldn’t put my finger on the name… 🙂
I found Activate Lubricants great. Furthermore Hall, Little BardfieldBraintree, Essex CM7 4TX
Hi, do you know if the mandatory ‘1 in 3’ unannounced audit when on an announced schedule comes into effect with this version change? And has anybody had any experience in opting a site out of this due to lack of presence on a smaller sister site when working on a main site which is already unannounced?! Thanks
Hi Josh
This should help https://techni-k.co.uk/how-your-brcgs-1-in-4-unannounced-audit-is-going-to-work/
Thanks
Kassy
I would like some clarification around the calibration requirements of Metal Detectors and X-ray machines. These are frequently critical control points and v8 requires the identification of measuring equipment used to monitor CCP’s, a documented list of it and an identification code and calibration due date for each piece of equipment. I fully agree that this is important for temperature measurement and weighing machines and other similar devices, but this clause has come to mean that every auditor also looks for an annual calibration certificate for Metal Detectors and X-Ray machines. These machines are fully adjustable, because different products require different settings, so the operator is perfectly capable of altering the sensitivity so that it rejects anything from; everything including all good product, to nothing at all! This is controlled by having a series of calibrated test pieces that are passed through the machine regularly (typically every 2-3 hours) and ensuring that they are rejected, the operator makes adjustments until he achieves this without wasting excessive quantities of good material, and it is the success of this test that is the assurance that the machine is doing the correct job and the fact that an engineer wrote out a test certificate six months ago has absolutely nothing to do with it! In reality the tests that are done by an engineer at an annual calibration are no different, they simply pass test pieces through and ensure that it functions properly. One argument is that the machines themselves are not calibrated equipment, only the test pieces are, but I have yet to find an auditor who accepts this point of view. We are a technical community and all clauses should have a sound scientific and practical background, what is written in v8 may be relevant for say temperature control, but it is not relevant for all equipment used as a CCP.
Version 8 states that “The Standard does not require routine calibration of metal detectors beyond the verification/checking activities described in this section. However, planned maintenance or servicing may have value depending on the machine, the manufacturer’s specification, the contract and/or the operating environment”. This means that you do not need your metal detector calibrating BUT we have our metal detectors serviced annually and the engineer leaves a report about that service. He tests the machine using certified test pieces which he references in his report also. This has sufficed me at several audits since the introduction in version 7. In my mind the certified test piece is the “calibrated” equipment.
I am unable to comment on X-ray as we don’t use it but with regards to metal detection we need to have a range of settings to accommodate different product types and different product wraps.
We have never allowed our operators to alter sensitivity, this has always been pre-set by technical and engineering and we have a number of different programs pre-saved that the operators select & this information is communicated to them via packing specifications for setting up their lines.
For testing of these programs the majority of own label retailer standards advise that metal detection systems must be tested at a minimum of hourly.
If the different programs are all pre-set and locked to prevent alteration then the service engineer can ‘calibrate’ the settings using your published test piece sizes to validate that metal detector meets the standard that you have pre-set it for.
I have to agree with CMcG on this.
Your operators should not be altering levels of sensitivity. You should have pre-set programmes for each product type in order to ensure that you are detecting the smallest possible contaminant for each product type.
This should ideally be determined in conjunction with your equipment provider, and then on an annual basis they service and check the machines and ensure that the systems work as set up including the set programs.
Having your operatives altering sensitivity is bordering on crazy IMHO.
Thanks for sharing and giving us the opportunity to share our thoughts. I’ve had a couple occurrences on several sections where I question….what is the clause actually asking us. Here are the points of reference, I really hope some of these are looked into and clarity is provided.
1. Test of Traceability System(3.9.3) – Within this requirement, it states that the traceability test shall be completed across the range of product groups but then in the interpretation section, it states where the traceability for all products is manufactured using the same or similar then a minimum of one test a year is completed. Our manufacturing site produces 7 product categories but traceability for each category follows the same process and lot code, am I required to complete 7 traceability tests or 1 test?
2. 4.7.5- Allergen Declaration for food grade chemicals – I know when I completed my third party auditor training our Instructor had indicated that the allergen declaration would show up within the revised version of the SDS but I’m still not seeing this so how would the industry comply with this. I don’t know if I agree with just asking the Supplier the question and in return they just answer yes/no because anyone can acknowledge a yes on paperwork without supporting evidence and I’m not sure if it’s realistic to have to contact each manufacturer, that’s a job in itself. 🙂
3. For ingredient/packaging approvals/renewal of 3rd party audit certificates – if we’re required to verify the validity of a Supplier’s 3rd party audit document, the validity step should be sufficient enough to adhere to this requirement. It’s overly redundant to have to also maintain an actual copy of the 3rd party certificate in our files.
4. Definition of food contact packaging to be revisited. I’ve been part of multiple discussions about, is this part of the package considered FC with mixed answers. Example: I’ve got a plastic tub which is sealed with film then a lid placed over the film. I’m told by a few people that the lid is considered FCP and others that it’s not.
I apologize for the long winded response. 🙂 I know their just small items but there is definitely inconsistencies within the industry that I hope they do look at providing clarity.
I may have more to add over the next few days. 🙂
Donna, for your suggestion no3, I believe just verifying is actually enough already. We have had several auditors tell us that we don’t have to go through obtaining current certificates every year as long as it has been verified on the BRC directory. I just screenshot the directory as evidence it has been verified. We have several suppliers who are a pain to get information out of and this has been accepted by all our auditors for the last 3 years since I started doing it.
Hi Donna
In relation to point 1: do they share the same HACCP plan? If so, then one should suffice. If not, then one per HACCP plan would be more suitable in my experience.
In relation to point 2: there is NSF certification for food contact chemicals, and this certification confirms it’s safety, including allergens. As a rule, we aim to always use NSF certified food contact chemicals.
In relation to point 3: this is relative. You can simply include a print off from the BRCGS directory rather than the certificate itself, especially if the cert is within the 3-year review. When completing a full intitial or 3-year review then the actual cert and NC report would be needed. If you’re fully digital, include a weblink to the relevant BRCGS directory page.
In relation to point 4: food contact is food contact. A simple risk assessment for your various components would alleviate any confusion. A simple document highlighting how you have determined that each component is or is not food contact. Have that in your packaging folder with the spec, and then you can demonstrate to the auditor that you have determined what is fc and what isn’t.
4.9.11? Is this supposed to be 4.9.1.1?
Quite right Zoe, thank you 🙂 All amended.
Hi Kassy,
many thanks for this, as always very informative and up-to date information in one place!
We’re an ice cream manufacturer and it would be great to know what the updates regarding zones will be? Could you please let us know or where to look for the information?
Thanks!
As soon as we know – we’ll let you know Anna. I know there have been lots of discussions about it!
What on earth is “Covid chicken”? Is this a reference to the high instance of Covid in chicken processing plants or something else unrelated. I understand the other new emerging points but not this one, which is concerning as I work in a poultry processing plant.
This refers to the fact that slaughter facilities were not able to remain open due to sickness and isolating staff with regard to Covid. This, along with restaurants, etc being closed meant that poultry (and other animals) were not 1. able to be sold and 2. were then being killed at “farm” premises and could not enter the food chain.
Awesome Audrey – thank you so much for clearing that up and sharing! 🙂
Hello and thank you Audrey, the issue with Covid chicken then is ensuring that it doesn’t enter the food chain through being resold, used outside date coding or unlicensed killing making it unfit. It all makes sense now. Thank you!
I find supplier approval to be one of the most tricky parts of the standard and we have lots of situations that crop up that are not covered in the standard and we therefore don’t know if we are handling them correctly. Supplier relationships can be very complicated and I don’t feel there is adequate guidance on how to handle certain situations, we do our best but it would be helpful to have clarification in issue 9.
For example:
– When you buy from a legal trading name (with no GFSI under that name) that is different to the name of the site (with GFSI under their name). They’re not an agent or broker, as its the same site, same people, simply a different legal name on the invoices (i.e. all to do with moving money around their business). We approve the GFSI site but the invoices have the legal name on, hasn’t come up yet but I wonder if it does, if it would be an issue. I’ve met others with confusion over this too.
Another situation we’ve had is where a manufacturer outsources all their communication if you like, so we order and speak with company A but the product is made, stored, dispatched by company B. Company A insist they are not an Agent or Broker, they have no rights over the product, they don’t exchange money for it, they don’t manage any traceability of the shipment etc, its simply a business relationship to deal with communications. Totally confusing…..
– What action to take if the product you’re buying is not within the GFSI scope. We treat as if they’re non- GFSI and ask them to complete the full SAQ etc, but this seems a bit OTT when we know they have pest control etc from their GSFI certification and suppliers get ratty about having to fill it all out. It would just give a bit of weight to our requests for them to complete the full SAQ if the standard stated that the expectation is to treat them as non-GFSI, or if there’s something else that can be done, then what that is.
On another note, if they don’t already, then all GFSI standards need to make it clear that it is an expectation to disclose the manufacturer of a product if you are an agent or broker. This still continues to be an issue at times and again I hear this a lot from others and lets be honest none of us have the time to send 12 begging emails and 8 voicemails to try and get this information. Or, alternatively if someone has A&B then make that enough so they don’t need to declare the manufacturers name….after all if they’ve gone to the trouble and expense of getting certification they have done the work to assure you as the customer.
Hi Technie12.
In relation to the legal name and trading name being different, I make reference to this on the supplier folders so that this is clear at the point of audit.
For example, an ingredient sold by Super Ingredients, but the parent company or legal name is Super Supplies, then the folder would make reference to this on the title (Super Ingredients c/o Super Supplies, or, Super Supplies t/a Super Ingredients).
From my experience, being clear at the start avoids the problems associated with confusion part-way through the inspection of that piece.
In relation to approving suppliers outside of the GFSI scope, you can review your SAQ and permit evidence to be provided to negate some sections of the SAQ – pest control as an example. If they provide you with evidence of their pest control, such as a schedule, then that should suffice. You could consider this as a form of Desktop/Remote Audit to which approval can be granted.
Also, ensure you’re using Risk Assessment as a way of deciding what actions are taken and why.
Thank you Gareth, appreciate your insight.