BRCGS Food Safety Issue 9 draft is here!

Here’s the key points about what’s going to happen and when…

PLEASE NOTE: Our training is not approved by BRCGS. If it was, we’d have to work to their curriculm – which we don’t want to do, as we want the training to be 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/

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!

Name(Required)

BRCGS Food Safety Issue 9 Training Bundle (unofficial)

Your proactive action plan for Issue 9

get Issue 9 ready!There’s going to be a LOT to do when Issue 9 is published, so we want you to get ready! If you’re signed up to Smart Knowledge we’ll send you a proactive action every Thursday to complete. Each action is designed to ensure that you’ve fully embedded Issue 8 and prepare you for Issue 9.

Here’s what you’ve achieved so far – January to March

Proactive action 1
You looked at what your business’ management culture was like, by completing a quiz. The results of this quiz showed that 40% of businesses had a good management culture – where compliance to BRCGS was seen to be a team effort.

Proactive action 2
You carried out a spot check your culture plan, to make sure it was up to date and that actions were being completed as they should.

Proactive action 3
Following the culture theme, from proactive action 2 – you then thought about how you relay the culture message to staff on site.

Proactive action 4
As staff training is going to be a focus of Issue 9, you checked your training programmes to ensure that they were compliant to Issue 8, which included allergen awareness, right product, right pack and product defence.

Proactive action 5
Non-compliant training record forms are a common problem, so you checked your forms to make sure that the right information was being recorded.

Proactive action 6
Whistleblowing was introduced for the first time in Issue 8, so for this action you checked that your system was compliant.

Proactive action 7
In this action, you checked that culture was on your management review agenda.

Proactive action 8
Issue 9 draft now clarifies the need for corrective actions from GMP inspections to be managed in the same way that system audit corrective actions are – so you checked that you already had this in place.

Proactive action 9
An improvement to internal audit requirements in Issue 8 was recording of evidence, so you did a spot check of your audits to make sure that this was happening.

Proactive action 10
Where your business fails to meet its objectives, Issue 8 stated that root cause analysis must be applied. So for this task, you checked if that had happened at last years management review.

Proactive action 11
Following the root cause analysis theme from proactive action 10, you then checked that your procedure provided a method of root cause analysis and that you had trained those who would perform it – to the procedure.

The plan for the next quarter (April to June)

Over the next 3 months, we’ll be sending out proactive actions every Thursday. If you’re not signed up to receive them – it’s free, just make sure you select ‘Food’ when telling us which standard you work to. We’ll be covering subjects, such as:

  • Product defence.
  • Vulnerability assessments.
  • Digital documents.
  • Cyber security.
  • Internal auditing.
  • Incident procedure.
issue 9 bundle offer

Your improvement calendar

Senior management commitment

Mini trainings:

Super course: 

Basic food hygiene for Issue 9

Spotlight on:

Corrective action, root cause and preventive action

Mini trainings:

Super course:

Non-conformance management

audIT.app:

Product defence (VACCP and TACCP)

Mini trainings:

Super course:

GMP inspections

Mini training:

  • Managing the internal audit programme.
  • Completing a GMP inspection.

Super course:

  • Managing internal audits programme and the corrective and preventive action system.
  • GMP inspections for inspectors.

Internal auditing

Mini trainings:

  • Completing a sytem audit.

Super course:

  • System audits for internal auditors.
  • System audits and GMP inspections for internal auditors.

Supplier management

Mini trainings:

  • Material risk assessment.
  • Supplier risk assessment.
  • Supplier approval.
  • Using approved and unapproved suppliers.
  • Supplier monitoring.

Super course:

  • Supplier management.

Maintenance

Mini trainings:

  • Equipment design and commissioning.
  • Good maintenance practices.
  • Managing the maintenance programme.
  • Change control.

Super course:

  • Maintenance.

High-care and high-risk

Mini trainings:

  • Ambient high-care facilities.
  • High-care facilities.
  • High-risk facilities.

Super course:

  • Risk-based facilities.

Level 2 Food Safety for Issue 9

Spotlight on:

Food safety and HACCP

Mini trainings:

  • Product safety commitment.
  • Product safety preparation.
  • Hazard analysis.
  • Product safety controls.
  • Physical controls.
  • Microbial controls.
  • Subcontracted controls.
  • Validation.
  • Monitoring product safety controls.
  • Maintenance of the product safety plan.

Super courses:

  • HACCP.
  • PCQI.

Issue 9 draft – summary

We’ve taken a look at the BRCGS Food Safety Issue 9 Draft and here’s our thoughts.

Section 1 – Senior management commitment

Overall, in this section, there’s a huge push on culture.

The commitment (quality) policy now needs to include the management’s commitment to improvement in culture.

‘Authenticity’ has been added throughout and ‘integrity’ has been removed where it was present.

Culture has been updated to include the need for the right behaviours to be defined. The requirements for the action plan have been moved, from the interpretation into the clause itself. The culture plan also needs to be reviewed at least annually.

The management review must include review of the culture plan.

During the BRCGS management must be available to discuss the culture plan with the auditor.

A statement has been added which says that staff should be able to request a training assessment. This must be where new requirements are introduced, as it would seem odd for an operator to request this. Hopefully, this will be more clearly worded, and the interpretation will provide more clarity.

Section 2 – The food safety plan

The information sources have been expanded to include previous food safety plans, site maps for flows and food safety areas and also water schematics.

The flow diagram needs to be updated annually and whenever there are changes.

Staff checking CCP records need to be trained.

A new clause for validation has been added, which will bring added focus to how the whole plan is validated including the product safety points (CCPs etc).

Section – 3 Management system

The requirements for what needs to be audited have been expanded, to clarify that it must include the culture plan and the overall management system.

A corrective action system must be applied to GMP inspection non-conformances.

The results from the non-conformance system and GMP inspections must be reviewed during the management reviews.

The requirements for auditing and SAQs for suppliers (materials, outsourced and traded products) have been expanded to include assessment of product security, defence and vulnerability.

Consultants have been added back in again as a service supplier that must be approved and monitored.

A procedure for the ongoing monitoring of supplier’s performance is required.

The definition of an outsourced supplier has been clarified. HACCP plans and specifications must be in place for outsourced suppliers and materials.

The corrective and preventive action section has been rewritten – it now seems to imply that preventive actions are required for all non-conformances. Which can’t be right…

The procedure for managing non-conforming product now needs to include returns.

Traceability must comply with local law (probably due to FSMA).

The list of examples of incidents now includes when product is contaminated and is therefore unsafe or illegal.

Testing of the incident system has been clarified to ensure that it checks that the full incident procedure, not just recall and withdrawal.

Records from incidents must provide sufficient detail to allow the certification body to evaluate the issue following a recall.

Section 4 – site standards

There’s a new clause specifically about managing visitors and contractors.

The product defence team must now be trained.

The defence plan must comply with local law (probably due to FSMA).

There’s a new clause for ensuring that you comply with the food safety areas on site (high-risk etc).

The food safety areas must also be on the site map, including areas used for time segregation for food safety.

Mezzanine floors now need to be controlled as elevated walkways do and it’s been clarified that the clause is specific to where there’s open product underneath.

Plastic strip curtains must be maintained.

Stored water must be controlled and water schematics must include the water source.

The equipment section has been rewritten, expanded and improved.

The maintenance system must cover mobile equipment.

Catering must consider the risk of allergies in staff.

The chemical procedure must include the management of spills and the disposal and return of chemical containers.

Food contact wood (where it can’t be avoided) must be controlled to ensure it’s fit for purpose.

The clause about pens has been expanded and a new clause has been added to allow non-conformances to be assigned where control of a foreign body has been missed, which isn’t included specifically in the standard.

There’s a new clause for control of X-ray equipment.

The clauses for magnets and optical sorting equipment has been clarified, to say that it only applies to finished product testing.

A new clause has been added to state that all foreign body removal equipment must be controlled.

Waste in open product areas must be controlled to prevent contamination.

Staff sales and charity product must be traceable.

The clause that states that storage and distribution contractors must follow the same rules has been rewritten.

Section 5 – product control

A product development procedure is now required.

A procedure for artwork approval is needed.

The vulnerability assessment team must be trained.

The vulnerability assessment has to be kept up-to-date, so must be reviewed wherever there is a change.

Where a claim is made, the production process has to be validated to prove that the claim isn’t compromised.

The product inspection and laboratory section has been updated, to ensure that:

  • The procedure includes sampling methods.
  • Understanding the significance of all results.
  • That limits must meet legal requirements.
  • Limits must take into account the uncertainty of measuring equipment.
  • Procedures for laboratory testing are required.
  • Laboratory materials must be controlled.
  • Line side testing is controlled.
  • Proficiency testing must meet ISO 17025 standards.

The pet food requirements have been expanded to cover animal feed and that in both cases, controls must comply with local law.

A new section for primary animal conversion has been added.

Section 6 – process control

Storage conditions have been added to the list of process control requirements.

Change control must be applied to process specifications etc.

Traceability of by-products must be in place.

Printed packaging reconciliation is now required.

A procedure for handling rejected packs for quantity control is needed.

Section 7 – personnel

No significant changes.

Section 8 – risk-based facilities

The site map must identify the process control steps that manage pathogens.

Where time segregation is in place for high-care, there must be a procedure to manage the changeover from low-risk.

Where structures can be removed to provide equipment access, there’s a new clause for the control of these.

Equipment must be fit for purpose, maintained and clean.

CIP systems must be segregated from product areas.

Section 9 – traded products

There’s a new clause to ensure that traded products are covered by a product safety plan.

Issue 9 training

It’s fair to say that our Issue 8 training courses went down a storm!  Everyone who attended, loved how practical the training was and used the lesson guide while implementing what they’d learnt.

This time around, we’ve made it even better – here’s 5 improvements that we’ve made!

Improvement 1

The course last time was 1-day, classroom based or eLearning. All the other training providers were doing the course in a day and so we had to do the same to make our prices comparible. This meant that the day was very rushed, as we were teaching the why and the how – which other trainers weren’t providing. However, those that completed the course in eLearning format could complete it at their own pace – so content of the course could be absorbed much better.

This time, we’re only providing the training in eLearning format. This means we can provide you with the right level of detail and the best learning experience – because you can complete it, at your own pace and a time that suits you.

Improvement 2

Although the benefits of eLearning are vast, there is one flaw – that you can’t ask the trainer questions and you miss out on the discussion and networking that you get when you attend an open course. Well, we’ve tackled both of these problems! We have live chat available on our website and this allows you to talk to Kassy directly. Kassy will also be hosting fortnightly Q&A and discussion sessions, which are open to everyone who purchases one of our Issue 9 courses.

Improvement 3

When we carried out in-house courses we found that some delegates only needed to attend certain parts of the course that were relevant to them. This caused some distruption to the other delegates and it also meant that we couldn’t check their learning, as the test included a competency check for the whole course.

Because we’re providing all of the training in eLearning format, we can now tailor the course for each person. This means that an engineer for example, can have a course that provides them with what they need to know about the changes to the facilites, equipment and maintenance section. This also allows us to test their learning, because we can also provide a tailored competency test for each learner. If you’re not confident in your team to self-study, or if they’re not confident with learning online, then we can schedule their learning – so the Techni-K team can supervise your learners over Teams. 

Improvement 4

We’re all about making implementation of Issue 9 as pain-free as possible. One way we can help you do this, is to provide you with the documentation you need. When Issue 9 is published we’ll be updating all of our documents to make sure that they comply. If you choose our Issue 9 bundle – we’ll provide you with a copy of each piece of documentation that we update for Issue 9. That way, you can either implement what we provide, or take out of it what you need and put it into your own systems. Even BRCGS think our documentation is pretty good, so we’re confident you’ll love it too.

Improvement 5

The gap analysis document that we provided for Issue 8 was really popular! This time, we’ve got audIT.app -so rather than do it on paper again we’re going to automate it. If you go for our Issue 9 bundle you’ll get 3 months access to ‘Plan 2’ of audIT.app – so that you can complete the gap analyiss and then use the system to create and complete an action plan. You can view the audit.app plans here.

BRCGS Food Issue 9 bundlePrice £2,400 (plus vat)

Please note, when Issue 9 is published, we will add more training to this bundle and therefore the price will increase. So, the sooner you place your order, the better!

More details.

Log in details for the eLearning will be issued 1st October 2022.

BRCGS Food Issue 9 trainingPrice £300 (plus vat)

Please note, when Issue 9 is published, we will add more training to this eLearning and therefore the price will increase. So, the sooner you place your order, the better!

More details.

Log in details for the eLearning will be issued 1st October 2022.

Issue 9 – site bundle

The complete solution for a team approach to Issue 9, includes:

  • Technical lead eLearning.
  • 60 credits to spend on tailored training for your team, e.g. engineering.
  • Training for approx. 12 team members, depending on your requirements.
  • Issue 9 documentation.
  • 3 months access to audIT.app plan 2 – so you can complete the Issue 9 gap analysis, create an action plan and use the automated system to assist you in its completion.
  • Invitation to the fortnightly Q&A and discussion sessions with Kassy.

Issue 9 – single training

This is the perfect solution for training one or two people. This training is designed for technical leads, so it includes all the training for Issue 9, including:

  • Culture.
  • Product defence (including fraud).
  • Maintenance.

Each topic will be provided separately so that you can choose which order you do them in, or you can opt not to complete those which don’t apply to you (high-risk for example).

A lesson guide will be provided for each topic, so you can use this to help you implement the changes.

BRCGS Food Safety Issue 9 Training Bundle (unofficial)

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!

Name(Required)

Have your say…

45 thoughts on “BRCGS Food Safety Issue 9

  1. 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.

    1. 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.

  2. 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.

    1. 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.

        1. 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!

  3. 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!

    1. As soon as we know – we’ll let you know Anna. I know there have been lots of discussions about it!

  4. 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. 🙂

    1. 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.

    2. 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.

  5. 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.

    1. 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.

    2. 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.

    3. 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.

  6. 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

  7. 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!

    1. 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?

      1. 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

        1. Thank you Natasha! Rocol was the one I was thinking of – but couldn’t put my finger on the name… 🙂

  8. 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

  9. 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.

    1. 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.

    2. 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.

  10. 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?

    1. 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

  11. 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.

    1. 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.

    2. 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.

      1. 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.

    3. 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.

  12. 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!

    1. 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)…

    2. 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.

  13. 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?

    1. 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.

  14. 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?

    1. 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

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