Comparison of IFS and BRCGS clauses.
Before we head into the detail, we thought you might like to see what the results were of the previous poll.
I want to move to FSSC22000 18%
I want to move to IFS 37%
I want to stick with BRCGS 46%
IFS are leading the way, so we will compare IFS and BRCGS first.
In order to do this piece of work, it made sense to add IFS and then, FSSC22000 to the documents that we are currently working on to compare and combine BRCGS.
You may have read one of our previous articles where we introduced this idea; How I fell down a BRCGS rabbit hole.
To summarise quickly, we are putting together one Standard, that brings together all of the four BRCGS Standards that we work on; BRCGS Food Safety, BRCGS Packaging, BRCGS Agents & Brokers and BRCGS Storage & Distribution.
There are a number of reasons for this:
1. To get ahead of the game
Every year one Standard is updated and so we are forever in an endless cycle of updating one of the four packs that we provide. Typically, updating each pack individually, with the same things as the updates are the same or similar. By updating them all when new updates appear in any of the Standards (which will mostly be driven by food) we are ahead of the game.
2. To make it simple
Sometimes one Standard will get updated and the update will be forgotten in another (whistleblowing in the BRCGS Packaging Standard is a great example of this). Or there will be things in the Standard that don’t make sense. By us assessing the changes and implementing just what’s needed, it means that sites don’t have to work through the confusion, as we’ve done it for you.
3. So it makes sense
When you compare the Standards – there are things in one Standard, that really should be in them all, but they’re not. Artwork control is a great example; BRCGS Packaging has this, but it’s not mentioned in food – where it would be of great use. Control of glass containers (like jars) is another good example, which is included in the BRCGS Food, but not in packaging. So you don’t have to make sure you handle glass breakages, if you’re making glass jars. But you do, if you’re filling into them. By combining them, we’re taking the learnings from one and applying good practice to the others where it’s relevant.
4. To translate and standardise
We like to think we can write things, in a simple to understand way. So, by taking all the Standards and combining them, we can then translate them into a Standard which makes sense and is easy to understand. We will use a consistent language (which BRC don’t) and provide a glossary, so that we’re all speaking the same language.
Because all the BRCGS Standards are laid out slightly differently, we had to come up with our own filing and numbering system. We’ve grouped the topics into 18 categories that make sense to us, so hopefully they’ll make sense to you. They are:
- Senior Management Commitment
- Document management
- Continuous improvement
- Hazard analysis
- Contamination control
- Product development
- Supplier management
- Product defence
- Site Standards
- Microbiologically controlled facilities
- Process control
- Storage & distribution
We have a huge spreadsheet for each of these topics, which holds all the clauses (and the interpretation as BRC put requirements in those too now).
So, it made sense to add IFS and then all the FSSC documents to these spreadsheets – as it will act as a type of gap analysis against BRCGS.
We can then highlight the differences to you. So, please bear in mind as we go through this gap analysis, we’ll be doing it based on the 18 topics above.
Comparison of IFS Food and BRCGS Food Safety
First, we’ll compare IFS Food and BRCG Food Safety. We’ll then do the same for IFS PACSecure, IFS Logistics and IFS Brokers in the next articles.
To make it easy to read, we’ve divided it into three main headers:
- What’s new
- What’s different
- What’s not included
Please bear in mind, for ‘Topics not included’ we’ve only highlighted the big changes. There are too many tiny details that are not included in IFS, so it’s not possible to include them all. And, if you’re moving from BRCGS to IFS it means you’re over compliant, so it’s not worth worrying about at this stage.
Customer expectations require:
- A procedure
- Control of contract amendments
- Implemented GMO requirements
Amendments must be carried out by authorised personnel.
|1. Senior Management Commitment|
|What’s new||What’s different||Topics not included|
|Senior management need to ensure that the QMS is reviewed annually, and whenever there is a change. And, this must be data driven based on verification measures.
There must be review each year to create an investment plan for infrastructure and the working environment.
There must be an IFS representative.
The technical team must have a direct reporting line into senior management.
There must be a procedure for external inspections and regulatory visits.
Job descriptions are needed.
|Topics for the policy include environmental responsibility and sustainability.||Culture
|2. Document management|
|3. Continuous improvement|
|The term ‘corrective action’ seems to be used when referring to both corrective and preventive actions. However, the term preventive measures is also used, which is confusing.
There is no definition for preventive measures, but the definitions provided are:
Correction: Action to eliminate a detected non-conformity or deviation.
Corrective action: Action to eliminate the cause of a detected non-conformity, deviation or other undesirable situation.
|Root cause is not mentioned.|
|Customers need to be notified in the event of serious incidents.|
|5. Hazard analysis|
|CPs are required – which is the IFS version of an OPRP (or PC if you’re in or exporting to the USA).||The HACCP team must have strong senior management support and be well known by staff.||There’s no set requirements for low risk, high risk, high care etc. it’s based on the sites risk assessment.|
|6. Contamination control|
|As well as allergen free from, where other claims mean elimination of certain materials, such as GMO free, vegetarian, or halal are listed, there must be suitable controls in place to prevent cross contamination.
Controls for recycled water.
Controls for non-potable water.
|Full allergen risk assessment and controls is only required where products are listed as not containing such allergens. May contain labelling is acceptable.||Strongly scented chemicals.
Controls are based on risk, so there are no specific requirements for sharps, pens, debagging or deboxing, metal detection, filters or sieves, glass containers etc.
|7. Product development|
|Hazard analysis principles must be used to manage product development.
Control of GMO.
|8. Supplier management|
|There is no prescriptive method for approval of suppliers.|
|Library samples to be kept where required by the customer.
Taste panels are required.
Calibrated equipment should only be used for it’s intended purpose (e.g. don’t use a probe for opening things)
|Nutritional verification.||Environmental monitoring; this would only be applied where identified by the risk assessment.|
Equipment failure should prompt a PPM review.
|11. Product defence|
|Vulnerability assessment includes packaging.
Product defence team with responsibilities is required.
Product security should be included in visitor, contractor and driver procedures.
|Personal hygiene, PPE etc. rules are applied based on risk.|
|14. Site Standards|
|Ventilation, air conditioning and dust extraction systems must be maintained.|
|15. Microbiologically controlled facilities|
|Controls applied are determined by risk assessment. They are not stipulated.|
|Retraining frequency for cleaning personnel.
Cleaning procedures must be reviewed where there are changes.
|Pest control is not prescriptive but should be applied based on risk.||No CIP section, controls applied based on risk assessment.|
|17. Process control|
|Validation of process controls.
Procedures for process deviations and where equipment malfunctions.
Product monitoring to meet the specification.
|Much more focus on the practicalities of making sure the process works – based on data.
Traceability test must be performed following changes to the system.
|18. Storage & distribution|
|Temperature monitoring of the internal temperature of the vehicle during transportation.|
- IFS is a lot less wordy than BRCGS – it has 33 pages, compared to 48
- IFS isn’t as prescriptive as BRCGS, so it’s more flexible but also open to interpretation (rightly or wrongly)
- There is no interpretation guide for IFS
- It’s interesting that CPs are required. FSSC require OPRPs. FSMS (in America) require PCs. Seems that this is the way things are going; to have three levels of control point – PRPs, OPRPs (or equivalent) and CCPs.
- The IFS Standard focuses much more on the site understanding their own risks and developing systems to meet them, rather than prescribing what’s right.
- Process control is much more robust in the IFS Standard, as it’s driven by data and validation to ensure that the product meets specification.
Overall, there doesn’t seem to be a huge amount of work involved in moving to IFS Food, with the exception of process control – which most sites will have in place, it’s just a case of formalising it.
All of the additional requirements all seem sensible. We also like the fact that it’s not as prescriptive, but there’s more focus on risk assessment to determine what’s needed. This does however, mean that you need to know your stuff to know what’s needed. Although the BRCGS Standard is less flexible, the good thing about it is that you can follow it and know you’ve got everything covered (even if it’s burdensome).
It’s going to take us some time to work on all the documents relating to FSSC22000, so to give us some time to do that, we’ll focus on the other three IFS Standards next.
What do you think?
So, what are your thoughts on IFS and the work that would be needed?
What do you think about the additional requirements?
What do you think about the topics that are not included?
Share your thoughts with your fellow techie’s and add them to the comments box below.
We've tagged this article as: BRC audit protocol
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