Module 11 meat supply chain assurance
Module 11 meat supply chain assurance, has been updated by BRC so that it is in line with Issue 8. There aren’t any really exciting changes or additions, but we wanted to make sure you’re aware of the updates…
Clause 11.2.1 Meat supply chain
The first of the changes is the approval of meat supply chain. BRC have removed the words ‘supplier approval’ from clause 11.2.1. As a whole this has made no difference to what the requirement is asking of you, so you don’t need to do anything differently.
There is an addition to the interpretation of this clause however, which you may need to be aware of. The risk assessment should remain up to date and reflect any changes made to your product, the supply chain or the emergence of new risks. This should be in the relevant procedure anyway, but just make sure you don’t get caught out by this and make sure your risk assessment is up to date.
Approval of suppliers
The second change is an update to 11.2.2 regarding how you approve your suppliers. BRC are just clarifying what you are expected to have as evidence. So, the approval of your suppliers (those who handle, store open or incompletely packaged product, or agents and brokers, or storage facilities that only handle fully enclosed products) the procedure is now the same.
You can approve supply through a valid certification. For facilities in your supply chain that handle the product this must be with a valid BRC food safety or storage and distribution certificate that must include the meat supply chain assurance module. The scope of the certification must also include the raw materials you are purchasing.
For agents and brokers or facilities who store fully enclosed product you are able to approve supply though a valid BRC agents and brokers or storage and distribution certificate or one that is an equivalent GFSI benchmarked standard. The scope of which should include the raw materials you are purchasing.
Suppliers can be approved through supplier audits as before. However, there is a change (or clarification) regarding what is needed, for this method of approval. You can use a second or third-party audit to approve your suppliers, but you are now responsible for also providing proof of the following:
- You need to be able to demonstrate the competency of the auditor. If this is done by one of your own auditors or through a consultant, you should have their training certificates on file anyway. If they are done through third party audits, carried out by a certification body, the certification will ensure the competency of the auditor. So you don’t need to.
- Secondly you need to confirm and show that the audit covers product safety, a traceability test, HACCP, GMP and compliance to module 11.
- Finally, you need to have obtained a copy of the audit report and reviewed the results to confirm the site is compliant with the requirements.
Clause 11.2.3 Exceptions
There was a new addition into 11.2.3 which states that you now need a procedure in place, defining how exceptions to the supplier approval process will be handled. This needs to include when an exception is likely to be considered, and what measures will be in place for the approval.
For instance, it could be that you are only supposed to purchase from a customer approved supply chain, and an audit wasn’t practical prior to the initial purchase. Or if an incident has occurred that has affected the supply chain which has forced you to have to gain supply from elsewhere. The methods of approval may include a risk assessment, product testing and additional controls to verify the integrity, legality and authenticity of the product (this should ideally be by batch delivered, until proper approval can be given).
If you are a site that makes customer branded products, all exceptional approval must be communicated to your customers.
Clause 11.4.2 Cross-contamination
The final change was just a reword in 11.4.2, but the wording didn’t make any change to the requirement. You still need to have a documented risk assessment that identifies all routes of cross-contamination between species. As in Issue 7, this would include identifying all potential points throughout the process where cross-contamination could occur. An assessment of the risk at each step that has been identified, and the what controls you’ve put in place to reduce or eliminate them.
The risk assessment must be used as a basis for any procedures that prevent cross-contamination from occurring. Including the handling of raw materials, intermediate products and finished products. So you need to include things like storage, production schedules, species specific equipment, labelling etc.
As you can see, there are no major changes to anything you need to do to comply with issue 8 of the module, above and beyond what you’ll already have done for issue 8 anyway. But a few tweaks may be necessary, just so you don’t get caught out – so do check to make sure!