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BRC Newsletter 7 – 58 points to check on the changes to BRC issue 7

By 24th June 2015 April 13th, 2016 BRC Compliance

58 Points to check on the changes to BRC issue 7

Quite a few for you to check before your V7 audit:
  1. Senior management commitment (section 1) has been amended to define which responsibilities must be owned by the site and which can be managed by a central function if there is one. If you have a central function and they take responsibility of certain management commitment requirements, make sure this is still adequate for version 7.  There are changes from ‘Company’ to ‘Site’ throughout the standard, so please ensure that you have all of the evidence you need to show on your audit, rather than stating that Head Office take this responsibility. (Section 1.1 and other clauses through the document)
  2. You no longer need a hard copy of the standard, a digital copy is fine. (Clause 1.1.7)
  3. It’s no longer enough just for senior management to attend the opening and closing meeting, they now have to show participation (involvement and interest). (Clause 1.1.9)

  4. Where you reference information in your HACCP plan you now must have copies of the documents referenced and they must be up to date. (Clause 2.3.2)
  5. The changes on BRC issue 7, include a clause around critical limits has been expanded to say that subjective measures for critical limits could be something like photographs.  Personally I do not see how a critical limit can be subjective, the pass or fail criteria should be clear – black and white for CCPs. Therefore I think this clause is contradictory to HACCP principles. (Clause 2.9.1)

  6. Where a recall occurs a HACCP review must be conducted. Internal audits must now be scheduled throughout the year, they can no longer be done in one go once a year. Therefore if you use a consultant to carry out your internal audits, they need to complete them routinely throughout the year. (Clause 3.4.1)
  7. Your raw material risk assessment must now be reviewed annually. (Clause
  8. The raw material risk assessment must now include substitution or fraud of ingredients (this section covers packaging but substitution or fraud need only cover ingredients), but the vulnerability assessment conducted in section 5.4 can be used to cover this requirement. I’m not really sure why they didn’t include the requirements of 5.4 in this section, it makes it confusing splitting them up. (Clause
  9. Supplier approval and monitoring must now include food contact packaging, but also consumer packaging – which means any packaging that the consumer receives with the products (even if it’s not food contact). (Clause
  10. The scope of supplier audits has now been defined to include as a minimum HACCP, traceability, product safety and GMP. (Clause
  11. Supplier audits must also be carried out by an experienced and demonstrably competent auditor. This means that the auditor doesn’t need to be qualified but must be able to demonstrate that they know how to complete an audit to a good standard. (Clause
  12. Supplier questionnaires can no longer be used for any suppliers, other than those that are defined by the supplier risk assessment as low risk. (Clause
  13. You also now need to have an up to date list of approved suppliers. (Clause
  14. When using agents and brokers, all approval and monitoring criteria must be applied to the last manufacturer or packer of the material, to assess just the agent/broker is not sufficient. Unless, the agent or broker holds a BRC Agents & Brokers certificate – if they do, to assess just the agent/broker is acceptable. (Clause
  15. Where raw materials have been used without following the approval process (these are known as exceptions), these exceptions must be made known to your affected customers – implying that they would need to approve. (Clause
  16. Packaging must now be included in your raw material risk assessment to determine acceptance criteria (checks at goods in). This acceptance criteria must also be implemented (done on a day to day basis) and the results of these reviewed. (Clause
  17. Management of outsourced processing, now includes outsourced packing as well. (Clause 3.5.4)
  18. The audit criteria and the requirements of the auditor have been defined for outsourced process and packing, as detailed above in (Clause
  19. Traceability now needs to include traceability of primary packaging, which is not just food contact packaging but also includes any consumer packaging (packaging that the consumer receives with the product. (Clause 3.9.2)
  20. Where raw material suppliers (except direct from farm) have been approved on just a supplier questionnaire (remember this can now not be for low risk suppliers), the approval process must include a traceability test to ensure that the supplier has the required trace systems in place. This trace approval exercise must be repeated at least every 3 years. (Clause 3.9.3)
  21. Root cause analysis now only needs to be applied to serious complaints or where there has been a significant increase in complaints. (Clause 3.10.2)
  22. Contingency plan requirements have been amended so that they do not need to include business continuity but now only need to maintain food safety, quality and legality. (Clause 3.11.1)
  23. Crisis contact details now need to include out of hours contact details. (Clause 3.11.2)
  24. New section for Customer Focus & Communication added, see newsletter 6 – take a look here. (Section 3.12)

  25. New clause has been added to the security section, which requires external raw material or product storage to be locked. (Clause 4.2.3)
  26. The site plan/ map now needs to include the new ambient high care zones and also the non product zones (such as offices). (Clause 4.3.1) In addition, the site plan also now needs to show the movement of personnel and access and movement of raw materials. It must also show the different staff facilities such as the changing rooms and canteen etc, plus the production flow. (Clause 4.3.2) Linked to this the site plan just be used to ensure that the movement of personnel, materials and product flow must not compromise the food safety of the product being produced. (Clause 4.3.4)
  27. The standard now states that where a physical barrier is not applied for entry to high care zones a documented risk assessment must be completed. This risk assessment must define the controls that will be required to ensure that the lack of segregation does not pose a risk to the product. The controls defined must be validated to prove that they actually work. (Clause 4.3.6) Note – a risk assessment cannot be used for high risk zones, a physical segregation has to be applied.
  28. A new clause has been added for ambient high care zones, the requirements are not set for layout, facilities and segregation (as with high care and high risk) but can be defined by you, but this needs to be documented in a risk assessment. (Clause 4.3.7)
  29. You must now define what chemical and micro tests you need to do on your water samples and this must be documented. (Clause 4.5.1)
  30. The water plan no longer has to show the water system as a plan of the site, a schematic of how the water systems works is adequate. (Clause 4.5.2)
  31. Maintenance tools and equipment must now follow the same rules as anything else when entering high risk/care areas, therefore they must be cleaned on entry (as you would raw materials) or these must be specific to the area and stored in the area. (Clause 4.7.5)
  32. Food grade oils that are used for maintenance must have specifications that detail allergens, this must be taken into account in allergen systems. (Clause 4.7.6)
  33. If you provide footwear for high care areas, the footwear must now not be worn outside the factory. (Clause 4.8.5)
  34. Footwear entering high care/risk areas must either be cleaned prior to entry to the area (using something like a foot bath) or footwear must be restricted to that area and only put on at the entry point. Plus – you must prove that these controls (which ever one you choose) are effective, through environmental testing such as micro swabbing. (Clause 4.8.4 & 4.8.5)
  35. The process for changing into high risk clothing has been defined – in that hand washing must take place after putting on a hair net and shoes (as these are “dirty”) and before touching clean protective clothing (white coat). (Clause 4.8.4)
  36. Electronic cigarettes are not allowed in the production or storage areas. (Clause 4.8.8)
  37. The standard now defines that metal detector test pieces can be defined based on risk and the reject system timing must be challenged. (I’ll explain how to do this in a later newsletter). In addition the fail safe systems of the metal detector must be tested, to prove they are effective. (Clause
  38. A new clause “The premises and equipment shall be maintained in a clean and hygienic condition.” has been added, this doesn’t change the requirements but has been added so that auditors can assign non conformances for poor cleaning to one clause, for trending purposes. (Clause 4.11.1)
  39. It has been clarified that cleaning procedures are specifically required for processing equipment, food contact surfaces and environmental cleaning in high-care/ high-risk areas, rather than the whole site. (Clause 4.11.2)
  40. Validation of cleaning must take place for processing equipment, food contact surfaces and environmental cleaning in high-care/ high-risk areas and this must be documented. It must include evidence that the cleaning method is effective and that there is no chemical residue. Verification of the clean is also required where the clean is needed to control allergens, micro or specication. (Clause 4.11.3)
  41. The clause managing cleaning equipment now states it must be hygienically designed and high care/risk equipment must be distinctive – which means it doesn’t need to be a different colour, but you must be able to identify it so it doesn’t get mixed up. (Clause 4.11.6)
  42. Where materials are stored outside they now must be checked prior to entry to the factory (e.g. For pest activity or cleanliness) and this must be recorded. (Clause 4.15.5)

  43. Where transportation of the finished product affects the quality or micro of the product then transport trials are now required for NPD or EPD (existing product development). (Clause 5.1.4)
  44. 5.2 Product Labelling has already been covered see Newsletter 2  – take a look here.
  45. The Statement of Intent now clarifies that the allergens covered should be appropriate to the country in which the product is to be sold. (Section 5.3)
  46. Where an allergen claim is made (e.g. Free from) the product must be checked routinely to prove that the controls that are in place continue to be effective. (Clause 5.3.7)
  47. The standard now clarifies that where lab test results are received, the results of these must be understood by the site and acted upon. Check that you understand them and can explain them. (Clause

  48. Where you use internal process specs/ factory specs, these must match your customer finished product specs, so check that they do. (Clause 6.1.1)
  49. Where monitoring equipment ensures that you get the right quality of product, the checks that this equipment does must be verified routinely to prove its effective. (Clause 6.1.3)
  50. Equipment that affects food safety or quality attributes of the product must now not only be validated to show its effective, but verified routinely. (Clause 6.1.4)
  51. 6.2 Labelling & Pack Control has already been covered see Newsletter 4 – take a look here.
  52. When equipment is used for CCPs (such as probes etc) you need to ensure that the uncertainty of the equipment is taken into account in the critical limits. For example if a probe is accurate to +/- 0.5C and you need to achieve 85.0C or above to pass your CCP, then you would need to add the 0.5C to your critical limit, meaning you would need to achieve a critical limit of 85.5C or above. (Clause 6.4.3)

  53. Agency staff must be trained prior to starting work and this must include their task based training, induction and allergen awareness. (Clause 7.1.1 & 7.1.4)
  54. Nail art cannot be worn in the factory. (Clause 7.2.1)
  55. In some countries it is not legally permitted to force people to declare if they are ill, therefore the medical clause has been amended to say that it’s a requirement to explain to personnel, visitors or contractors what symptoms, infections or diseases are a problem, but they cannot force people to tell them. In the UK this is not the case and so it is still required that employees and agency staff/ visitors and contractors should notify their manager/ host if they are ill. (Clause 7.3.1 & 7.3.2)
  56. Agency workers must be trained on the protective clothing rules. (Clause 7.4.1)
  57. The frequency of laundry audits must now be determined through risk assessment. (Clause 7.4.4)
  58. High risk/care protective clothing must be changed at least daily. Other zones frequency of changing if not daily, must be based on risk assessment and this must be documented. (Clause 7.4.5)

I hope you’ve found that useful, I’d love to hear how you got on with checking the points above.  I’d also be really keen to know your thoughts on the subjective critical limits clause from the HACCP section – I really don’t understand why BRC have decided to put that in.  If you use subjective critical limits, I’d love to hear your application of them!

Don’t forget to get your copy of our free step by step work plan to help you with your raw material vulnerability assessment, just click below to get your free copy:
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Thanks, Kassy


  • Karen Wells says:

    HI thank you for these news letters they are very useful and its good to get another perspective of the clauses. Would you be looking at covering the new clause 4.13 Management of surplus food and products for animal feed at any point? Thank you

    • Kassy Marsh says:

      Hi Karen
      Your’re welcome! As a matter of fact I’m in the process of writing 4.13 ready for next weeks newsletter, so look out for it on Wednesday!
      Take care, Kassy

  • Diana says:

    thank You so much for this overview, it is really helpful.
    I have a question regarding clause 4.11.3. Is this applies only to high care/high risk areas?

    • Kassy Marsh says:

      Hi Diana
      Thank you for your question. Clause 4.11.3 (for unacceptable and acceptable limits) applies to food contact surfaces, processing equipment and also environmental areas in high risk/care areas. So even for low risk areas you need to have these limits for food contact and processing equipment.
      I hope that helps, if you have any more questions, please just get in touch 🙂
      Thanks, Kassy

  • Diana says:

    OK. Still a bit confusing. We don’t have at our facility high care and high risk areas. Only low risk areas, where there is program for monitoring of microbiology for food contact equipment and surfaces. What we never had is a monitoring of chemical residues, now this seems to be a requirement?

    • Kassy Marsh says:

      Hi Diana
      The standard now states that even for low risk food contact surfaces and equipment that when validating your cleans you need to ensure that there’s no chemical residue left behind. So to do this you’d need to get your chemical provider to help you to test the surfaces following the completion of the method.
      I hope this helps?

  • Susan Annatone says:

    Are there general categories or is there a general definition as to determining the Low, Med and High Risk suppliers?
    Some sort of industry standard or doe seach company determine their definition/parameter and document it?
    thank you

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