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Techni-K attended the Food Safety Europe 2018 BRC Conference on Thursday of 22nd Feb, to hear key speakers from Campden, industry leading businesses, the FSA, universities and also to find out just what is planned for BRC V8. It was an interesting day at a great venue in London at the Crystal, Royal Victoria Docks, so here’s what they said about Version 8.  I’ve also added in my thoughts – it would be great to hear what you think about what they’ve said too!  Just pop your thoughts in the comments box at the bottom of this post.

Timings

BRC Version 8 will be published in August 2018 and will effective from February 2019. So, if your audit is after the end of January, you’ll need to be prepared for Version 8.

Audit Reporting

When the audit report is issued, if you are being audited for the first time and you are waiting for the result for the commencement of some business, then good news – there is now going to be a 10 day interim report for use in these situations.

FSMA

The standard is now said to be compliant with the US Food Safety Modernization Act (FSMA) requirements for the Food Safety Plan. This means there may be some different terminology which is used in FSMA such as preventive controls, however we will need to see the full standard to understand full clarification on this element.

Senior Management Commitment

Senior Management, you are not getting off lightly in the V8 audits! Not only will your operational staff members be audited, but there will be more questioning of senior management throughout the audit to ensure you have a good understanding of BRC too.

Participate

BRC Participate is going to be free from August 2018, so no more subscription fees!

Kassy’s thoughts: “I think this is a really positive move by BRC.  I never really agreed with the BRC charging for Participate, as they should want all sites to have access to as much information (for free) as possible, because they should want them to do well and achieve the standard.”

Training for Version 8

Training for BRC V8 is available from September 2018 for auditors, there are a variety of courses from a 1-day for technical managers, to a 5-day course which is aimed at site level auditors.

The Standard

Let’s have a look at the sections that are changing then I will go into more detail on each to explain:

Senior Management Commitment & Continual Improvement

  • Food Safety Culture – an assessment is required
  • Reporting Issues – A (whistle blower) reporting system to be in place

Food Safety & Quality Management systems

  • 4.0 Internal audits – clear expectations for scheduling throughout the year
  • 5.0 Supplier approval – clarification re: ongoing approvals
  • 5.4 Outsourced processing – applies only where product comes back to site
  • 7.3 Root cause analysis – procedures now needed

Product security & food defence
Labels & packing
Environmental Monitoring

Senior Management Commitment & Continual Improvement
Food Safety Culture

This is what BRC said:
Background and Objectives

  • Food safety culture is a fundamental factor in the management of product safety
  • Whilst challenging to audit, it is important that food safety culture is considered within a site and therefore within the requirements of the Standard
 What the standard says:
“The site’s senior management shall define and maintain a clear plan for the development and continuing improvement of food safety and quality culture. This shall include:
  • defined activities involving all sections of the site that have an impact on product safety
  • an action plan indicating how the activities will be undertaken, measured and intended timescales
  • review of the effectiveness of completed activities”

BRC Global Standard for Food Safety Draft V8

This is what this means to you:
A food safety culture assessment for your business is required.  This means we need to design and implement an assessment, for which BRC have an assessment tool that can be used. This issues a link for your employees to complete an anonymous survey, which is then submitted to the BRC culture assessment portal for collation.  This costs £500 for businesses wishing to pursue this. You could research other assessment tools out there and put your own together, however the way forward suggested by Campden is to think under the following categories:
People: Reward, empowerment, training, teamwork and communication
Process: Control, co-ordination, consistency, systems and premises
Purpose: Vision, values, strategy, targets, metrics
Proactivity: Awareness, foresight, innovation, learning, investment
Kassy’s thoughts:  “I understand why BRC have put this clause into Senior Management Commitment and I think it’s a bold move.  However, I personally believe labelling it ‘food safety culture’ gives the wrong impression – surely culture should cover quality, legality and integrity.  I also think that suggesting that it can be tackled using an employee questionnaire is a little short sighted.  To create a change in culture has always required a top down approach, rather than bottom up.  Changing the culture in the food industry I believe will be one of the greatest challenges that we’ve faced and so, it requires a lot more than an ‘assessment’.  It is a really good start though to include it in the standard.  But I do fear; that because it’s going to be the technical team trying to comply with the clause, it will become a bit of a tick box exercise.  As Techie’s we’re going to have to get whole management team involved – and we know how hard that is to do!”

Reporting Issues

This is what BRC said:
Background and Objectives

Encourage the opportunity for employee feedback (whistle blower concept) following the EFRA Committee 2 Sisters review
Requirements
  • Clause 1.1.5 amended – staff understanding importance
  • Clause 1.1.6 added – confidential reporting system needed
The company shall have a confidential reporting system to enable staff to report concerns relating to product safety, integrity, quality and legality.

Food Safety & Quality Management systems

This is what BRC said:
Background and Objectives

General Changes
Requirements
3.4 Internal audits – clear expectations for scheduling throughout the year
3.5 Supplier approval- clarification re ongoing approvals
3.5.4 Out sourced processing – applies only where product comes back to site 3.7.3 Root cause analysis –procedures now needed

3.4 Internal audits – clear expectations for scheduling throughout the year

Now all sites need to evenly distribute the internal audits throughout the year, this is to prove that systems are compliant all year round.
Kassy’s thoughts:  “I would recommend that where you use external help to complete your internal audits, that you ensure that your auditor comes in 4 times a year, once per quarter (total 4 days).

3.5 Supplier approval- clarification re: ongoing approvals

Approvals can be based on 3rd party audits which are not GFSI standards such as SALSA or ISO22000 (which is recognised by GFSI).  If you take the option of approving via a non GFSI recognised scheme, you need to request the certificate and the audit report from the supplier. You then need to review the audit report, to ensure you’re happy with it and then approve it if you are.

3.5.4 Out sourced processing – applies only where product comes back to site

Clarification of the requirements for the outsourced processing and packing elements, only apply when the product is returned to the site again prior to being sent out to the customer.

3.7.3 Root cause analysis

A procedure for how root cause analysis is to be managed is now required.

Product security & food defence

This is what BRC said:
Background and Objectives
  • Need to align more closely with the GFSI requirements and international expectations
  • Extend the requirements to consider internal risks as well as external security issues
Requirements
The company shall undertake a documented risk assessment (threat assessment) of the potential risks to products from any deliberate attempt to inflict contamination or damage. This assessment shall include both internal and external threats.
Kassy’s thoughts:  “Of course I’m pleased that food defence has been introduced. Again, I just hope it won’t turn into a tick box exercise, as another assessment is given to technical to produce.”

Labels & packing

This is what BRC said:
Background and Objectives
  • Product recall/withdrawal data shows the underlying cause of the greatest number of problems is still associated with errors in labelling and packing.
  • Whilst unlikely that mis-packing or mis-labelling will occur whilst the auditor is onsite, it is important that the Standard continues to promote best practice.
Requirements
  • ‘Change control’ needed at goods receipt
  • Onsite printing (eg date codes) need to be controlled
  • Online verification equipment needs to be tested
  • Vertical audit to be extended to include a comparison of the label with specification and recipe should form part of the audit

Environmental Monitoring

This is what BRC said:
Background and Objectives
  • Introduce an important tool for identifying potential contamination risks
  • Sites to develop a rigorous monitoring programme, enabling timely corrective action before product contamination occurs
Requirements
Risk based environmental monitoring programmes shall be in place for pathogens or spoilage organisms. As a minimum, this shall include all production areas with open and ready-to-eat products.

As you would expect from us by now, we will be tackling the changes to the standard section by section as soon as it’s published in August, so that you’re ready for audit from February. It would be helpful for me to know which topics you’d like me to tackle first – you can do this by adding your requests to the comments box below.

36 Comments

  • Marinda says:

    GOOD DAY,
    Thanks for the interesting info, very informative. From my side please tackle the Senior Management Commitment & Continual Improvement.

    Kind regards.

    Marinda

  • Cant say my manager will kill me if he sees this! says:

    Environmental monitoring will be a good one, I don’t agree with how our head techie approaches it but as assistant I don’t get a lot of say in the issue! He swabs after cleaning has been completed but everything I have read states we should swab during production so we know what micro risks are present during a production run. It would be great to have some guidance on this

    • Kassy Marsh says:

      Hi!
      Ok, I’ll make sure I cover this. I can understand why he does that, but I can see your point too. You need to prove that the cleaning worked, but like you say you should also ensure that the cleaning frequency is right (by knowing what micro build up you get over the time inbetween cleans).
      Kassy
      p.s loving your style – I think it’s a good idea to post comments and not put your name. I’d like more to do it – we can be more open and help each other more that way, while staying ‘hidden’! 🙂

  • Anna Gallagher says:

    Hi Kassy,.

    Thanks for the update.

    I would like to receive more guidance on the Procedure for Root Cause Analysis and The Environmental Monitoring section regarding Risk based environmental monitoring programmes.
    Also interested in what you would advise to be carried out with regards to the Food Safety Culture – even with the Whole Mgmt team involved as you say it will revert to Technical.

    kind regards
    Anna Gallagher

    • Kassy Marsh says:

      Hi Anna

      Thank you for your comment. I think culture is looking like a favourite – it’s definitely going to be the hardest, so we may as well tackle it first and get it out of the way!

      Thanks
      Kassy

  • Deborah Laurie says:

    Thankyou very much for an insightful look at BRC v8. It is refreshing to have comments that appreciated the ‘lot’ of Technical Managers and that every update to BRC is accompanied by more work for Technical Managers to incorporate into their already crammed schedules.
    Any help/ ideas for the Senior Management commitment changes would be first priority.
    Suggestions on tackling in house Root Cause Analysis training, especially for small companies – maybe a pack for purchase for Technical Managers to then train out?

    • Kassy Marsh says:

      I’ve been a site technical manager myself, so I can appreciate first hand – the pressure you are under. Culture comes first then!
      I like your suggestion of pack that you can train out – great idea, thank you!

  • Rachel Mercer says:

    Thank you for your newsletter. As ever it is professional, comprehensive and easy to read.
    My vote would be for Food Safety Culture first with Product security and food defence second as these seem the most challenging changes.
    Kind regards
    Rachel

  • Jo-Anne Postlethwaite says:

    Thanks for the update Kassy, really useful.

  • JACQUELINE BURNSIDE says:

    Hi Kassy, some great insight into version 8 – thank you.
    I think because it is such a new change and may take time to implement if you could start with the changes to Senior Management Commitment.

    Thanks
    Jacqui

  • KatyG says:

    Food Safety Culture, please especially since currently all information about this as add-on to V7 standard has been put on hold.

  • Hi Kassy,

    Thanks for initial autopsy of the prospective changes that will be made in V8. I would like to tackle Labels and Packing to start with.

    Regards
    Jagadish Babu

    • Kassy Marsh says:

      Hi!
      How are you? It’s been a while! 🙂
      I think we’re going to have to go for culture as the first topic, but I will get to all the changes – I promise!
      Thanks
      Kassy

  • MELINA RODRIGUEZ says:

    HI, ITS VERY IMPORTANT FOR A LOT OF LATINAMERICAN COUNTRIES TO HAVE ALL THE INTERPRETATION GUIDES IN SPANISH. THAT WOULD BE GREAT AND VERY HELPFULL, SO TEAMS CAN WORK WITHOUT THE HELP OF ONE OR TWO PEOPLE TO TRANSLATE (WITH THE MISTAKES THAT CAN BE MADE)
    THANKS A LOT FOR THE NEWSLETTERS …VERY USEFULL !!

    • Kassy Marsh says:

      Hi,
      I wasn’t aware that the BRC didn’t do the interpretation guides in different languages – I’ve just been on to check, but unfortunately it looks like they are updating the bookshop and so you can’t see them.
      I’ll keep looking!
      Thanks
      Kassy

  • Rony Fortin says:

    Excellent feedback and I coincide with your thoughts about changing the employees food safety culture.

  • Gail Hurlbert says:

    Will there be revisions on the Vulnerability of the raw materials and packaging? I’m expecting this will become a bigger section to deal with. I’m still confused on weather I need to go into as much detail with suppliers that are already BRC or SQF Certified.
    Thank you so much for sharing what you know about Section 8. Our audit will be in March so the more I can do now to prepare, the better.
    SO STRESSFUL!

    • Kassy Marsh says:

      Hi Gail,
      I don’t believe there will be any changes to the vulnerability section. However, I would imagine, that the auditors will have higher expectations of the application of the clauses, as the years go by. The clauses are robust enough, but they have to be audited properly to add value (and I’m not seeing auditors do this yet).
      I think the BRC’s opinion would be that as long as your supplier has BRC then you don’t need to worry (one of the BRC guys said that in a talk he was doing when version 7 came out), but this isn’t written into the standard. And, if a site wants to be fraudulent, I don’t see how having a BRC certificate is going to stop them….?
      Please don’t stress too much – we’re all in this together! 🙂
      Thanks
      Kassy

  • Mireia says:

    Hi Kassy,
    This is a very informative. Challenges our customers will have on V8 will be transmitted on the work and information passed onto their supplier chain.
    I would like a bit more detail on the supplier approval process (ongoing approvals )and monitoring and what are the expectations of BRC customers to ingredients suppliers with ISO 22000.
    Thank you

    • Kassy Marsh says:

      Hi Mireia,
      Thank you for your comment. Sure, I can do that. Quickly in summary though, if you are ISO 22000 (not FSSC) then you will need to provide your audit report as well as your certificate, so that your supplier can see what NCNs you got. The supplier should also ask you to supply evidence of close out of these NCNs too – so that they can check you’ve closed them out effectively.
      Kassy

  • Alex says:

    Hi Kassy,

    Really interesting article – thanks for explaining it all, looking forward to seeing your post on Food Safety Culture, I definitely think that it will be the hardest to implement from a Techie perspective, it will be interesting to see!

    thanks

  • Dr.Madhavan Pillai Sajeev says:

    Hi,

    Thanks for the information on BRC. It is really covering more stringent aspects of food safety. We look forward to hear from you more
    on this.
    Dr.Sajeev

  • Carolin says:

    Hi Kassy. Will the BRC Food Safety Culture assessment be available in multiple languages?

    • Kassy Marsh says:

      Hi, That’s a good question – I’ll ask for you!

    • Hello,
      It’s great to see this excellent site for sharing knowledge and engaging in discussions! I can confirm that currently there are 23 languages on the BRC Food Safety Culture assessment, and these are continually being added to over time. If you have a specific language you are interested in, please let me know! Best wishes, Joanne (Culture Excellence).

  • Gabriel Ghomren says:

    Management commitment should include a process where there is monthly schedule for Quality Management System KPI review attended by most senior site top management representative. This will ensure corrective actions are taken and progress /closure tracked in subsequent meeting. This will ensure the Quality compliance culture is driven from top down.

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