Briefing Note 3 – BRCGS Global Standard Food Safety Issue 8 to 9

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Clauses 3: Food Safety and Quality Management Systems

This is the third BRCGS Global Standard Food Safety Issue 8 to 9 briefing sheet regarding the main changes to Clause 3 Food safety and quality management system.  To understand all the changes from issue 8 to 9 it is recommended you download the draft version of the standard issued on 6.12.2021 and read in conjunction with this briefing note.

We will also be issuing a briefing note when the standard is published on the 1st August comparing any amendments from the draft standard to the published standard.

The Briefing Note has been prepared by John Husband who is BRCGS Approved Principal Training Partner and has been delivering BRCGS training for totrain and on behalf of BRCGS for over 20 years.

Clauses 3: Food Safety and Quality Management Systems

Clause Clause subject Details of main changes
3.4.1 Audit programme Additional requirements for site internal audit programme scope to include:
– Food safety and quality culture plan
– Assessment of the site’s conformity with their food safety and quality management systems.
3.4.3 Conformity and nonconformity Additional requirement requiring non conformities raised at internal audits to be handled as detailed in corrective and preventive actions clause 3.7.
Non-conformities raised at Internal Audits also need to be reviewed at management review meeting.
3.4.4 Hygiene and fabrication inspections Additional requirements requiring:
– Issues raised at hygiene and fabrication inspections shall be reported to the personnel responsible for the activity
– For issues raised there needs to be corrective actions, and timescales for their implementation, shall be agreed and their completion verified
– As a minimum a summary of the results shall be reviewed in the Management review meetings clause 1.1.4.
3.5.1.1 Raw material risk assessment Additional requirement added that requires risk associated with customer requirements to be considered
3.5.1.2 Supplier approval The scope of supplier audits has been expanded to include:
– Product security
– Food defence plan
– The product authenticity plan
– Good manufacturing practices
The audit shall ensure that the food defence plan and product authenticity plan form part of the supplier’s product safety management system and that any resultant actions are implemented.
Questionnaire used to evaluate low risk suppliers as a minimum shall have a scope that includes:
– Product safety
– Product security
– Food defence
– Product authenticity
– Traceability
– HACCP review
– Good manufacturing practices
The questionnaire is now required to be reviewed and verified by a demonstrably competent person.
3.5.3.1 Approval of suppliers of service The procedure for the approval of supplier services now needs to include product safety consultants.
3.5.3.3 Monitoring of service suppliers performance There is now a requirement to have in place a process for ongoing performance review of suppliers of service, based on risk and the performance criteria defined.
3.5 Management of outsourced processing Additional text has been added clearly defining what is meant by the term outsourced processing.
3.5.4.2 Approval of outsourced processor The scope of outsourced processor audits has been expanded to include:
– Product security
– Food defence plan
– The product authenticity plan
– Good manufacturing practices.
The audit shall ensure that the food defence plan and product authenticity plan form part of the outsourced processors product safety management system and that any resultant actions are implemented.
3.5.4.3 Outsourced processing and HACCP. There is a new requirement that outsourced processing be included in site HACCP plan.
3.5.4.4 Outsourcing specifications There is now a requirement for sites to have clear and agreed specifications for all outsourced processing.
3.7.1 Corrective action procedure New requirement that site procedures will include the completion of root cause analysis and handling of preventive action.
3.7.2 Nonconformity investigation The clause has been expanded to include the situation where authenticity is not met and adverse trends in quality and this shall be investigated and recorded.
BRCGS define authenticity as ensuring that food or raw materials purchased and offered for sale are of the nature, substance and quality expected.
The following statement has also been added:
Root cause analysis shall also be used to prevent recurrence of non-conformities and to implement ongoing improvements when analysis of non-conformities for trends shows there has been a significant increase in a type of non-conformity.
3.7.3 Root cause analysis procedure Clause has been removed but requirement for root cause analysis procedure detailed in clause 3.7.1
3.8.1 Non conformity procedures Clause has been expanded to include procedure required for management of any product returned to the site.
3.9.1 Traceability procedure A requirement has been added requiring a traceability system to meet the legal requirements in the country of sale or intended use.
3.11.1 Management of incidents Clause has been expanded to include the site requiring systems in place to manage incidents and potential emergency situations that impact authenticity.
3.11.4 Food safety incident The clause has been expanded to include incidents relating to authenticity or legality.
New requirement Certification body needs to be informed when a site has a withdrawal in three working days using the BRCGS Directory.
Additional requirement added requiring site to provide sufficient information when an incident has occurred to certification body covering corrective action, root cause analysis and a preventive action plan undertaken by the site.

John’s contact details:

E: john@totrain.co.uk

M: 0780 3136598

W: totrain.co.uk