Clauses 4: Site standards
This is the fourth BRCGS Global Standard Food Safety Issue 8 to 9 briefing sheet regarding the main changes to Clause 4 Site Standards. 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.
|Details of main changes
|Statement of intent title wording changed to 4.1 External standards and site security
|Visitors and contractors
|New clause detailing requirements for the control of visitors and contractors covering:
– Policies and systems required to control access of employees, visitors and contractors. Plus a system for recording visitors entering the site to be in place.
– Contractors and visitors, including drivers, shall be made aware of the procedures for accessing the site.
– Only authorised personnel have access to production and storage areas.
– Contractors working in product processing or storage areas shall be the responsibility of a nominated person.
|Statement of intent
|Statement of intent title wording changed to Food Defence.
|Food defence personnel
|New requirements for personnel involved in developing threat assessments and food defence plans are required to understand potential food defence risks at the site.
Where there is a legal requirement for food defence training the site shall ensure this has been undertaken.
|New requirement: Where applicable, the food defence plan shall meet the legal requirements in the country of sale or intended use.
|Production risk zone
|Requirement moved from clause 8.1.1
The site shall assess the production risk zones required for the products manufactured, processed or packed at the site, using the definitions in appendix 2 of the Standard.
|New requirement that require additional information to be detailed on site map covering:
– Production risk zones to be defined where the product is at different levels of risk from pathogen contamination.
– Any areas where time segregation is used to complete different activities (for example, time segregation for high-care areas).
|The term mezzanine floors has been added.
|New requirement that requires: Where plastic strip curtains are present, these shall be maintained in good condition to prevent pest ingress.
|New requirement requiring where water is stored and handled onsite (e.g. holding tanks) these shall be managed to minimise food safety risks.
|New requirement that requires water source needs to be detailed on the water schematic diagram.
|The equipment clause now has a statement of intent detailing: All production and product handling equipment shall be suitable for the intended purpose and shall be used to minimise the risk of contamination of product.
|New requirement that requires where new equipment is being purchased there needs to be a documented purchase specification covering:
– Any relevant legislation
– Where applicable, requirements for food contact surfaces to meet legal requirements
– Details of intended use of the equipment and the type of materials it will be handling
The requirement also requires that the supplier should provide evidence that equipment meets these site requirements before equipment is supplied.
|New requirement that requires a site to have a documented, risk-based, commissioning procedure to ensure that food safety and integrity is maintained during the installation of new equipment.
The commissioning procedure shall include the update of any other site procedures that are affected by the new equipment, for example, training, operating procedures, cleaning, environmental monitoring, maintenance schedules or internal audits.
The design and placement of equipment shall ensure that it can be effectively cleaned and maintained.
|New requirements requiring the design and construction of the equipment shall be based on risk, to prevent product contamination.
For example the use of the correct seals, impervious surfaces or smooth welds and joints, where they are exposed to product and could otherwise result in foreign-body, microbiological or allergen contamination of the product.
|New requirement requiring a procedure to be in place to manage the movement of static equipment in production areas.
|Storage of equipment
|New requirements covering:
– Equipment which is not in use or taken out of service shall be cleaned and stored in a manner which does not pose a risk to the product.
– Equipment stored in internal production and storage areas shall be kept clean.
– Food contact equipment which has been stored but is not in daily use shall be cleaned and, where necessary disinfected, prior to use.
|New Mobile equipment
|New requirements covering:
– Mobile equipment (e.g. fork-lift trucks, pallet trucks, scissor lifts and ladders) used in open product areas shall not pose a risk to the product.
– Where the use of mobile equipment in external areas cannot be avoided, the equipment shall be cleaned and disinfected prior to entering production areas.
|Battery charging equipment
|New requirement requiring battery charging equipment shall not be stored in open product areas (unless the batteries are fully sealed/maintenance free) or where there is a risk to products.
|New requirement requiring mobile equipment to be included in the preventive maintenance schedule.
|New requirement requiring control of allergenic ingredients or introduction of new allergenic material to the site to prevent contamination of product.
|New requirement for non-food chemicals covering:
– A designated storage area (separate from chemicals used as raw materials in products) with restricted access to only authorized personnel
– Procedures to manage any spills
– Procedures for the safe, legal disposal or return, of obsolete or out-of-date chemicals and empty chemical containers.
|Control of wood
|New requirements requiring where the use of wood cannot be avoided, the condition of wood shall be continually monitored on a risk-based frequency.
Additional text clarifying use of wood in a food production environment.
|Use of Pens
|Original clause requirements have been expanded to provide additional clarification on the use of pens and similar portable items.
|Foreign body contamination
|Based on risk, procedures shall be implemented to minimise other types of foreign-body contamination (i.e. types of contamination that are different from those detailed in section 4.9).
|New requirements requiring where the test piece shall be passed as close as possible to the least sensitive area of the metal detector (usually the center of the metal detector aperture).
|New clause detailing what needs to be covered in a x-ray equipment testing procedures covering:
Use of test pieces incorporating a sphere of suitable material (e.g. a typical contaminant) of a known diameter selected on the basis of risk. The test pieces shall be marked with the size and type of test material contained
– Tests carried out using separate test pieces
– A test to prove that both the detection and rejection mechanisms are working effectively under normal working conditions
– Tests of the X-ray detector by passing successive test packs through the unit at typical line operating speed
– Checks of failsafe systems fitted to the detection and rejection systems.
In addition, where X-rays are incorporated on conveyors, the test piece shall be passed as close as possible to the least sensitive area of the X-ray
Wherever possible, the test piece shall be inserted within a clearly identified sample pack of the food being produced at the time of the test.
Where in-line X-ray detectors are used, the test piece shall be placed in the product flow wherever this is possible and the correct timing of the rejection system to remove identified contamination shall be validated.
Testing of in-line detectors shall be completed during both line start-up and at the end of the production period.
|Clarification added covering inspection, cleaning, strength testing and integrity checks of magnets are only required where magnets are used for final product testing.
|Optical sorting equipment
|Clarification added covering testing of equipment only required where optical sorting equipment is used for final product testing.
|Other foreign body detection equipment
|New clause requiring where other foreign-body detection and removal equipment, such as gravity separation, fluid bed technology or aspirators, are used they shall be checked in accordance with the manufacturer’s instructions or recommendations.
|Clause has been expanded to include disinfection procedures shall be in place and maintained for the building, plant and all equipment.
|Additional requirements to check spray balls are operating correctly.
|Environmental monitoring controls
|The existing clause has been expanded to include: Appropriate control or action limits shall be defined for the environmental monitoring programme.
|New requirements requiring waste disposal from open product areas shall be managed to ensure that it does not compromise product safety.
|Management of surplus food
|New requirements requiring where products are sold to staff or passed on to charities or other organizations then traceability needs to be maintained.
|Pest management survey
|There is a change in terminology from survey to assessment and control expert to management expert.
|Third party contractor
|Original clause wording has been replaced with additional clarification on how to approve a contractor when they are BRCGS/GSFI certified and a contract who is not BRCGS/GSFI certified.
John’s contact details:
M: 0780 3136598