Briefing Note 5 – BRCGS Global Standard Food Safety Issue 8 to 9

Clauses 5: Product controlThis is the fifth BRCGS Global Standard Food Safety Issue 8 to 9 briefing sheet and in this briefing sheet we are going to look at the main changes to Clause 5 Product control. 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 5: Product control
Clause Clause subject Details of main changes
5.1.1 New product development procedure Additional text detailing new product development procedures needs to cover new product development and changes to existing product, packaging and manufacturing processes.
5.2.1 Labelling artwork New requirements requiring the company shall have a procedure for artwork approval and sign-off.
5.3 Management of allergens An introductory statement added providing clarification on allergens in pet food.
5.4.1 Vulnerability assessment New requirements requiring personnel involved in vulnerability assessments shall understand potential food fraud risks. This shall also include knowledge of raw materials used by the site and the principles of vulnerability assessment.
5.4.3 Vulnerability assessment Additional text added detailing when Vulnerability assessment needs to be reviewed covering:

– A change in raw material or a supplier of raw materials

– Emergence of a new risk (e.g. known adulteration of an ingredient)

– Developments in scientific information associated with authenticity of the site’s products

– Raw materials, for example, information obtained as part of clause 1.1.8)

– Following a significant product safety incident (e.g. a product recall)

– Where the authenticity of the site’s products or raw materials is implicated

5.4.7 Product claim New requirements requiring where a product is designed to enable a claim to be made, the company shall ensure that the product formulation and the production process are fully validated to meet the stated claim and any legal requirements (in the country of intended sale) relating to the claim.
5.5.1 Purchasing primary packaging The requirement now requires that packaging suppliers are made aware of existing packaging being used by the site covering recyclable or reusable packaging materials.
5.6 Product Inspection The statement of intent title has been changed to 5.6 Product inspection, product testing and laboratory analysis.
5.6.1 Product testing New requirement requiring processes for obtaining product samples including where appropriate, their delivery to a laboratory.
5.6.2 Test and inspection results New requirements requiring where legal limits apply, these shall be understood by the site and appropriate action taken promptly these limits are exceeded.
5.6.5 Onsite testing laboratories New requirements requiring controls shall be documented, implemented and include consideration of:

– Hygiene and protective clothing arrangements

– Movement of materials that may pose a risk to products, raw materials or the production area, into and out of the laboratory, including the disposal of laboratory waste

– The management and monitoring of laboratory equipment

Also where testing activities are performed in production or storage areas (e.g. at the line tests or rapid tests) these shall be located, designed or operated to prevent product contamination. Laboratory results This clause has been removed and requirements can be found in clause 5.6.2.
5.8 Pet food Statement of intent title has changed to 5.8 Pet food and animal feed.

Additional text detailing all sites that produce pet food or animal feed need to meet all the relevant requirements from sections 1–7 of the Standard as well as section 5.8.

Also the term animal feed has been referenced in clauses 5.8.1, 5.8.2, 5.8.3 and 5.8.4 e.g. pet food or animal feed.

5.8.3 Pet food medication New requirements requiring the following additional controls when dealing with pet food medicated raw material:

– Supplier approval process required equivalent to section 3.5.1 for all medicated raw materials

– Specific staff training on the correct handling of medicated materials

– Waste disposal mechanisms (see section 4.12) include the safe and legal disposal of medicated raw materials and products.

5.8.4 Pet food and animal feed legislation New requirements requiring site procedures to be designed and implemented to meet the relevant pet food and animal feed product safety legislation in the country of production and in the country of sale.
5.9 Animal Primary Conversion New clause with the following statement of intent:

Where a site completes animal primary conversion (e.g. for red meat, poultry or fish) the following requirements apply, in addition to those within the rest of the Standard.

For animal primary conversion, the site shall operate controlled processes that ensure products are safe and fit for intended use.

5.9.1 Risk Assessment New requirements requiring sites to undertake a risk assessment, for potential prohibited substances (i.e. those prohibited by legislation in the country of operation or intended country of sale). Example substances include pharmaceuticals, veterinary medicines (e.g. growth hormones), heavy metals and pesticides.

The results of the risk assessment shall be included in raw material acceptance and testing procedures and for the processes adopted for supplier approval and monitoring.

5.9.3 Traceability New requirements requiring the site to operate procedures to ensure the traceability of all edible parts of the carcass.
5.9.4 Time and temperature New requirements requiring the site to establish defined time and temperature requirements for all post-slaughter processes. These requirements shall be defined for all chilled or frozen, edible parts of the carcass.

John’s contact details:


M: 0780 3136598