WHITE PAPER

BRC GLOBAL STANDARD

FOR FOOD SAFETY
ISSUE 8
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BRC GLOBAL STANDARD FOR FOOD SAFETY ISSUE 8

CONTENTS

Introduction 4

Understanding the Requirements 5

The BRC Global Standard for Food Safety 5
Fundamental Requirements Within the Standard 5
Section 1: Senior Management Commitment 6
Section 2: The Food Safety Plan - HACCP 6
Section 3: Food Safety and Quality Manual 7
Section 4: Site Standards 7
Section 5: Product Control 8
Section 6: Process Control 8
Section 7: Personnel 9
Section 8. High-Risk, High-Care, and
Ambient High-Care Production Risk Zones 9
Section 9. Requirements for traded products 9

BRC Food Issue 8 Audit Process 10

BRC Audit Standards 10
Audit Options 11
Changes to Audit Requirements 11

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BRC GLOBAL STANDARD FOR FOOD SAFETY ISSUE 8

INTRODUCTION

The British Retail Consortium (BRC) is a retail trade membership organisation whose mission is
to make a positive difference to the retail industry and to the customers it serves. It does this by
leading the industry and working with its members to shape debates and influence issues and
opportunities.

The BRC Global Standard is a leading safety and quality certification programme used by over
23,000 certified suppliers in 123 countries. There are five BRC Standards including three for
manufacturing, plus BRC Food, BRC Packaging, and BRC Consumer Products. These are in
addition to BRC Storage and Distribution and BRC Agents and Brokers. The BRC Global Standard
for Food Safety is the leading third-party certification standard worldwide with over 18,500
certified manufacturing sites.

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BRC GLOBAL STANDARD FOR FOOD SAFETY ISSUE 8
BRC FOOD ISSUE 8
UNDERSTANDING THE
REQUIREMENTS
These requirements are crucial to the
establishment and operation of an effective
food quality and safety process. Failure
to comply with a statement of intent of
a fundamental requirement (i.e. a major
nonconformity) leads to non-certification at
an initial audit or withdrawal of certification at
subsequent audits. A further full audit will be
required to demonstrate compliance.
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The BRC Global Standard for Food Safety
• Senior Management Commitment
• The Food Safety Plan - HACCP
• Food Safety and Quality Management System
• Site Standards
• Product Control
• Process Control
• Personnel
• High-Risk, High-Care, and Ambient High-Care Production Risk Zones
• Requirements for Traded Products
Fundamental requirements within the Standard
• Senior management commitment and continual improvement (1.1)
• The food safety plan – HACCP (2)
• Internal audits (3.4)
• Management of suppliers of raw materials and packaging (3.5.1)
• Corrective and preventive actions (3.7)
• Traceability (3.9)
• Layout, product flow and segregation (4.3)
• Housekeeping and hygiene (4.11)
• Management of allergens (5.3)
• Control of operations (6.1)
• Labelling and pack control (6.2)
• Training: raw material handling, preparation, processing, packing and storage areas
(7.1)
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Section 1: Senior Management Commitment

The fundamental statement of intent requires that the site’s senior management demonstrates
that they are fully committed to the implementation of the requirements of the Standard and to
the processes which facilitate continual improvement of food safety and quality management.
Senior management needs to provide sufficient resources, both financial and human, to establish,
maintain, and improve the food safety management system and associated infrastructure.
This section of the Standard includes the need for a documented quality policy statement
which defines the site’s obligations to produce safe, legal products and describes the site’s
responsibilities to its customers. It also defines an agenda for management review meetings
which need to be held at least annually.
Other requirements include:
• Maintenance of certification: the site is obliged to have their audit within the audit
window which is specified on their certificate.
• The site must hold a copy of the Standard; either a hard copy or electronic.
• Access to resources to ensure the site keeps up to date with scientific and
technical developments, industry codes of practice, new risks to authenticity of raw
materials, legislation in the country, production and country of sale.
There is also a requirement for corrective actions from previous audits to be addressed and
verified to prevent recurrence. Nonconformities that are carried over from one audit to the
next may result in two non-conformities being raised, one for not effectively addressing the
root cause and escalation of the actual non-conformity itself from a minor to a major. This will
inevitably impact the outcome of the audit and the grade awarded.

Section 2: The Food Safety Plan - HACCP

The statement of intent is a fundamental requirement and requires the site to have a fully
implemented food safety plan based on Codex Hazard Analysis & Critical Control Point (HACCP)
principles. A HACCP system should be developed, reviewed, and managed by a multi-disciplinary
team. The team should have knowledge of HACCP, the products manufactured by the site,
the processes employed, and the likely hazards. The HACCP team leader or nominated team
representative needs to be able to demonstrate competence in the application of HACCP
principles. Records should be maintained to show that key personnel identified as HACCP
team members have adequate HACCP training and appropriate experience. External expert
assistance may be used to aid the development of the HACCP system; however, the site needs to
demonstrate that day-to-day implementation is being managed.
Senior management needs to demonstrate commitment to supporting the HACCP team.This
is usually demonstrated by a senior manager. The HACCP team needs to confirm the scope of
the HACCP plan and conduct a hazard analysis identifying all the possible hazards, including
those present in raw materials and those likely to be introduced or survive the process (including
allergen risks). The team should determine the control measures required to prevent, eliminate, or
reduce hazards to acceptable levels and identify which hazards are managed via Critical Control
Points (CCPs) and those that are managed prerequisites. The team should justify and document
how acceptable levels of hazards are determined.

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Section 3: Food Safety and Quality Manual

The management system needs to be fully implemented to meet the requirements of the
Standard. The system will include procedures, work instructions, and records, and can be
electronic or hard copy. There are requirements for document control and records maintenance.
When defining how long records need to be kept, consideration needs to be given to the shelf
life of the product.
The Standard requires that internal audits are carried out to a schedule with consideration
given to the risks associated to the activity being audited. Audits should be spread throughout
the year rather than undertaken as a multi-day annual internal audit. The internal auditor needs
to be competent and independent of the area being audited. There needs to be a system in
place to assign and track corrective actions and verification or follow-up activities.
This section also describes the processes for approval and monitoring of raw material suppliers
and suppliers of services e.g. laundry, pest control, maintenance, cleaning and laboratories.
There are also requirements that need to be met where parts of the production process or
packing is outsourced to another organisation. The section also describes:
• Specifications management
• Corrective and preventative actions
• Control of a non-conforming product
• Traceability and the need for the site to test the system forwards and backwards
at least annually. The exercise will also include a mass balance and should be
achieved within four hours. The system will also be tested during the audit through
a vertical traceability exercise. The auditor will select a complex product produced
approximately two to five months before the audit and challenge the traceability.
• The challenge will be extended out to look at verification of the process flow,
monitoring of CCPs, supplier approval, specifications (raw material, packaging,
finished products and internal specifications), product release and testing, claim
verification, and allergen management.
• Complaint management
• Management of incident product recall and withdrawal. This section of the
Standard also includes the requirement for sites to test the procedure.
This is different to the traceability test as it is looking at the capability of the
procedure to operate under different scenarios; traceability will be one
element of the test.

Section 4: Site Standards

The auditor will spend approximately 50% of the audit time in production assessing sections 4,
5, 6, 7, and 8. Section 4 covers many of the prerequisites including:
• External standards
• Site security and the need for a risk assessment and controls
• Layout, product flow, and segregation. Sites are required to use the decision trees
within the Standard to determine whether areas are low risk, high care, high risk, or
ambient high care.

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BRC GLOBAL STANDARD FOR FOOD SAFETY ISSUE 8

•
Utilities, use of water, ice, steam, etc.
•
Equipment
•
Maintenance
•
Staff facilities
•
Chemical and foreign body control. For example, metal detection, x-rays, optical
sorting, magnets, etc.
• Hygiene and housekeeping: the auditor will want to see a shift change over or
production startup on day two. They may also ask to see inside equipment which is
not in use but is clean and ready for use.
• Waste disposal
• Management of surplus food and products for animal feed: this is a new section
recognising that surplus may be given to food banks or sold for animal feed.
• Pest management: frequency of inspections needs to be based on risk, and an
annual detailed inspection is required. Staff need to be trained to spot the signs
of pest activity and be aware of the need to report evidence to the designated
manager.

Section 5: Product Control

This section covers:
• Product design and development, including review of HACCP, production trials, and
assessment of shelf-life.
• Product labelling: this involves ensuring that labels meet legal requirements and that
product claims (e.g. reduced sugar) are fully validated
• Management of allergens: the risk assessments which are to be carried out to
determine the controls that need to be implemented and the information that needs
to be communicated to the consumer. Where claims are made, validation and
verification need to be undertaken.
• Product authenticity, claims, and chain of custody: sites need to undertake a
vulnerability risk assessment on all raw materials or raw material groups to assess
the potential for adulteration or substitution. The site needs to have access to sources
of information to inform the risk assessment which needs to include historical
evidence of substitution or adulteration, economic factors, ease of access to the
materials in the supply chain, sophistication of routine testing, and the nature of raw
materials. Where claims are made, for example MSC, halal, etc, current certification to
the relevant scheme needs to be demonstrated.
• Product packaging needs to be fit for use and comply with legal requirements.
Evidence needs to be available to demonstrate that the packaging supplier has been
made aware of any particular characteristics of the food e.g. high fat content, pH or
usage conditions for example cook by microwave.
• Section 5 also includes requirements around product release and testing.

Section 6: Process Control

There is a highlighted fundamental requirement aimed at reducing product recalls as a result of
an incorrect logo being applied to the product. During the audit the auditor will, where possible,
observe a product change-over. This section also includes requirements for:
• Quantity, weight, volume, and number control
• Calibration and control of monitoring devices

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Section 7: Personnel
This section includes requirements on the following:
• Training and competency assessment for staff and agency staff
• Personal hygiene rules
• Medical screening for employees, agency staff and visitors
• Requirements for protective clothing
Subscription to BRC Participate, the BRC’s online subscription service, which will provide sites
with access to all BRC Standards, guidance documents, and webinars. The website contains a
lot of useful materials to help sites prepare for certification. Some of the guidance documents
provide examples of how to set out the risk assessments required in the Standard.

Section 8: High-Risk, High-Care, and Ambient High-Care Production Risk Zones

The Standard identifies a number of different production risk zones within the processing and
storage facilities, with corresponding levels of hygiene and segregation to reduce the potential
for product contamination with pathogenic micro-organisms. The purpose of this section is to
assure that the site is able to demonstrate that production facilities and controls are suitable to
prevent pathogen contamination of products.
Where a site produces products that require handling in high-risk, high-care and/or ambient high-
care production facilities, all the relevant requirements from sections 1–7 of the Standard must
be fulfilled in addition to the requirements in this section.

Section 9: Requirements for Traded Products

Where a site purchases and sells food products that would normally fall within the scope of the
Standard and are stored at the site’s facilities, but which are not manufactured, further processed
or packed at the site being audited, the site’s management of these products shall be covered by
the requirements in this section, in the traded goods.
Issue 7 introduced a traded goods module for sites that store and sell food products that are not
manufactured, processed, or packed on site. Issue 8 has incorporated these requirements into the
main text of the Standard (section 9).
Section 9 will remain voluntary and any site with applicable products may opt into these
additional requirements to demonstrate to customers that good management practices relating
to traded products are in place. Sites wishing to be audited to section 9 should notify their
chosen certification body in advance of the audit.

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BRC GLOBAL STANDARD FOR FOOD SAFETY ISSUE 8
BRC FOOD ISSUE 8
AUDIT PROCESS
Issue 8 has been developed to specify the
food safety, quality, integrity, and operational
criteria required to be in place within a
food manufacturing organisation to fulfil
obligations with regards to legal compliance
and protection of the consumer. The format
and content of the Standard is designed to
allow an assessment of a company’s premises,
operational systems, and procedures by a
competent third party- the certification body-
against the requirements of the Standard.
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BRC Audit Standards
•
Learn: Visit the BRC Global Standards website, obtain a copy of the Standard, and
study it. You may find the Interpretation Guidelines useful.
• Review: Perform a self-assessment gap analysis, assemble and train a team, and
obtain consultancy if required.
• Prepare: Carry out risk assessments. Establish necessary control points, prepare pro
cedures, confirm site is capable of meeting BRC requirements and undertake internal
audits.
• Plan: Select and contact a certification body, arrange an optional pre-assessment
visit and implement any identified corrective actions.
• Audit & Certification: Arrange an audit visit, ensure staff are available and
preparations are made for the audit to be conducted. A non-conformity summary
is left with the site at the time of the audit. The site needs to respond to the
nonconformities. The auditor’s notes, full report and corrective action response
are reviewed, and the certification decision is made. The audit report and
certificate are uploaded to the BRC Directory. Sites provide their customers access
to their report and certificate via the Directory. Certified sites are also listed on
the BRC public directory.
• Maintain: Continue to meet requirements, arrange a new audit before expiry and
continue the development.
The latest issue of this BRC Global Standard focuses on:
• Encouraging development of product safety culture
• Expansion of the requirements for environmental monitoring to reflect the
increasing importance of this technique
• Encouraging sites to further develop systems for security and food defense
• Adding clarity to the requirements for high risk, high care and ambient high care
production risk zones
• Providing greater clarity for sites manufacturing pet food
• Ensuring global applicability and GFSI benchmarking. Issue 8 focuses the audit
towards the implementation of good manufacturing practices within production
• Increased emphasis on areas which usually have the highest rate of recalls and
withdrawals, such as labelling and packing. Issue 8 continues to highlight
management commitment and HACCP-based food safety programmes and
supporting quality management system
• Providing a greater confidence in the food safety management systems and
encouraging the development of a site’s wider food safety culture
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BRC GLOBAL STANDARD FOR FOOD SAFETY ISSUE 8

Audit Options
Food manufacturers can opt for full certification which involves an announced audit and a fully
unannounced audit. ADDITIONAL
• Announced audit: the site and the certification body agree the date of the MODULES
date of the audit in advance. Issue 8 maintains the principles
• Unannounced audit: the audit date is not communicated to the site in developed in Issue 7, to enable the
advance of the audit. incorporation of additional modules.
There has been an increasing interest in unannounced audits among specifiers during the These allow sites to elect to include
lifetime of Issue 7 as this has been seen to provide a greater confidence in the food safety additional requirements with their audit
management systems and encourage the development of a site’s wider food safety culture. to meet particular customer, regional or
The unannounced programme remains voluntary but provides added confidence in certification scheme needs and reduce the number
to customers and creates marketing benefits where sites achieve the top BRC grade of AA+. of site audits. BRC Global Standards
will continue to develop such modules
Changes to the Audit Requirements in response to market needs and make
these available via the website.
BRC Food Issue 8 sees the following changes within the audit requirements:
Food Safety Culture
•
Food safety culture is a fundamental factor in the management of product safety.
•
Although challenging to audit, it is important that food safety culture is considered
within a site and therefore within the requirements of the Standard.
• Sites shall plan to maintain and develop product safety and quality culture within the
business.

Reporting Issues
• Product safety is the responsibility of all staff – not just a select few.
• Therefore, all staff need to know how to report concerns and incidents.

HACCP/Food Safety Plan

• Some countries (e.g. the United States) have regulatory requirements that
incorporate all HACCP processes outlined by Codex Alimentarius but use different
terminology.
• Review wording for section 2 of the Standard on the HACCP Food Safety Plan to
ensure compatible in all countries and geographies.
• Sites are required to meet the requirements of the Standard - specific terminology
should not be an impediment to demonstrating compliance.

Printed or Electronic?
Standard permits both hard copy and electronic files, documents, and records – it is not
prescriptive. Where documents are stored in electronic form these shall also be stored securely
(e.g. with authorised access, control of amendments, or password protected) and backed up to
prevent loss.

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BRC GLOBAL STANDARD FOR FOOD SAFETY ISSUE 8

Internal Audits
Clause 3.4.1 amended to make sure that the safety management systems are being assessed in
depth at regular intervals – at least four audit dates per year.

Supplier Approval
• Safety, integrity, legality and quality of raw materials are fundamental to the site’s
operations.
• GFSI benchmarking
• All of the requirements are reviewed and updated to ensure rigorous control controls
of raw materials whilst maintaining practical application.

Outsourced & Subcontracted Processes

Definitions for outsourced processing are often confusing. It’s vital that food safety is
maintained throughout the whole production process. Statement of Intent is updated to ensure
clarity.

Incident Management
• The incident management plan and procedures must be capable of addressing all
types of incident.
• Effective communication is vital. Clause 3.11.1 is updated to include ‘failure of, or
attacks against, digital cyber security.’ Significant food safety incidents (including
product recalls & regulatory food safety non-conformity) must be communicated to
your certification body.

Product Security & Food Defense

• Rigorous food defense systems have gained renewed understanding and should
form an integral part of factory protocols.
• Procedures are adopted to assure the safety of raw materials and products from
malicious contamination or theft.
Threat (risk) assessment with actions (a plan) should be based on risk. Scope of the risk (threat)
assessment should be the same as the process flow diagram (clause 2.5) i.e. all stages when
product is under the management control of the site.

Environmental Monitoring
BRC Food Issue 8 introduces an important tool for identifying potential contamination risks.
Sites are to develop a rigorous monitoring programme, enabling timely corrective action before
product contamination occurs. Monitoring of all factory production areas as a minimum area
with open, ready-to-eat products. Risk-based programme should be developed, and pathogens,
spoilage organisms, and/or indicator organisms should be considered.

Pest Management
Requirements are amended from ‘control’ to ‘management’. Birds must not enter buildings or
roost in loading/unloading areas.

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BRC GLOBAL STANDARD FOR FOOD SAFETY ISSUE 8

Cooking Instructions
• Vital on pack information for consumers – consumers expect and need a consistently safe product
• Cooking instructions can affect Production Risk Zones:
- Where provided – i.e. not mandatory to have cooking instructions
- Fully validated instructions

Labels & Packing

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.
• ‘Change control’ is needed at goods receipt.
• Management of obsolete packaging is clarified.
• Onsite printing (e.g. date codes) needs to be controlled. Online verification equipment needs to be
tested.
• Vertical audit is to be extended to include a comparison of the label with specification and recipe
should form part of the audit.

Pet Food
Pet food is within the scope of the Standard-animal feed is not. GFSI benchmarking introduced three new
requirements for pet food (not applicable for human food).

Production Risk Zones

• Requirements remain largely unchanged from Issue 7 to Issue 8
• Equipment returned following maintenance
• Waste management
• Portable equipment
• Requirements have been relocated into a single, newly created, section of the Standard (section 8).
• Protocol and definitions reviewed and updated for increased clarity

Traded Products (formerly the traded goods module)

Issue 7 introduced a traded goods module for products that are stored onsite but not manufactured, processed
or packed onsite. Customers require clarity – are traded products onsite and have they been audited. This is now
Section 9 of the Standard.
• Provides clarity, accreditation and inclusion on the certificate.
• Section 9 is voluntary but opting out is considered an exclusion from scope.

Unannounced audits
The option 2 unannounced audit (two-part audit) has consistently proven to be unpopular, with very few sites
selecting this audit. It was therefore necessary to review the audit options.
•
The unannounced audit programme remains voluntary and sites can still continue to opt for an
announced or unannounced audit.
• Option 2 unannounced audits have been removed, simplifying the options to just announced or
unannounced.

Interim Reporting
• Following each audit an interim report shall be available on the BRC Directory within 10 calendar
days.
• Contents strictly limited to date of audit, details of the audit scope and the non-conformities found.
• Final audit report will still be available after 42 days – this is currently being designed.

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