Fresh Produce Free

Food
Safety
GLOBAL STANDARD
FOOD SAFETY ISSUE 8
FRESH PRODUCE
GUIDELINE
Food
Safety
GLOBAL STANDARD
FOOD SAFETY – ISSUE 8
GUIDELINE FOR
CATEGORY 5
FRESH PRODUCE
BRCGS 2018
LIABILITY
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BRCGS/FPC Guideline for Category 5 Fresh Produce and the terms of the disclaimer set out above shall be construed in
accordance with English law and shall be subject to the non-exclusive jurisdiction of the English Courts.
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For more information about BRCGS, contact: For more information about the FPC, contact:
BRCGS Fresh Produce Consortium

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7 Harp Lane Minerva Business Park
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Website: www.freshproduce.org.uk
The FPC is the UK trade association for the fresh produce and cut flower industry. Recognised as the voice of the UK industry,
FPC represents around 700 members including retailers, distributors, importers, wholesalers, processors, packers, food and
service companies and associated members.
WWW.BRCGLOBALSTANDARDS.COM
CONTENTS
Introduction2
PART I AUDIT PROTOCOL

Scope4
Duration and timing of the audit 6
Audit Options 6
Additional modules 8
PART II RELEVANT REQUIREMENTS OF THE GLOBAL

STANDARD FOR FOOD SAFETY EXPLAINED
1 Senior management commitment 11
2 The food safety plan – HACCP 13
3 Food safety and quality management system 15
4 Site standards 22
5 Product control 28
6 Process control 30
7 Personnel 31
8 High-risk, high-care and ambient high-care production risk zones 33
9 Requirements for traded products 33
APPENDICES
Appendix 1 Scope wording 35
Appendix 2 Root cause analysis 37
Appendix 3 Decision tree for metal detection 38
Appendix 4 Sources of further information 39
Appendix 5 Acknowledgement 41
WWW.BRCGLOBALSTANDARDS.COM 1
INTRODUCTION
The aim of this guideline is to provide assistance to packers of fresh produce covered under Category 5 of the Global Standard for
Food Safety (hereafter referred to as the Standard). Category 5 covers fruit, vegetables and nuts.
It does not specifically offer guidance for products covered by Category 6, ‘prepared fruit, vegetables and nuts’, consisting of
prepared/semi-processed fruit, vegetables and salads, including prepared ready-to-eat salads, coleslaws and frozen vegetables.
Whilst some of the simpler processing methods may be satisfied by this guideline, the notes have not specifically been written to
cover the more complicated preparation systems and do not cover all of the requirements for these types of production. For
example, the following requirements of the Standard may be appropriate to Category 6 products but are not covered by this
guideline:
• the requirements for high-care or high-risk production zones

• the controls and mechanisms required for Category 6 new product development
• shelf-life testing requirements, which are beyond those required for Category 5 products.
This guideline concentrates on areas which are of particular concern to the fresh produce industry and, wherever possible,
includes practical guidance and examples to assist the effective implementation of requirements and promote consistency of
interpretation. However, the examples are not exhaustive or exclusive and are provided to assist understanding of the principles
behind the requirements. Practices and controls shall always be pertinent to the situation, shall be able to withstand challenge by
an auditor and shall be in line with good industry practices.
The aim of these guidance notes is to aid individuals and companies involved in the certification process, to ensure that robust
systems and procedures which adequately meet the requirements of the Standard are in place. However, the practical
implementation of the Standard, and whether the resulting systems are deemed as conforming or non-conforming by the auditor
carrying out a BRC Global Standards audit, is an objective judgement, based on evidence collected and observations made
during the audit.
Guidance on the implementation of systems that are the same for manufacturers in other categories and industry sectors (for
example, the requirements for management commitment) is available in separate guidelines, and therefore such topics are not
specifically referred to in this document. Information can be found in the appropriate BRC Global Standards publications – for
example, in the Global Standard for Food Safety Interpretation Guideline.
2 WWW.BRCGLOBALSTANDARDS.COM
PART I
AUDIT
PROTOCOL
SCOPE
Scope wording 4
Extension to scope 4
Exclusions from scope 5
Product safety rationale 5
DURATION AND TIMING

OF THE AUDIT
AUDIT OPTIONS
Announced/unannounced audits 6
Seasonal production sites 7
Temporary packhouses 7
Field rigs 8
Relationships between head office and
satellite sites 8
ADDITIONAL MODULES 8
PART I
AUDIT PROTOCOL
SCOPE
Where packers are also growers, it will be common for the Standard to be implemented in conjunction with various good
agricultural practice (GAP) schemes. Whilst it is not the place of the Standard to determine where the scope of these GAP
schemes finishes, the point at which the Standard begins and ends is defined as follows:
• The Standard begins at the point where harvested goods enter the structure in which they will be placed into protective
customer packaging. Therefore, the actual growing of the product is beyond the scope of the Standard. The only exception is
the production of bean sprouts, which can be included providing there is no growing medium, no nutrient addition and no
agrochemical inputs to the growing operation. If the product is packed in field rigs, or in other non-permanent structures, then
that rig or structure is included in the scope of the Standard and the audit. The auditor will visit the rig or non-permanent
structure and assess both the fabric of the packing area and the activities of the personnel working there.
• The Standard ends at the point where the packed product leaves the site premises. The auditor will examine all procedures and
facilities throughout the whole process up to the dispatch of packed goods. The Standard does not cover storage and
distribution by third parties, as this is covered in the BRC Global Standard for Storage and Distribution.
The scope of certification, and therefore the scope of the audit, shall be agreed between the company and the certification body,
and must reflect the operations on site as accurately as possible. Certification shall include all products packed on site; any
specific exclusions require reasonable justification. It is not acceptable for certification to cover only specific products or specific
customers’ products. Where a number of products are processed and packed in a similar manner, the scope will be defined to
include all these products. Where differing seasonality means that not all of the products are being processed during the audit,
the scope can still include additional products where the process technology is the same and where records from the previous
season are available to be audited. Where process technologies are significantly different, a separate audit for this process may
be required (see below).
SCOPE WORDING
The scope wording must clearly reflect the activities on site. It is used to enable search functions within the company listing in the
BRC Global Standards Directory.
It is therefore necessary to use standard terminology and formats. The wording must generally be in the format of:
• the processes included (clearly establishing, for example, if this includes the inspection of field rigs)
• product grouping and examples of products within that group (where the site produces a single product such as apples, it may
be appropriate to include this specific product in the scope wording; however, where there are numerous different types of
product, these should be grouped by the type of product, such as citrus fruit, berries or root vegetables)
• the separate auditing of head office functions (see below).
For example: ‘The sorting, labelling and packing of brassicas (cauliflower, broccoli), including field rigs, Abbey Farm packhouse
and head office functions.’
Appendix 1 outlines details of the scope wording that must be used on certificates and audit reports.
EXTENSION TO SCOPE

Once certification has been granted, any new additional products or processes that are undertaken by the site which need to be
included in the scope of certification must be communicated to the certification body. The certification body must assess the
significance of the changes and decide whether a site visit is required. The supply of documentary evidence may be sufficient
where the extension is for new products handled in a similar way to existing products – for example, adding nectarines and
peaches to an existing scope for other stone fruit. However, where a significant new risk is introduced, a further partial audit (at
extra cost) will be necessary to ensure that these new processes have been:
• accurately described in procedures

• properly considered in the Hazard Analysis Critical Control Point (HACCP) plan
• fully and properly implemented.
Significant new risks could include the addition of:
• new processes, such as washing or mechanical grading; changing from manual to automated packing; introducing modified
atmosphere packing (MAP) or defined temperature storage
• new products which require completely different handling techniques, such as the addition of cherries to an apple packing site
• a nut-based product at a previously allergen-free site.
The additional visit must be completed before the new products or processes can be added to the certification scope. Any
non-conformities raised during this partial audit need to be closed out in the normal way, within 28 days, but will not affect the
grade of the certificate unless the practices observed by the auditor raise concerns such that a full audit is appropriate to re-
establish the validity of certification.
An extension visit report should be documented, but it does not need to be in the format of the full audit report. The visit report
should document the processes or products, including the controls in place, and confirm the effectiveness of these controls. A
new certificate will be issued, containing the updated scope which supersedes the existing certificate; however, audit due dates
and certificate expiry dates will remain unchanged.
EXCLUSIONS FROM SCOPE

Previous issues of the Standard have excluded traded (or factored) products (i.e. products that are not part-processed, packed or
sorted on site, but are bought in and sold on) from the scope. With Issue 8 there will be the opportunity to include the
management of traded products within the scope of the audit. The requirements for traded products are included in section 9 of
the Standard.
PRODUCT SAFETY RATIONALE

The inclusion of the product safety rationale (PSR) in the audit report aims to highlight and summarise the characteristics of the
product and production processes that make the final product safe for consumption. For example, the PSR for oranges could be
summarised as:
• Ambient, fresh fruit with natural acidity (pH<4), short shelf life (<5 days), post-harvest application of fungicide and wax
treatments.
For very simple products and processes, the PSR may be proportionally limited and is likely to be quite simple. For example, for
fresh potatoes:
• Ambient, short shelf-life product (<7 days).

It should be noted that the PSR represents the key safety features of the product. The content of the PSR will therefore form part of
the audit and the information on the controls will be covered in greater detail in the relevant parts of the audit report.
BRC Global Standards has published a full guide to PSR.
DURATION AND TIMING OF THE AUDIT
The Standard states that the duration of the audit is typically 2 days (8 hours/day). Often, however, fresh produce packing
operations are relatively simple processes. In these situations, a shorter duration may be suitable, but the auditor must fully justify
why the duration has been reduced. This evidence will be included within the audit report. Points to consider include:
• lack of processing – where only whole products are packed, with no trimming or cutting
• lack of washing – where there are no processes to render the raw material into a cleaner state for packing
• lack of weight declaration – where products are sold by count or as single items
• the use of central food safety and quality management systems on satellite packing sites where the central system has been
assessed separately.
There are also factors which can increase the duration of the audit. These include:
• the use of field rigs and/or temporary field packhouses

• a large or complex operation with a number of lines or packing operations
• a poorly prepared site (e.g. records are not easily accessible).
The plan for the audit day must be discussed between the company and the certification body prior to the audit to determine the
most appropriate timing. The audit must cover all relevant processes undertaken. Therefore, when agreeing the logistics of an
audit, consideration must be given to:
• what needs to be seen

• when this needs to be seen
• who from the company needs to be involved
• where these operations are located, allowing appropriate time for travel.
The company must provide comprehensive information to the certification body prior to the audit, to allow it to assess the
duration and timing of the audit and confirm the scope. This may include but is not limited to:
• the product types and where they are packed, e.g. field rigs or temporary packhouses
• the number of field rigs operating and where they are located
• the approximate size and location of the site
• an outline of the company structure, detailing any head office functions such as purchasing
• a summary of critical control points (CCPs)
• the process flow diagram
• a simple site plan and a description of the site and building fabrication
• a management organisational chart
• typical shift patterns
• the production schedule – for example, where production processes are not carried out each day
• any recent quality issues, withdrawals or customer complaints, and other relevant performance data
• an outline of any outsourced processes
• other certification schemes applicable to the site.
It is generally expected that 50% of the audit will be spent auditing production, site facilities, interviewing staff, observing
processes and reviewing the documentation in use in production areas. However, for smaller sites or those with simple
processes, this may not be applicable. As with the audit duration (see above), it may be necessary to reduce the proportion of
time spent in the production areas. However, this should remain as close to 50% as is practical and the auditor must fully justify
why the proportion of time spent in the production areas has been reduced. This justification will be documented in the audit
report.
AUDIT OPTIONS: ANNOUNCED/UNANNOUNCED

Audits may be announced or unannounced. The site can choose which of the two audit options it prefers (announced or
unannounced). However, sites should be aware that an increasing number of customers are asking their suppliers to select the
unannounced option.
For the fresh produce sector there are certain factors that must be kept in mind as they will have an impact on the planning and
success of an unannounced audit:.
• Seasonal production sites For those with very short seasons (as defined below), an unannounced audit may not be

feasible
• Temporary packhouses These need to be discussed with the certification body to ensure that they are included and
available when the unannounced audit takes place
• Field rigs These need to be discussed with the certification body to ensure that they are included and available when the
unannounced audit takes place
• Head offices Where a company operates several sites, but certain functions are carried out by a head office (such as
training and supplier auditing), arrangements will need to be made to ensure a complete audit, either by auditing the head
office prior to the other sites or by ensuring sufficient information is available to the site being audited. Full details on
completing multiple site audits of this type are given in Appendix 4 of the Standard.
SEASONAL PRODUCTION SITES

The Standard defines a seasonal production site as a place where a product is ‘harvested and processed on a site that is opened
specifically for the duration of the short term of that harvest (typically 12 weeks or less) during a 12-month cycle.’ Packhouses that
are open throughout the year, but pack seasonal products, are not considered to be seasonal production sites within this
definition.
For seasonal sites, the scheduling of audits needs to be carefully planned so that:
• certification does not lapse – where the product harvest is dictated by the weather and this affects the actual audit date (i.e. the
season is later than expected), there is no penalty for a delay to the audit, although justification for this delay must be included
in the report
• the site is in production – so that all of the requirements of the Standard can be assessed
• there is a minimum of one week’s production records for the auditor to review
• corrective actions can be closed out within 28 calendar days and therefore within the current season. In the event that the
harvest is unavoidably early (e.g. due to weather conditions) and, as a consequence, there are fewer than 28 calendar days
before the end of the season, it may not be possible to close out identified non-conformities before the end of the season. In
this situation, the same rules apply as for sites with very short seasons (see below).
The scope of the certification may include a variety of products where these can be ‘grouped’ because they have the same
processing systems. For example, the audit may be undertaken during the harvest of apricots, but certification could include
other stone fruits that are known to be packed at the site, e.g. the scope might be for apricots, peaches and nectarines. Where
products are packed during different seasons, the audit will take place during one season so that the auditor can assess the good
manufacturing requirements of the Standard. During the audit, the auditor will also review paperwork and/or traceability systems
associated with both the product currently in production and those produced in different seasons.
For packhouses in production for very short seasons (i.e. less than 4 weeks), it may not be possible to close out identified
non-conformities within the season. However, where major non-conformities are identified, these must be resolved before the
end of the season or within 28 calendar days of the audit if the site is to gain certification. Where minor non-conformities cannot
be closed out within the season, they may be addressed by the provision of a suitable action plan, accepted by the certification
body. These actions shall be addressed prior to the beginning of the next season and verified at the next audit. Any non-
conformities that are not adequately closed out by the next audit have the potential to be raised as non-conformities against
management commitment. This will apply whether the certificate has lapsed or not.
Where a site is awarded a Grade C or D, it is likely that the site will not be in production when the next audit would be due (normally
6 months later). In such circumstances, the next audit shall take place once production has started in the new season. In this
situation, the site may be required to agree a course of action with its customers, since it will not be certificated at the beginning of
the season. Certification will not be granted until the scheduled re-audit has taken place. Under no circumstances will the validity
of a certificate be extended.
It is particularly important that seasonal sites are well organised to ensure that systems are in place prior to start-up – for example,
pest control must be effective from Day 1 of operations. The systems shall include any internal audits completed prior to start-up.
TEMPORARY PACKHOUSES
Temporary packhouses may be constructed during the packing season. These packhouses, which are not permanently sited
and which are often constructed from textiles, shall still conform to the relevant requirements for building fabric and shall be
audited accordingly. The structure of these packhouses must be such that they do not put the products at risk of contamination.
FIELD RIGS
A field rig is any mobile unit within the growing field where fresh produce is harvested and packed directly into retail packaging.
Where fresh produce (e.g. cauliflowers) is packed directly into customer packaging on mobile field rigs without further work at the
packhouse, the company must provide details to the certification body of the typical number and location of the field rigs, so that
a relevant inspection can be scheduled. The audit will include at least one field rig per product type (i.e. where products have
similar characteristics and packing methods they may be considered as one product type for the purpose of this requirement, but
where products have very different characteristics or packing methods then examples of each type will be audited). Where a site
operates more than five rigs, good practice is to inspect √x field rigs (i.e. the square root of the number of field rigs operated by
the site). At the auditor’s discretion, further rigs may be assessed to ensure full compliance with the Standard. The choice of field
rig(s) must be made by the auditor.
Field rigs are audited if they are within the control of the packhouse, either by contract or ownership, as it is the packhouse that is
seeking certification. If a field rig is brought in by a farm and is under the farm’s sole control, then this is not in scope.
Field rigs must be treated as equipment and therefore audited against the equipment requirements, rather than the requirements
for building fabric. However, where lighting is supplied, the lighting requirements appropriate to buildings will apply. The field rig
must be deemed the ‘production area’ and all other requirements pertinent to the production area must apply (e.g. personnel
hygiene controls).
Field rigs can add significantly to the time needed to undertake the audit (because of numbers and/or location), and this must be
discussed with the certification body when booking the audit. Field rigs must also be discussed with the certification body when
the supplier is having an unannounced audit (see above).
If there is no rig present or operating when an unannounced audit takes place, this will not necessarily lead to a re-audit. If a rig is
present but not being used, the auditor will want to view. The auditor will ask to see records concerning the rig (e.g. training,
cleaning and operating procedures), the aim being to satisfy themselves that rigs are operated under the appropriate controls
and systems.
RELATIONSHIPS BETWEEN HEAD OFFICE AND SATELLITE SITES

Certification to the Standard is site-specific and the audit must cover all the requirements of the Standard. However, some
produce packers operate as satellite sites of a central head office or customer food safety and quality management system.
Audits of such operations may be carried out by one of the following two methods:
• The audit may be conducted at the packing site where the site has obtained all the relevant documentation, as well as ensuring
that head office personnel are available (either on or off site) during the audit to discuss issues.
• The auditor may visit the head office prior to visiting the packing site and audit those parts of the management system
controlled by the head office.
Full details of the requirements affecting both of these options are given in Appendix 4 of the Standard.
ADDITIONAL MODULES
Over time, alongside the Standard, a set of additional modules will be developed, which can be audited alongside the main audit.
These are designed to address concerns in particular geographies or for specific customers and to remove the need for these
additional requirements to be audited separately. Full information on available modules can be obtained from the BRC Global
Standards website.
PART II
RELEVANT
REQUIREMENTS
OF THE GLOBAL
STANDARD FOR
FOOD SAFETY
EXPLAINED
Note that the numbering of Part II has been aligned with the
Standard to make cross-referencing easier. The numbers
therefore do not follow sequentially.
1 SENIOR MANAGEMENT
COMMITMENT
1.1 Senior management commitment and
continual improvement 11
2 THE FOOD SAFETY

PLAN – HACCP
2.3 Describe the product – Codex
Alimentarius Step 2 13
2.4 Identify intended use – Codex
Alimentarius Step 3 13
2.7 List all potential hazards associated with
each process step, conduct a hazard
analysis and consider any measures to
control identified hazards – Codex
Alimentarius Step 6, Principle 1 13
3 FOOD SAFETY
AND QUALITY
MANAGEMENT SYSTEM
3.3 Record completion and maintenance 15
3.4 Internal audits 15
3.5 Supplier and raw material approval and
performance monitoring 15
3.6 Specifications 18
3.7 Corrective and preventive actions 19
3.8 Control of non-conforming product 19
3.9 Traceability 19
4 SITE STANDARDS 8 HIGH-RISK, HIGH-
4.2 Site security and food defence 22 CARE AND AMBIENT
4.4 Building fabric: raw material handling, HIGH-CARE
preparation, processing, packing and
storage areas 23
PRODUCTION RISK
4.5 Utilities – water, ice, air and other gases 23 ZONES 33
4.8 Staff facilities 23
4.9 Chemical and physical product 9 REQUIREMENTS FOR
contamination control: raw material TRADED PRODUCTS 33
handling, preparation, processing,
packing and storage areas 24
4.10 Foreign-body detection and removal
equipment25
4.11 Housekeeping and hygiene 25
4.14 Pest Management 25
4.16 Transport 27
5 PRODUCT CONTROL
5.1 Product design/development 28
5.6 Product inspection and laboratory
testing29
6 PROCESS CONTROL 30
7 PERSONNEL
7.1 Training: raw material handling,
storage areas 31
7.2 Personal hygiene: raw material handling,
storage areas 31
7.4 Protective clothing: employees or
visitors to production areas 31
Part II outlines those sections of the Standard that are of particular interest to the fresh produce industry. It is not intended to cover
all the clauses of the Standard – only those where additional clarification is required in the application of the clauses to the fresh
produce category. A full interpretation guideline which covers all the clauses of the Standard has been published separately and is
available from www.brcbookshop.com or on BRC Participate: www.brcparticipate.com
PART II
PART II RELEVANT REQUIREMENTS OF THE GLOBAL STANDARD FOR FOOD SAFETY EXPLAINED
RELEVANT REQUIREMENTS OF
THE GLOBAL STANDARD FOR
FOOD SAFETY EXPLAINED
1 SENIOR MANAGEMENT COMMITMENT
Adoption and successful implementation of the Standard requires the commitment of senior management to ensure that food
safety is part of the culture of the organisation and that support and resources are available.
Whilst all categories of food manufacturing need to ensure that the management commitments are applied consistently and
correctly, there are some particular considerations for fresh produce sites, which are examined in this section.
1.1 SENIOR MANAGEMENT COMMITMENT AND CONTINUAL IMPROVEMENT

1.1.2 FOOD SAFETY CULTURE – DEVELOPMENT PLAN
The site is required to define and implement a clear plan or programme for developing and improving its food safety culture. Such
a plan should be based on the nature of the organisation, and dependent on its size, seasonality and the overall aims it has
identified as important for its own company culture.
When developing a culture plan, fresh produce sites may wish to consider:
• the proportion of permanent staff compared with seasonal staff. If staff are employed only for a short, defined season (e.g. 12
weeks or less), then the activities may need to be different for permanent and seasonal staff. In this situation, a good induction
is vital, so that from the very beginning temporary staff understand the need to maintain food safety, and see this culture led by
the senior management and relevant throughout the organisation.
• different actions in and out of season. For example, out-of-season periods provide an opportunity for senior managers and
permanent staff to prepare for the new season, and to assess the effectiveness of previous activities.
1.1.3 OBJECTIVES
Senior management must set objectives concerning food safety and quality which help to achieve their stated policy. The
objectives must have targets which ensure continuous improvement and these must be communicated so that the relevant
individuals understand what is required. The setting of these objectives also enables the allocation of suitable budgets and
resources. Auditors will look for evidence that the objectives have been set and communicated to the appropriate staff.
Objectives should be measurable and targeted to a defined time period. Typical examples include:
• reducing customer complaints

• fewer non-conforming products
• reduction in audit failures – internal and external
• reduction in customer rejects or returns.
1.1.4 MANAGEMENT MEETINGS AND REVIEWS
Food The Standard requires that sites have a programme of management meetings and reviews. The aim of the meetings is to
ensure that there is a channel for food safety and quality issues to be raised and discussed at a management level within the
business. For permanent sites that produce products throughout the year, management meetings normally occur weekly or
monthly and the inclusion of safety, legality and quality as agenda items meets the requirements of the Standard. For seasonal
and temporary sites, it is assumed that the site is not operational ‘out of season’ and therefore weekly or monthly meetings would
not be valid during this period. However, the site must be able to demonstrate that meetings have taken place in a timely manner,
i.e. before the start of the season and at least monthly during the season.
A schedule for the meetings needs to be in place and evidence should be available (such as minutes) to demonstrate the
discussion of food safety issues.
Sites are also required to hold a management review meeting attended by the site’s senior management. The purpose of the
management review is to take an overview of the food safety systems, and to discuss what has been achieved, what progress has
been made against objectives, and to identify targets and areas for improvement. Seasonal and temporary sites will need to
consider the timing of these meetings so that they occur at appropriate points in the season, in order for actions, targets or
objectives to be completed within meaningful timescales. For example, some sites may find it necessary to have two
management meetings: one at the start of the season to set objectives for the forthcoming season, and one at the end of the
season when the season’s information can be assessed. Alternatively, a management meeting shortly after an external audit
allows any non-conformities to be included in the discussion and any relevant corrective actions to be introduced in a timely
fashion.
1.1.6 CONFIDENTIAL REPORTING SYSTEM (WHISTLEBLOWER SYSTEM)

From time to time, it may be necessary for individual staff to report hazards or non-conforming product anonymously and
confidentially (e.g. if a staff member felt that a genuine concern raised through other mechanisms, such as those covered in
clause 1.1.5, had not been adequately addressed). The Standard requires the site (or company) to have a system in place to
manage this.
The way this system is communicated to staff and the location of any information (e.g. reminders of the relevant telephone
number) are important as all staff need to have an understanding of, and access to, the reporting mechanisms. Packhouses,
offices and changing rooms are all obvious locations for such information to be displayed, but it should be noted that some
agency staff or field workers may not visit these areas as part of their role, and alternative arrangements may be needed. For
example, the system could form part of the induction training, or the employment agency could provide a confidential contact
number and then pass anonymised information to site management.
Seasonal sites will also need to consider the timing of any action. Appropriate action must be completed in a timely fashion;
however, if the site is out of season when the feedback is given, assuming that unsafe product has not been sold to customers,
preventive action for the next season may be the most appropriate way to address the concerns raised. Good practice is to
ensure that there is a way to communicate this to staff (so that they know that the concerns raised are not being ignored).
1.1.8 PROVISION OF TECHNICAL KNOWLEDGE AND INFORMATION

Food safety issues and legislative requirements are constantly changing and it is important that sites remain up to date, are able to
meet legislation and adapt their food safety systems to protect against new or emerging threats, whether they be microbiological,
geographical or threats to the authenticity of the material.
Authenticity is also important, with greater emphasis being placed on varieties and/or geographic origin. The Standard has a
section (section 5.4) on product authenticity, claims and chain of custody, which includes systems to prevent adulteration/
substitution. For the fresh produce industry this might manifest itself as substitution of a product with a similar-looking variety or
from a different source – so English premium apples may be substituted by apples from Poland, or tomatoes may be from Mexico
instead of Florida. What is appropriate in terms of control will obviously differ by commodity and supply chain, but typically the site
may need to consider audits, certificates of analysis, mass balance and product testing.
The company must be able to demonstrate that it maintains up-to-date knowledge of relevant legislation, scientific and technical
developments, and industry codes of practice. For example, information could include updates on:
• recent food-poisoning incidents. Examples from the past might have included incidents with cantaloupe melons in the USA
and/or bean sprouts in Europe
• changes in legislation, such as the latest amendments to EU legislation on approved plant protection products and maximum
residue levels (MRLs).
Updates can be obtained from a wide range of sources, such as trade associations, government websites, customers and
research organisations. Some examples of sources are given in Appendix 4.
The auditor will look for evidence of systematic checking and the process for ensuring that, where necessary, the information is
translated into action – for example, through inclusion in the HACCP process, or during the HACCP review.
2 THE FOOD SAFETY PLAN – HACCP
The Standard lays out the generally accepted approach to conducting an HACCP study based on Codex Alimentarius principles.
With Category 5 fresh produce, it is not envisioned that this study will be complex, due to the potential simplicity of the operations;
however, it must be conducted thoroughly. In particular, the site must consider that finished products may not receive further
processing or cooking. Although potentially less complex, the controls used in the fresh produce sector must reflect those
expected within any other sector of the food industry.
2.3 DESCRIBE THE PRODUCT – CODEX ALIMENTARIUS STEP 2

The description of the product is likely to be relatively short. However, the following should be included:
• country of origin
• description of the packaging system – this may include modified atmosphere, shrink wrap or a simple container
• treatment or processing – for example, whether products are washed, trimmed or ripened
• storage and distribution conditions (e.g. chilled, ambient)
• target shelf life under prescribed storage conditions to ensure that the product meets customer/consumer requirements (i.e.
which have been agreed with the customer and are usually based on quality considerations).
2.4 IDENTIFY INTENDED USE – CODEX ALIMENTARIUS STEP 3

The identification of the intended uses of the product should include:
• whether the product can be eaten raw, cooked or both

• instructions for use (such as customer storage, cooking or preparation)
• target customers (the use of the product is unlikely to be restricted – therefore, use by vulnerable groups such as young
children, allergy sufferers and the elderly shall be considered)
• consideration of all uses of the product (e.g. the use of citrus peel in cooking or consumption of potato skins)
• consideration of where there is a known alternative use for a product, including the potential for a customer or consumer to
misuse or mistreat it. For example, there may be temperature abuse in the chain (for example, between shop and home) or
consumers may assume items are pre-washed and eat them raw without further washing (even if the label says to wash, not
wash anyway, as can happen with fresh berries).
2.7 LIST ALL POTENTIAL HAZARDS ASSOCIATED WITH EACH PROCESS

STEP, CONDUCT A HAZARD ANALYSIS AND CONSIDER ANY MEASURES TO
CONTROL IDENTIFIED HAZARDS – CODEX ALIMENTARIUS STEP 6, PRINCIPLE 1
The HACCP study requires that all potential hazards are identified and documented.
For fresh produce, many of these potential hazards will be the same as for any other food manufacturer, such as the presence of
micro-organisms in incoming goods, microbiological contamination from equipment and personnel, and the potential for
foreign-body contamination and chemical contamination from equipment or non-food chemicals.
Physical contaminants, both from the site (e.g. plastic, metal or glass) and from the growing environment (e.g. stones, inedible
plant material and manure, compost or substrate) must be considered, since customers and consumers would not expect to
encounter these within the product pack, irrespective of whether they are considered a food safety risk.
Chemicals to consider include:
• those associated with raw materials (e.g. pesticide residues or mycotoxins) – controls should be in place to prevent legal or
safety limits being exceeded
• those used within the company premises (e.g. cleaning chemicals, oils or lubricants for machinery, and pest control products)
• chemicals directly associated with the production or packing processes, including post-harvest treatments (e.g. fungicide
treatments, waxes or processing aids)
• water used for irrigation, cooling, washing or the preparation of plant protection products.
The potential for allergen cross-contamination must be considered. This includes, for example, the presence of:
• peanuts
• tree nuts
• celery and celeriac
• mustard seeds
• sesame seeds
• lupin seeds.
Other allergenic products/ingredients may need to be considered in line with the legislation in the country of sale.
The HACCP study should also consider any relevant product-specific characteristics or requirements (e.g. the sensitivity of
potatoes to light).
The hazard analysis may show that many, if not all, potential hazards are controlled through prerequisite programmes. For
example, using only approved suppliers certificated to a recognised GAP scheme will help to manage pesticide residues.
If there are any points where a hazard may reach unacceptable limits (e.g. exceeding legislative or safety levels), these will be
critical control points (CCPs) unless there is another process which reduces the hazard to acceptable levels. Where CCPs are
established (e.g. the use of post-harvest treatments or controlled storage conditions), then the critical limit(s) must be specified.
These may be in the form of minimum and maximum values, or a range of values that are acceptable, and may include a margin of
safety beyond any legal requirement.
Documented evidence must be available showing how the CCPs have been validated, to ensure that the CCPs control, reduce or
eliminate the hazard to the specified limit. A documented monitoring programme consisting of a set of planned checks must be
instigated to ensure that these critical limits are not exceeded.
Relevant staff must be trained in the procedures for the management and monitoring of CCPs.
A corrective action plan must be in place to ensure that any implicated products (i.e. those found to be outside the critical limits)
are handled appropriately (e.g. recorded destruction of the quantity of product by a licensed waste removal contractor).
Procedures to verify the safety and legality of produce packed subsequent to the implementation of corrective actions are also
required.
3 FOOD SAFETY AND QUALITY MANAGEMENT SYSTEM
3.3 RECORD COMPLETION AND MAINTENANCE
Records may be called upon to demonstrate the integrity or legality of the product and must therefore be kept for a period of not
less than the indicated shelf life plus 1 year (see clause 3.3.2). Additional retention time may be required by legislation, by
customers, by the requirements of a GAP scheme (e.g. GlobalG.A.P. requires records to be retained for a minimum of 3 years) or
because of the nature of the product (e.g. extension beyond the normal shelf life by customer freezing).
3.4 INTERNAL AUDITS

The site needs to establish the scope of the internal audit programme, which should cover all the systems and processes in
operation at the site and, therefore, cover all the requirements of the Standard as appropriate for a Category 5 site (the Standard
provides guidance on the minimum expectations for the scope of the internal audit programme). Field rigs and temporary
packhouses must be included in the scope of the internal audit programme.
The site must evaluate the risk inherent in each area and determine the frequency of audits accordingly. For example, the site
should consider the consequences if the system, or compliance with it, is inadequate, and shortcomings are not identified in a
timely manner. Frequency may also be influenced by known issues within the company, best practice or customer requirements.
The site must therefore have a schedule or programme of internal audits to ensure that individual sections of the process,
documentation or production are scheduled for different, predefined audit dates.
It is worth noting that a once-a-year check against all the requirements of the Standard may be of value as a gap analysis when
preparing for an audit; however, it is insufficient to cover the full requirements of an internal audit programme as it will not provide
the depth of assessment or level of confidence required. The Standard therefore requires a minimum of 4 different audit dates
within the internal audit programme. It is not expected that each of the internal audits within the programme will cover all aspects
of the Standard. Each date may be used to audit different aspects of the site’s systems, providing all aspects are covered at least
once within the annual programme.
For seasonal production, particularly when the season is very short (e.g. 4 weeks or less), the site must have in place a system for
the management of start-up processes. The site is not expected to complete a series of internal audits when the site is not
operating; however, internal audits are expected to start before the season commences to ensure that the site is ready to start
production. For example, the HACCP programme should be audited to ensure that it is up to date and appropriate for the
forthcoming production; that hygiene and fabrication are correct; and that staff are appropriately trained. The remaining areas of
the internal audit programme should be covered throughout the season. Evidence of this ‘pre-start internal auditing’ must be
demonstrable (i.e. it should be documented and available during the audit).
In addition to the internal audit programme, the site will need to introduce a schedule of documented inspections to ensure that
the factory environment and processing equipment are maintained in a suitable condition. These inspections are different from
the internal audit programme, as rather than examining practices against documented procedures, these are hygiene- and
fabrication-based inspections to assess whether the quality and suitability of cleaning, equipment, building fabrication and
personal hygiene are of an appropriate standard.
The frequency of the inspections should be based on risk, but will be no less than once per month during the season.
3.5 SUPPLIER AND RAW MATERIAL APPROVAL AND PERFORMANCE

MONITORING
3.5.1 MANAGEMENT OF SUPPLIERS OF RAW MATERIALS AND PACKAGING
A controlled raw material sourcing procedure must be in place to ensure the safety, legality and quality of raw materials – and,
therefore, that finished products are not compromised.
Many fresh produce lines have minimal processing and consequently little opportunity for the process to change the parameters
affecting the safety or legality of the finished products. A robust and rigorous raw material and supplier checking process is
therefore particularly pertinent. Good practice is for the process to consider the complete production and supply chain to the
point of receipt at the factory, from growing, harvesting, storage and then distribution to the packing house.
3.5.1.1 Raw material risk assessment
All raw materials must be subjected to a documented assessment of their inherent risk. This may form part of the HACCP plan;
however, as this is an important starting point for the production of safe food, it needs to be sufficiently detailed. The assessment
may be of individual products or, where a number of raw materials share the same characteristics and likely risks, these may be
grouped together – for example, different types of stone fruit originating from the same farm. However, before grouping materials,
it is important to consider whether any of the products have a specific risk that is not common to the other items in the group.
The risk assessment must consider the potential for:
• allergen contamination, including other allergens handled by the grower or site, and allergenic plants used in crop rotation or
those planted in field margins
• foreign-body risks
• microbiological contamination
• chemical contamination
• radiological contamination (e.g. resulting from growing crops in contaminated ground)
and may therefore need to include:
• known hazards associated with the raw material (e.g. mycotoxins, pesticide residues, micro-organisms or heavy metals);
access to up-to-date reference information and an awareness of emerging food issues are essential to ensure all known risks
are assessed
• whether the product is fresh or has come out of storage (e.g. controlled-atmosphere storage of apples)
• consumer use of the ingredient (e.g. is the customer required to cook the product or will it be consumed raw?)
• the nature of the supplier, including historical evidence concerning the supplier and the raw material
• geographic origins (products from particular origins may carry a greater risk because of less stringent local legal requirements/
enforcement or a less developed food safety culture)
• customer or legislative requirements (e.g. pesticide maximum residue levels (MRLs) in the country of sale)
• the potential for climatic conditions to affect product safety, for example:
• flooding can introduce new waterborne hazards to growing crops
• drought may necessitate using alternative sources of water, the quality of which needs to be understood
• unusually hot or cold weather can affect pesticide harvest intervals
• extreme weather can increase susceptibility to plant diseases or mycotoxin formation.
There are a range of tools that can assist with risk assessment and the evaluation of hazards (e.g. quadrant graphs, scoring
systems, logic tables or decision trees). The outcomes of these activities must be considered when assessing the requirements
for supplier approval and for raw material monitoring and acceptance procedures.
3.5.1.2 Documented supplier approval system

Within the food industry, the packer and grower may have a close relationship throughout the growing season – for example,
when the packer is purchasing the whole crop. Where the packer has an input into the growing phase of the crop, demonstration
of ongoing supplier assessment may be achieved via technical input (e.g. regular agronomist visits) throughout the growing
season. This input aims to ensure that the growing crop meets requirements, particularly in terms of pesticide residue levels. The
control must be documented.
Where pesticide MRLs have not been identified as a CCP, controlled sourcing is particularly critical. Evidence of control may
include the company confirming the suppliers’ certification to a GAP scheme or through a documented review of:
• the qualifications of agronomists and advisers

• the competence of pesticide applicators
• the legality and appropriateness of chemicals used
• compliance with harvest intervals and spray intervals.
For example, certification to GlobalG.A.P. will include checks on:
• packing on farm and in the field

• the auditor’s qualifications
• the competence of pesticide applicators
• compliance with pre-harvest intervals
• agreed pesticides that can be used
• spray records.
A site would not be expected to duplicate the checks that are completed as part of certification to a GFSI-benchmarked scheme.
Supplier/grower approval may also include assessments of:
• the company’s historical experience of the supplier

• a customer’s nomination
• criteria such as the provision of products meeting the agreed specification, of acceptable quality, supplied in the right quantity
and on time.
Where claims are made (e.g. for organic or GlobalG.A.P. products), there should be a particular focus on the raw material claims to
ensure that the supplier’s control systems are appropriate. Checks on certification status to the appropriate third-party scheme
are important and the Standard now requires sites to ensure that where a supplier’s certification is used as part of the supplier
approval decision, the site confirms the validity of the certificate (e.g. by checking the certification scheme’s database of
certificated companies) and that the scope of certification includes the products being purchased.
3.5.1.3 Ongoing supplier monitoring

Where different departments are involved in the approval and monitoring systems (e.g. a head office or other sections of the
site technical team), a linked process must demonstrate the responsibilities of each team and how these teams work together
to operate the system. Small growers/packers who pack only their own produce will not have a produce supply programme.
3.5.1.4 Approved suppliers list

The site is required to have an up-to-date list of approved suppliers that is readily available to relevant staff such as buyers or
goods receipt personnel. Good practice is to ensure newly approved suppliers are added and obsolete details removed in a
timely manner.
3.5.1.5 Purchasing from companies that are not the manufacturer, processor or consolidator
Where products (including primary packaging) are purchased from companies that are not the manufacturer, packer or
consolidator (e.g. purchased from an agent, broker or wholesaler), the site must know the identity of the last company that
completed such a process (e.g. the grower(s), farmer(s) or, where bought in bulk, the last place of consolidation).
Information to enable the approval process (see clause 3.5.1.2) to take place can be obtained directly from the supplier or from
the agent/broker/wholesaler. Where the agent/broker/wholesaler is certificated to either the:
• BRC Global Standard for Agents and Brokers

• wholesale module of the BRC Global Standard for Storage and Distribution
• BRC Global Standard for Food Safety, including section 9 (traded products requirements)
the requirement to obtain information on the approval process does not apply as this is covered by these certifications.
However, this does not remove the need for the site to know the grower’s/farmer’s identity or the last place of consolidation.
In the case of products bought from auctions, every effort must be made to ensure that their provenance is known (i.e. the
point before the auction, which may be a grower/farmer or last place of consolidation) to ensure that the product is traceable
and meets the requirements (e.g. pesticide applications).
New suppliers should be reviewed after a specific trial period. The length of the trial is likely to be supplier-dependent, as it is
difficult to specify a timeframe pertinent to all situations. For example, consideration should be given to the supply period
(where the produce is seasonal) or after 2 months for regular deliveries.
It should be noted that the requirements for supplier and raw material approval also apply to packaging and the same
methods for assessment can be applied.
3.5.1.7 Exceptions procedure
The site must have documented procedures that define how exceptions are handled (e.g. when products need to be
purchased from unapproved suppliers because of supply or crop failure, or when the use of a specific supplier is a customer
requirement). This may include controls such as identification of suppliers with GAP certifications, details of the pesticides
used that season, consideration of sample analysis, or an increase in the number of incoming product checks.
The Standard expects that product testing will be used to verify product quality and safety of products purchased in these
exceptional circumstances.
3.5.2 RAW MATERIAL AND PACKAGING ACCEPTANCE, MONITORING AND MANAGEMENT PROCEDURES
Ongoing acceptance of the raw materials (including packaging) must be based on risk assessment and include a monitoring
programme with clear criteria for the acceptance of each batch. These criteria could include:
• visual inspection on receipt

• checking the accuracy of the product order to ensure that the correct varieties, grades and quantities have been delivered
• product sampling and testing to a defined sampling plan (e.g. for pesticide residues or mycotoxins)
• certificates of analysis provided by the supplier
• validation of certification to a GAP scheme.
3.5.4 MANAGEMENT OF OUTSOURCED PROCESSING
Outsourced processing is defined by the Standard as an intermediate production process or step in the manufacture of a product
that is completed at another company or site. It should be noted that contract packing is outside the scope of these clauses as it is
not an intermediate step in the process and product may not be returned to the site.
To cope with seasonal volumes, some operations may be outsourced for a short period. When such outsourced operations have
no formal contract, the auditor will still expect to see information on the agreed specification and volumes to be supplied.
3.6 SPECIFICATIONS
Companies must ensure that specifications for raw materials, packaging and finished products (or generic groups of finished
products) are available and adequately detailed. This includes any product or service that could affect the integrity of the finished
product.
Legislative standards (such as the class rules defined by European marketing standards) are often used as raw material and
finished product specifications within the produce industry, unless the product is being bought for a specific customer that has its
own specification.
Because of the nature of the fresh produce industry, specifications may change over the season to reflect the changes in crops.
Companies must have a system in place to ensure that they are packing to the most up-to-date specifications.
3.6.1 SPECIFICATIONS FOR RAW MATERIALS AND PACKAGING

The site must be assured of the safety and quality of the products purchased. This includes raw materials, packaging and any
service that can impact food safety – for example, the water and cleaning chemicals used, as well as services such as pest
control, cleaning or final product distribution. See also section 4.5 of the Standard that deals with utilities used within the
production and storage areas.
Specifications for raw materials must include sufficient detail, with defined limits, on the relevant attributes of the material that may
affect the quality or safety of the final products (e.g. chemical, microbiological or physical limits). For example, on the use of
pesticides, the specification may need to include a list of agreed pesticides that can be used (proposed pesticide undertaking),
together with spray application records/harvest intervals to demonstrate that pesticide residues are managed (i.e. that
consideration has been given to the applications and MRLs relevant to the country of sale and, where appropriate, to customer-
specified limits). Alternatively, if a positive listing cannot be specified, then the pesticides that cannot be used could be listed (e.g.
referring to the legislative banned/non-approved lists or customer requirements).
Where raw materials are not purchased to a specification (for example, where the whole crop is purchased from the grower),
details such as quantities and grading may be included within contracts between the parties.
3.6.2 FINISHED PRODUCT SPECIFICATIONS
A finished product specification must exist for all products covered under the certification scope (i.e. for both customer and
branded products) to ensure that the required legislative and customer expectations are achieved. Customer specifications may
need to conform to a specified format and system requirements.
Where a customer has not defined the format or content of the specification, an internal document must be in place, setting
appropriate parameters to meet legal requirements and assist the customer in safe usage of the product.
Specifications should also include details of packaging.
Customer requirements may include limits for other contaminants, such as microbiological criteria or levels of heavy metals, and
these additional requirements must be included in the specifications.
Production line staff may not require the full specifications for their operations and other options such as simple spreadsheets
highlighting differences in specifications, or photographic standards, may be appropriate (e.g. during processing or grading
activities).
3.7 CORRECTIVE AND PREVENTIVE ACTIONS

An important part of any product safety management system is the use of corrective and preventive actions to ensure that safety
of products, and therefore consumers, is not compromised by any non-conformity, incident or non-conforming product at the
site.
Corrective action is defined as ‘action to eliminate the cause of a detected non-conformity’. It is therefore the action taken to
immediately correct an identified concern.
Preventive action is defined as ‘action to eliminate the fundamental, underlying cause (root cause) of a detected non-conformity
and prevent recurrence’. To identify this underlying cause the site will need to complete a root cause analysis.
Issue 8 introduces a new clause (3.7.3) which requires sites to have a documented procedure for the completion of root cause
analysis. At a minimum, sites must conduct a root cause analysis when trend analysis shows a significant increase in a type of
non-conformity or when a non-conformity places the safety, legality or quality of a product at risk. Further guidance on root cause
analysis is given in Appendix 2 of this guideline.
3.8 CONTROL OF NON-CONFORMING PRODUCT

The control of non-conforming product must be described in a documented procedure. This document should clearly explain all
aspects of the management of non-conforming products, including, for example, the isolation and disposal of unsafe products.
It should be noted that, where a product does not meet a specific customer’s quality requirements, this does not mean that the
product cannot be marketed elsewhere, providing that the product does not breach safety limits or legislative requirements.
3.9 TRACEABILITY
3.9.2 IDENTIFICATION OF RAW MATERIALS AND FINISHED PRODUCT
As well as being a legislative requirement, traceability is a risk management tool, allowing food businesses and authorities to
withdraw or recall products that have been identified as unsafe. The level of traceability (beyond the legal requirements) will
normally be decided between the company and its customers, but the system used must be capable of:
• identifying the suppliers* of all lots/batches of raw materials

• linking the batch codes of all raw materials through production to finished product codes
• identifying the customers to which each batch of finished product has been supplied.
The system must ensure that products supplied to customers are adequately labelled or identified to facilitate traceability. This
must include products sold loose to the final consumer (e.g. through the use of labels on transit or bulk packaging or through
documents associated with the lot). Traceability details need to be retained in a format that allows access in a timely manner.
*In this context it is worth remembering that the glossary to the Standard (Appendix 9) defines a supplier as ‘the person, firm,
company or other entity to which a site’s purchase order is addressed’. The Standard therefore expects full traceability one stage
‘forwards’, one stage ‘backwards’ (see section 3.9.3) and throughout the production process.
The limitations of any traceability system must be recognised, as can be demonstrated by the problems associated with:
• bulk storage
• consolidation of different batches of raw material
• where traceability identifies only an agent, a number of producers or a number of fields/orchards as the source for a given
batch or lot.
For example, in the event of a problem, a shipment of oranges made up of a variety of farm sources and harvest dates would have
to be treated as a single ‘lot’ if additional traceability was not available that allowed implicated and non-implicated product to be
distinguished. In this situation, the whole shipment would need to be treated as implicated and treated accordingly (e.g.
withdrawn or recalled). Similarly, mixing of batches/lots during packing will require any subsequent action to be applied to the
larger lot or consignment.
The traceability system must include packaging and processing aids (e.g. the use of post-harvest waxes) and must be capable of
tracing a batch of goods to the relevant test results (e.g. batches of nuts should link to the aflatoxin test certificates).
3.9.3 TESTS OF THE TRACEABILITY SYSTEM

The site must undertake a traceability test at least annually. The traceability system should operate both ‘forwards’ and
‘backwards’; therefore the system should be tested in both directions. For example, a batch of raw material should be selected
and traced forwards to show in which finished product batches it was used, and a finished product should also be selected and
traced backwards to show the raw material batch codes used to produce it. The tests should include identification of which
customers received the products and which suppliers provided the raw materials.
Traceability to identify the suppliers used and how much was in the specific batch/consignment should be achievable within 4
hours. It is not intended that supplementary information, such as a full mass balance test, would always be achievable within 4
hours. Where a site chooses to include additional supply chain information in its traceability tests, such as spray records or transit
information, or to demonstrate compliance with clause 3.5.1.6, this may not be available within the 4-hour time limit (e.g. imported
products may originate from areas where differences in the time zones delay the receipt of this level of detail), but systems should
be in place to ensure that this additional documentation is made available in a timely manner.
During the Standard audit, the auditor will ask the site to complete a full vertical audit. At a minimum this will include the traceability
of a specific batch of product or ingredient through the site’s production, processing and distribution, and review of the site’s
records related to the product or ingredient. Records will include, for example, supplier approval, goods receipt, process records
such as temperature monitoring, metal detector checks and dispatch records. However, the vertical audit is not expected to
include records that would be held only at other points in the supply chain (e.g. the raw material supplier’s processing records or
farm records).
Tests of the traceability systems must include a quantity check or mass balance test. The mass balance test should occur at least
annually for products without a provenance or assured status claim. Where there is a product claim, however, the test should be
undertaken at least every 6 months. If, under a particular scheme, there is a requirement for more frequent mass balance
exercises, that scheme’s requirements must be met. For example, GlobalG.A.P. certification requires mass balance checks at
least every 3 months.
The objective is to test the systems and, where necessary, make improvements to the recording of information to allow claims to
be substantiated should they be challenged by a customer or legal authority. Where very different traceability systems are used
(e.g. in a large or multi-product site), more than one mass balance exercise may be required to ensure that all the systems are
working effectively. However, where a site has multiple claims, it is not necessary for every claim to be mass-balance-tested every
6 months; it is acceptable to choose a representative selection for testing. In this situation, good practice would be to choose
different claims or products each time the test is conducted. The use of a third-party mass balance exercise (e.g. by an organic
certifier or by the Fairtrade Foundation) would be acceptable evidence of a test, providing that records of the test, the results and
evidence of any necessary improvements made as a result of the test are maintained.
The mass balance test is defined as a reconciliation of the amount of incoming raw material against the amount used in the
resulting finished products, taking into account process waste and rework.
Yield +
Raw Finished
waste +
materials products
rework
The mass balance exercise is usually undertaken as follows:
• Select a batch or lot code of a specific raw material.

• Identify the quantity of raw material supplied under that batch code.
• Identify all the final products in which the raw material is used.
• Use production schedules and batch make-up sheets to calculate the quantities of the selected batch used in each product,
including any material that is known to go to waste.
• Calculate the quantity of any unused part of the batch in the warehouse (if any remains).
• Reconcile the quantity delivered against the amounts used plus residual unused stock.
The mass balance exercise must be carried out both forwards and backwards and therefore will need to be repeated, starting with
a specific batch of finished product and tracing back to the relevant sources of raw material.
Worked example
20,000 kg of apples were purchased. These were packed over the next 3 days into unit packs of either 4 apples in a tray or 10 per
bag. The average weight of an apple is known to be 150 g (i.e. 0.15 kg). Production records show that the following quantities
were packed:
Day 1 10,000 × 4-pack + 2,000 × 10-bags Waste = 100 kg

Day 2 7,000 × 4-pack + 300 × 10-bags Waste = 330 kg
Day 3 10,000 × 4-pack + 4,400 × 10-bags Waste = 400 kg
However, the batch was finished partway through Day 3 and another batch of apples was used to complete the order. Therefore,
on Day 3, only the 4-packs were filled with the specific batch being investigated.
Calculations
4-PACKS 10-BAGS WASTE TOTAL

Day 1 10,000 × 4 × 0.15 = 6,000 kg 2,000 × 10 × 0.15 = 3,000 kg 100 kg 9,100 kg
Day 2 7,000 × 4 × 0.15 = 4,200 kg 300 × 10 × 0.15 = 450 kg 330 kg 4,980 kg
Day 3 10,000 x 4 × 0.15 = 6,000 kg 0 (6,600 kg used from a different batch) 400 kg 6,400 kg
Total 20,480 kg
Therefore, the approximate total used was 20,480 kg, compared with an original batch size of 20,000 kg.
It is unlikely that the mass balance test will account for all materials with 100% accuracy. However, the company must justify any
discrepancies and demonstrate understanding of the nature of the variance. This may be inherent in the product characteristics
– for example, the dehydration of fresh ingredients or portion variances. The principle is to ensure that the traceability system is
effective.
In this context it is worth remembering that the glossary to the Standard (Appendix 9) defines a supplier as ‘the person, firm,
company or other entity to which a site’s purchase order is addressed’. The Standard therefore expects full traceability one stage
‘forwards’, one stage ‘backwards’ (see section 3.9.3) and throughout the production process.
4 SITE STANDARDS
Although producers may be located on farms or in large agricultural areas, maintenance of the external area must be considered
to ensure that it does not constitute a contamination hazard to the finished product.
Local activities and the site environment must be considered to ensure that they do not have an adverse impact on finished
product integrity. For example:
• derelict buildings, rubbish dumps, wasteland etc. should not become a harbourage for rodents. Where these hazards occur
on land that does not belong to the site, consideration should be given to the use of additional monitoring or control measures
to ensure that they do not adversely affect the site or product
• adjacent water courses at risk of flooding
• neighbouring companies and the nature of their business (e.g. presenting air or odour taint potential)
• livestock farming in adjacent areas.
The external area, including storage areas, must be kept in good order. For example, where large volumes of equipment such as
crates are stored, they should not harbour pests.
Appropriate measures must therefore be in place, and these must be regularly reviewed to ensure that they are continually
effective. This may, for example, include specific points on regular audit schedules to ensure that checks are undertaken and
corrective actions are implemented.
All external traffic routes under the control of the company must be suitably surfaced and maintained in good order. It is
recognised that traffic routes may have a variety of surfaces, and the risk of product contamination will also be influenced by other
factors, such as weather conditions. The aim of these requirements is for a risk assessment to be completed, to ensure that
products are not placed at risk of contamination through the inappropriate surfacing of routes where products are transferred.
Where the risk assessment indicates that action is needed to reduce this risk, this action may take the form of a combination of
procedures, such as the suitable protection of products whilst in transit or the wash-down of transit vessels prior to entering the
packhouse.
The fabrication of the site must be appropriate to the requirements of the process and sufficient to minimise the potential for
contamination of the product and the ingress of pests.
4.2 SITE SECURITY AND FOOD DEFENCE

The need for companies to have rigorous product security and food defence systems to prevent malicious contamination has
gained renewed understanding since the publication of Issue 7. To this end the requirements have been reviewed and more clarity
has been added to section 4.2.
The company must undertake an assessment (threat assessment) of the potential risks to products from any deliberate attempt to
inflict contamination to damage. This will include consideration of both internal (e.g. from staff) and external threats (an individual
or organisation that has a working relationship with the company). The output will be a documented threat assessment plan which
includes the identified risks and the controls to mitigate those risks.
Although fresh produce sites may span open areas where it is more difficult to control access than at a fenced building within an
industrial area, access to the site must be controlled by including clearly identified access points where visitors can be directed to
a reception area. Here a reporting procedure must be in place for visitors and contractors, to ensure that they are made aware of
site rules and can be issued with protective clothing.
Staff must be aware of company security, and be encouraged to make enquiries or report unknown persons observed on site.
Whilst the company cannot control access to fields by non-authorised personnel (e.g. where a rig or temporary packhouse is in
operation), access to the packing and storage facilities must be appropriately controlled. This is particularly important where staff
play a vital role in ensuring the security of a large site. However, staff must not compromise their own personal safety and
suspicious activities must always be referred to relevant management or security staff.
Note: The above summarises the key points that apply only to fresh produce sites. Companies will need to review the full details of
the requirements in the Standard to ensure they are aware of all the activities required for food defence.
4.4 BUILDING FABRIC: RAW MATERIAL HANDLING, PREPARATION,
PROCESSING, PACKING AND STORAGE AREAS
The walls in temporary packhouses must conform to the Standard’s requirements for walls even where they are made of textile
fabric. The internal surfaces must be clean, appropriate to the process and product, and appropriate for the prevailing weather
conditions.
The Standard requires that drainage must be designed and maintained to ensure that product contamination risks are minimised.
Produce packhouses where goods are brought in ‘dirty’ and washed before packing will often feature a segregated ‘dirty’ area
where the washing is undertaken before the goods are transferred to a ‘clean’ dry area where packing is completed. Therefore,
drainage within dirty wet areas must be designed, where possible, so that process waste water goes directly to drain.
Whilst there may not be doors in product reception areas, the facility must be appropriately designed to protect the product and
minimise potential contamination during packing operations.
Sufficient lighting must be provided for safe operation and the production of quality product. For the packing operation, this may
be provided artificially or by natural daylight. Where natural light is used, the working hours must be controlled to ensure that the
natural lighting is adequate.
4.5 UTILITIES – WATER, ICE, AIR AND OTHER GASES

Water used must be provided in sufficient quantities (e.g. for cleaning operations), pose no contamination risk (e.g. must be
potable) and conform to relevant legislation by being suitably treated or drawn from a mains supply.
Some sectors of the fresh produce industry use water to wash products. It is particularly important to ensure that the wash water
does not become a source of contamination – for example, through the use of chlorine or other sanitiser approved for food use,
which is monitored to ensure that it remains at the correct and effective concentration.
Where wash water is recycled, it is important that procedures and monitoring are in place that prevent products from being
contaminated by recycled water that is not of the appropriate standard (consideration should be given to potential micro-
organisms, chemical contaminants, foreign bodies and allergens)..
4.8 STAFF FACILITIES

Appropriate staff facilities such as restrooms, changing areas, toilets and storage must be provided to enable staff to adhere to
company policies (e.g. the correct storage of protective clothing and personal belongings), to ensure that the risk of product
contamination is kept to a minimum. This must include the provision of sufficient facilities to accommodate fluctuations in staff
numbers during peak production times (e.g. there should be sufficient facilities for use by seasonal and agency staff).
The location and design of facilities must be the subject of a risk assessment to ensure that they are adequate. For temporary
packhouses and field rigs this may be as simple as the provision of coat hooks in a ‘travelling’ restroom, vehicle or changing area
prior to entering toilet facilities.
Changing facilities must be provided to ensure that staff change their clothes away from the packing area (e.g. away from the field
rig or packing lines in a packhouse).
To prevent staff from bringing personal items into production and storage areas (where they could contribute to the risk of
foreign-body contamination), there must be sufficient and separate secure storage for staff belongings. For field-based workers
this may simply involve ensuring that staff leave personal belongings appropriately secured in the minibus travelling to the site. For
‘permanent packhouses’, suitable permanent facilities must be provided.
Hand-washing facilities must be provided prior to entry to the packhouse or field rig which conform to the requirements of the
Standard, including the provision of water, liquid soap, single-use towels or hand driers, water taps with hands-free operation and
instructions in appropriate languages. Where the hand-washing facilities are located away from the immediate entrance to the
packing area (e.g. in the toilet facilities), the flow of staff must be designed to ensure that staff are able to wash their hands prior to
entry into the packing area.
Toilet facilities must conform to the requirements of the Standard.
Smoking and eating must be adequately controlled to a level expected within all food manufacturing industries, i.e. with
designated areas provided to an acceptable standard of hygiene.
4.9 CHEMICAL AND PHYSICAL PRODUCT CONTAMINATION CONTROL: RAW
MATERIAL HANDLING, PREPARATION, PROCESSING, PACKING AND STORAGE
AREAS
The risk of foreign-body or chemical contamination must be minimised through the consideration of potential sources of risk and
the implementation of control procedures. This must be included within the HACCP food safety plan. Examples of sources of risk
include:
• sources of raw materials (e.g. the likelihood of contamination by soil, dead animals or insects)
• storage – potential contamination or damage from pests, chemicals, taint or handling
• processing – where potential contaminants can arise through personnel, equipment, materials and services (e.g. water used
for washing)
• hazards from the environment and building fabric
• hazards from maintenance, hygiene and cleaning operations.
4.9.1 CHEMICAL CONTROL
Non-food chemicals are a potential product contamination hazard and taint risk if they are not stored and handled correctly.
In addition to those chemicals common throughout the food industry (e.g. cleaning fluids, oils and lubricants), the company will
need to give particular attention to any post-harvest treatments that are used on site. For example:
• post-harvest fungicides and wax treatments

• the use of additives or processing aids
• the addition of chemicals such as chlorine to produce washes.
Specific consideration must be given to the safety and legislative requirements for the use and storage of these chemicals,
including that:
• they are suitable and approved for food use

• the site has documented procedures that ensure the product is used in accordance with the label instructions
• pesticides are stored safely (e.g. in a designated area which is located away from products and designed to prevent the
contamination of products)
• post-harvest treatments are officially registered or permitted for use on the product by the appropriate local or national
authority in the country of production and any use does not contravene the legislative requirements in the intended country of
sale. The site must be able to demonstrate that it remains up to date with the legislative requirements (e.g. by maintaining an
up-to-date list of substances that are used and their approval status). When deciding which chemicals to use, sites must also
consider their customer requirements and any limitations these introduce
• the maximum levels for each chemical are not exceeded. This will include both the maximum amounts that can be applied (i.e.
the maximum limits set on the label) and the potential for residues
• where the legislation in the country of sale (e.g. on maximum residue levels) is more restrictive than the legislation in the
country of production, the site must demonstrate that this has been managed (e.g. by management of the application regime
and/or additional product testing).
Where a site uses post-harvest chemicals, records of the applications must be maintained. Typically these will include:
• the application date

• the reason for the application (e.g. the pest or condition being treated)
• the type of treatment (e.g. spray, drench or gas)
• the product name (as per the label)
• the amount applied
• sign-off by the operator.
4.9.3 GLASS, BRITTLE PLASTIC, CERAMICS AND SIMILAR MATERIALS
The company must undertake an assessment of glass, hard plastic and other brittle items of equipment in the packhouse
environment. This assessment should cover all open product areas, and any areas where there is a risk of product or packaging
contamination. Wherever possible, these items should be removed. Where it is not possible to remove items, they must be
protected against breakage (e.g. by the use of adhesive plastic sheeting, reinforcement or shielding) and included on a register
for inspection purposes.
External glass components of vehicles which travel over growing crops (such as broken headlights, mirrors or windows) should
also be considered, as they represent a significant hazard.
4.9.5 WOOD
The use of wood within open product processing areas is not permitted except where it is a requirement of the process. Where
wood cannot be avoided, then procedures must be in place to:
• that the use of wood is covered by the HACCP assessment

• identify damaged items
• minimise the potential for contamination
• carry out regular checks to ensure that the wood is in good condition and clean.
The use of wooden containers for the transport of product to the packhouse is acceptable where suitable procedures are in place
to prevent the risk of wood or splinters contaminating the final product and where this does not present a risk of product spoilage.
The use of wooden pallets to transport product to the first processing step and for the storage of finished packed product is
acceptable.
4.10 FOREIGN-BODY DETECTION AND REMOVAL EQUIPMENT

4.10.3 METAL DETECTORS AND X-RAY EQUIPMENT
The Standard makes a general presumption that metal detection provides improved protection for customers and should
therefore form part of the food protection system of the site. There will, however, be situations where metal detection does not, on
the basis of a risk assessment, provide any significant additional protection for the consumer.
Where metal detectors are not used, a risk assessment must be available to justify the reasons why they are not required. Whilst
complaint levels are a factor in making a decision on the necessity for metal detection, this evidence alone will not be sufficient
justification that a metal detector is not required. Any justification for the absence of metal detection should be based on the
nature of the product, the risk to the consumer and alternative controls in place at the site. The absence of metal detection
equipment cannot be justified on the basis of cost.
BRC Global Standards has developed a decision tree (see Appendix 3) to provide guidance on defining where metal detectors
would be required and the circumstances where they might not. In all circumstances where products are manufactured to a
customer’s specification, sites must comply with any customer requirement for metal detection of their products. Where metal
detection is not used and the risk assessment has been accepted by the auditor, this will be noted in the audit report and the
justification and alternative controls described.
For example, it may be justified not to have metal detection equipment in potato bagging on the basis that the risk of foreign
bodies (particularly metal) is low because:
• little mechanical equipment is used

• no knives are used in the process
• washing within the packing process removes foreign bodies
• whole produce is unlikely to harbour contamination without suffering quality degradation picked up by visual inspection
• the product is ‘processed’ by the consumer (i.e. washed, peeled and cooked) before consumption.
In this example, the low risk of occurrence of a metallic foreign body and the low risk of severity may justify not using a metal
detector or X-ray equipment. However, the risk would be re-assessed if the process changed or included a greater likelihood of
contamination (e.g. a greater degree of automation).
4.11 HOUSEKEEPING AND HYGIENE

The site must be maintained to a defined level of cleanliness. Control of hygiene must be achieved through cleaning schedules
and policies that are based on risk assessment and appropriate to the product. This must be demonstrated through documented
and monitored systems.
Limits of acceptable and unacceptable cleaning performance must be defined. The limits need to be based on the risk, and this
should be used as the basis for assessing whether the cleaning undertaken is of an acceptable standard. Where the cleaning is
designed principally to provide a clean processing environment, an assessment by visual inspection may be sufficient.
However, where the cleaning is designed to ensure a sterile food contact surface or to ensure that traces of allergen have been
removed, then the level of acceptable cleaning may need to be based on routine measurement of the relevant micro-organisms or
allergens (see section 4.11.8 for details of the requirements for environmental monitoring).
The methods of cleaning themselves must not pose a risk of product contamination (e.g. from cleaning areas adjacent to open
products).
4.11.8 Environmental monitoring

The aim of the environmental monitoring programme is to identify any potential risks in the production and open-product
areas so that they can be appropriately managed and prevented from becoming the source of product contamination (which
could lead to non-conforming product, customer complaints or other incidents). An effective programme can, for example, be
used to:
• confirm the effectiveness of cleaning and hygiene activities and identify any areas that require corrective management
• prevent product contamination by acting as an ‘early warning’(identifying potential contamination from the site facilities before
it affects products).
The design and structure of this programme will depend on the nature of the products being handled and the potential
hazards associated with them. It is important that sites understand these risks and build their programmes appropriately. Sites
cannot ‘opt out’ of this requirement by determining that they have a low-risk product or environment; they should use the risk
assessment process (clause 4.11.8.1) to identify the relevant hazards, suitable monitoring techniques and appropriate
monitoring frequencies. This might be based on pathogens, spoilage organisms or indicator species.
Consideration also needs to be given to suitable locations for sampling and the times when samples are taken. The risk
assessment should consider, for example, whether field rigs, wash tanks and/or temporary facilities are appropriate test
locations.
The Standard is not prescriptive on when samples should be taken. The timing is therefore likely to be dependent on the
legislation in the country of production, customer policy and the aims of the specific testing regime. For example, guidance
from the US FDA on the control of Listeria monocytogenes indicates:
“The most important time to collect environmental samples is at a time that is several hours into production (e.g., 3 to 4 hours)
or preferably just prior to cleanup, because this allows time for L. monocytogenes (if present) to work its way out of harborage
sites and contaminate the environment, the processing line (including FCS sites), and, potentially, RTE product. Note that if
you take samples too close to the time when surfaces have been sanitized, the sanitizer may not be adequately neutralized
and could interfere with the analytical test.” (Control of Listeria monocytogenes in Ready-To-Eat Foods: Guidance for Industry
https://www.fda.gov/downloads/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/UCM535981.pdf)
In other geographic regions it may be more common to take samples from the factory environment immediately prior to
production; for example, after cleaning and disinfection and immediately prior to start-up as, in the event of an unacceptable
result, this allows corrective action (e.g. additional cleaning activity) to be taken before production commences.
In countries or geographic regions where there are no statutory criteria for the indicator organisms (e.g. most unprocessed
fresh produce within the UK), the site will need to consider the most relevant micro-organisms to monitor. As mentioned
above, these may be pathogens, spoilage organisms and/or indicator organisms and may be a matter of company policy or
customer requirements. It is worth noting that whilst there are no statutory criteria for the majority of unprocessed fresh
produce in the UK, there are specific EU regulations for sprouted seeds. This highlights the need for sites to understand the
specific risks and legislative requirements associated with their products, and the need to remain up to date with any new
developments or requirements (see clause 1.1.8).
4.14 PEST MANAGEMENT

The company must ensure that an effective pest management programme is in place. The programme must cover all the
requirements of the Standard and must operate effectively throughout the site.
Ideally, a year-round pest management system must be in place. However, where seasonal production or temporary packhouses
are used, it is important to ensure that systems are in place prior to start-up, so that they are effective from day 1 of the operation.
Pest management systems for seasonal sites should be reviewed and, where appropriate, updated prior to the start of each
season.
In addition to routine inspections, sites are required to have in-depth, documented pest management surveys undertaken by a
pest control expert (e.g. a field biologist). For sites that operate throughout the year, these surveys must be completed at least
annually. For seasonal production sites, however, the risk assessment is likely to demonstrate that ‘out of season’ visits are not
appropriate. The exact number of surveys required for seasonal sites will depend on the length of time the site is in production and
the assessed pest risk, but short-season sites should consider one survey shortly before seasonal production begins and one
during production.
BRC Global Standards has published a best-practice guideline on pest control (see www.brcparticipate.com or www.
brcbookshop.com).
4.16 DISPATCH AND TRANSPORT

The Issue 8 of the Standard has expanded the requirements for transportation of products to include both raw materials delivered
to the site and final products leaving the site (clause 4.16.2). All vehicles or containers used for the transport of raw materials and
the dispatch of products must be fit for purpose; i.e. they must maintain the safety, quality and legality of the materials being
transported. Where appropriate, this might include the following:
• consideration and prevention of potential contamination (e.g. previous use of the vehicle or container, spillages during
transport, pest control during transportation and prevention of taint)
• temperature control
• design and materials used for containers
• type of product and any subsequent production steps.
The level of activity depends on whether the vehicles are owned by the site or operated by a third party (e.g. a supplier, customer
or contractor). For example, where a supplier organises delivery to the site, the goods receipt processes will contain recorded
checks to confirm the suitability of the delivery vehicles (see section 3.5.2). Any specific requirements, such as previous loads,
prevention of taint, temperature-controlled transport or cleanliness, can be agreed in advance with the supplier and form part of
contracts or trading agreements. Where the site is responsible for the vehicles delivering raw materials, additional controls are
needed; for example, vehicle/container design, controls on previous uses of the vehicle (including changeover and cleaning
procedures), maintenance and repairs.
5 PRODUCT CONTROL
5.1 PRODUCT DESIGN/DEVELOPMENT

Although there is limited new product development within fresh produce (due to the small number of manufacturing processes
involved), consideration must be given to the requirements of the Standard when new products, new varieties of existing
products or innovations in storage and packaging are introduced. Such significant changes will require:
• formal approval by the HACCP team leader or an authorised member of the HACCP team to ensure that the consequences of
any change are understood and correctly managed
• the introduction of suitable controls relating to allergen-containing materials
• consideration of the suitability and legality of the packaging and labelling for the country of sale. The site will be expected to
demonstrate how it keeps up to date with labelling legislation and the process for reviewing and signing off labels for new and
changed products.
5.1.4 INITIAL SHELF LIFE EVALUATION

Whilst shelf life is not a safety requirement for most fresh produce, many customers still require shelf-life data to be generated. In
the absence of customer requirement, the risk should be assessed and trials be performed as appropriate to the product.
The company must establish a documented procedure for shelf-life evaluation. The aim of an initial shelf-life trial is to confirm, as
part of product development processes (e.g. when the company intends to trade a new product, or changes such as storage or
transport methods are being considered for an existing product), that product safety, legality and quality will be acceptable
throughout the life of the product. The procedure should ensure that the data are generated in a consistent manner.
The shelf-life assessment must be based on risk, and consideration should be given to the use of data relating to the rate of
spoilage, microbiological limits and/or sensory analysis, as well as relevant chemical measurements such as pH, brix or sugars, or
tests required by specific customers. See also clause 5.6.1.3 of the Standard for requirements for ongoing shelf-life verification.
5.2.4 THIRD-PARTY LABEL DESIGN

This clause is applicable wherever the decision on pack copy is not controlled by the company but is the responsibility of the
customer or a nominated third party. In these circumstances the site is required to supply accurate information on which to base
the label creation.
Note that the site remains legally responsible for safe, legal product, even where a customer specifies the packaging or packaging
supplier.
5.4.4 CLAIMS AND CHAIN OF CUSTODY

The purpose of these requirements is to ensure that all claims relating to the raw materials used in products can be substantiated.
They also require that the audit process provides a suitable evaluation of the site’s management of the chain of custody where
claims are made relating to primary agricultural schemes such as GlobalG.A.P., organic or Fairtrade.
This section covers claims that relate to the provenance of the raw material used and that differentiate it from the norm. Such a
claim may be made either on the product label for the consumer or in business-to-business communication. The types of claim
that are covered by this clause include:
• varietal claims (e.g. Bramley apples)

• origin claims (e.g. Florida grapefruit)
• assurance claims (e.g. GlobalG.A.P., Red Tractor)
• identity-preserved claims (e.g. genetically modified organism-free).
Whilst many of the same principles apply, this section is not intended to endorse the requirements of other certification schemes
that have specific rules covering production processes at the factory (e.g. organic, halal or kosher products).
It is the responsibility of the site to make reasonable checks to ensure that the raw materials supplied are genuine and that the
claims about the ingredients are proven. For example, for many assurance schemes, such as GlobalG.A.P., it is possible to check
the assurance status of the supplier and the scope of products included by searching a database or by obtaining a copy of their
certificate. Particular attention should be paid to ensuring that any specific requirements of the assurance scheme are met. For
example, GlobalG.A.P. requires the status of the supplier to be validated on the date the batch is received, and requires records of
these checks to be maintained. Reliance solely on a declaration from the supplier will not be sufficient.
Where claims are made relating to primary agricultural schemes such as GlobalG.A.P., organic or Fairtrade, the site must be able
to demonstrate management of the chain of custody. For example, GlobalG.A.P. certification requires that certified incoming and
outgoing produce is identified using the site’s GlobalG.A.P. number (GGN) and that, where appropriate, raw materials and work in
progress carry an identification number or reference that is traceable to the certificated source. In addition to this, documentation
(e.g. transaction documents) has to indicate the status of the product and include the GGN of the certified company so that
customers have a clear indication of the status of the product they are purchasing.
Where claims relate to variety/species (e.g. some varieties of fruit), examination of the visual characteristics may suffice. However,
where visual analysis is not sufficient, certificates of analysis and periodic sample analysis will be required.
5.4.6 PREVENTING MIXING OR LOSS OF IDENTITY

The site must identify (e.g. as a list or on a process flow diagram) potential areas where mixing of products or loss of identity may
occur. This is particularly important for products with claims or where different G.A.P. standards have been employed. The
process flow diagram used within the HACCP process may be used. Specific work procedures must be in place to ensure
segregation throughout the process.
One example might be that in a large packhouse packing both farm-assured and non-farm-assured fruit, the two are always
stored separately, within dedicated stores, and that grading and packing operations are organised so that packing of farm-
assured product occurs first or on particular days. In this way the assured product remains segregated from the non-assured
product. A site should employ appropriate identification and segregation based on space and/or time to maintain the integrity of
provenance, assured status or claims.
5.6 PRODUCT INSPECTION AND LABORATORY TESTING

5.6.1 PRODUCT INSPECTION AND TESTING
Quality inspections such as grading may be undertaken to confirm compliance with criteria contained within raw material or
finished product specifications. In addition to visual inspection, tests such as brix/sugar or penetrometer measurements may be
required. Test requirements must be documented (e.g. within raw material specifications) and must include acceptable limits.
The tests should be carried out to industry guidelines and documented procedures, and completed to a documented schedule.
5.6.2 LABORATORY TESTING

Testing Testing schedules must be established to a documented frequency. This must include both internal and external testing
schedules.
The company must identify the analyses that are critical to product safety and legality (e.g. pesticide residues or mycotoxins) and
must ensure that the subcontracted laboratory that undertakes these analyses is using suitably accredited methods (e.g.
accredited to ISO17025).
The frequency of tests that are critical to confirm product safety or legality should be based on risk, which may include:
• confidence in the supplier (e.g. due to high involvement by the company during the growing season)
• in-house historical analytical data
• national or international monitoring data
• details available from the supplier (e.g. spray records or certificates of analysis)
• customer requirements
• certification to a recognised G.A.P. scheme.
The use of targeted tests (e.g. testing for specific pesticide residues) or multiscreen tests (e.g. testing for a wide range of pesticide
residues) should be based on risk assessment, using similar criteria to those discussed above.
Good practice is to ensure that the documented methods used by the company include details of:
• how to obtain samples

• how to send fresh products to an external laboratory
• the methods used for internal tests such as quality grading (e.g. the use of trained staff and inspection to photographic
standards that clearly indicate acceptable and unacceptable criteria).
A number of best-practice guidelines on sampling and analysis have been published – for example, the Fresh Produce
Consortium (FPC) Code of Practice for the Control of Pesticides (10th edition, 2014); see http://www.freshproduce.org.uk/
services/fpc-publications
All test results must be documented and analysed for trends, and appropriate action instigated when unsatisfactory results are
obtained. Microbiological testing must be included where required (e.g. for sprouting seeds or pulses).
6 PROCESS CONTROL
There are no process control requirements that are unique to fresh produce (Category 5 products), and sites should refer to the
Interpretation Guideline for a detailed explanation of these requirements.
7 PERSONNEL
The production area is defined as any area where product is packed and includes field rigs and packhouses. Therefore, all the
personnel requirements in the Standard apply to these areas.
7.1 TRAINING: RAW MATERIAL HANDLING, PREPARATION, PROCESSING,

PACKING AND STORAGE AREAS
Companies must ensure that all fresh produce handlers have received training to a level commensurate with their responsibility
and the type of work carried out. This requirement includes contractors, seasonal staff and temporary personnel. If employment
agencies are used for the provision of staff, then all these requirements must be adequately met. These may include:
• specifying company policies within the supply contract

• obtaining evidence of staff training records from the agency prior to a staff member commencing work
• using a risk-based system to challenge staff understanding and therefore ensure they are competent to carry out the role.
Training procedures, schedules and records must be documented.
All staff must have been given adequate induction training. This training must include procedures on protective clothing, personal
hygiene and quality requirements. Where a site uses allergenic materials, all relevant staff involved in handling ingredients,
equipment, utensils, packaging and products must also receive training to raise their awareness of food allergens and the specific
allergen control measures used by the company.
Training on critical control points (CCPs) identified in the HACCP food safety plan and other control points (such as quality
inspections) that are relevant to the areas in which staff work must be provided. Where post-harvest treatments (e.g. fungicides)
are used, the relevant staff must be able to demonstrate sufficient technical training, including the safe use and application of the
plant protection products.
Competence and training in areas that impact food safety, such as cleaning, machine operation and sampling, must be
demonstrated. The HACCP team must be able to demonstrate competence, which may be achieved through a combination of
external qualifications, experience or in-house training. Consideration should be given to the delivery of training in the
appropriate languages of trainees.
All personnel must be adequately supervised throughout the working period and the needs of temporary or seasonal workers
and contractors must be identified and attended to.
Competencies must be reviewed regularly and relevant training provided as required.
7.2 PERSONAL HYGIENE: RAW MATERIAL HANDLING, PREPARATION,

PROCESSING, PACKING AND STORAGE AREAS
The fresh produce sector must comply with all the personal hygiene requirements of the Standard and the company must
document its policies to achieve this compliance. These policies should be based on risk assessment. Field rigs are defined as
production areas and are therefore included in this requirement.
7.4 PROTECTIVE CLOTHING: EMPLOYEES OR VISITORS TO PRODUCTION

AREAS
Protective clothing includes uniforms, overalls, head coverings (such as hats and hairnets), shoes and boots, and aprons and
gloves, whether disposable or washable.
The company is required to determine the procedures for the application and use of protective clothing based on a risk
assessment. The risk assessment must consider potential contamination from foreign bodies (e.g. buttons and fibres from
clothing and hair), and microbiological and allergen risks as appropriate, as well as general good-practice principles. It must
document:
• what must be worn

• where and how clothing must be put on and taken off (i.e. away from the packing area and prior to crossing the field to access
the field rig)
• where it must be stored
• specific requirements for specific areas
• removal of protective clothing before entering toilets
• procedures for canteens and smoking areas.
The requirements must be documented and communicated to staff during induction training.
Protective clothing must be available for all staff and provided in sufficient numbers to allow it to be maintained in an acceptable
condition during working. Consideration should be given to fluctuations in staff numbers (e.g. due to seasonal or agency staff) to
ensure that sufficient protective clothing is available at the times of highest demand.
The company needs to consider the design of protective clothing and ensure that it is suitable for the production process and
prevalent conditions (e.g. to allow working in a hot or cold environment). As a minimum, it must:
• not include external pockets above the waist or sewn-on buttons

• include suitable footwear
• include headwear such as mob hats or hairnets to ensure that hair is completely covered (hats or baseball caps are acceptable
provided that hair is completely covered – for example, by being tied back and tucked under the hat)
• include beard snoods where product contamination is a risk and needs to be prevented (the policy must be based on a clear
risk assessment by the company)
• consider the use of gloves. Where gloves are used, they are potentially a source of foreign bodies (e.g. due to the potential for
pieces to be removed if the glove is damaged). A control procedure must be in place, and gloves must be visually distinct from
fresh produce. Disposable gloves must be single-use and of sufficient durability for the task. A risk assessment should be used
to determine how frequently gloves are replaced – for example, changing after each break, upon re-entry into the processing
area, or when soiled or damaged.
Where a risk assessment demonstrates that it is acceptable, staff uniforms that are worn from home to the site can be used in field
rigs, providing the assessment includes the use of an apron which is worn over the uniform and is added only after arrival at the
site and before entering the packing area.
There will be a documented process for the laundering of protective clothing, including verification criteria such as:
• monitoring of the temperature

• detergent use
• items that must not be washed together
• drying processes
• visual inspection.
Whilst it is more prevalent in other sectors of the food industry, some companies may contract a third-party laundry to clean the
protective clothing. External contracted services must be incorporated within the company’s supplier approval process and
systems of continual assessment employed to ensure that the process is under control (e.g. the use of self-audit questionnaires,
visual assessment and the monitoring of complaints).
Home laundering may be deemed acceptable in low-risk operations such as produce packing where there is little microbiological
risk. Home laundering still requires appropriate care and attention to ensure that appropriate standards are maintained. The
process must be controlled by a documented company policy provided to staff and, as a minimum, will include:
• how garments are to be washed (e.g. temperature, detergent, avoidance of certain items being washed together, drying
instructions)
• company policy on the transport of washed garments from home to the workplace
• a defined responsibility within the company for monitoring the effectiveness of the system (typically this may be achieved by
visual inspection)
• a procedure and system for effectively dealing with any cases where employees are unable to perform self-laundry, either
through lack of diligence or through lack of facilities (this system must be capable of being brought into immediate effect once
a problem has been identified)
8 HIGH-RISK, HIGH-CARE AND AMBIENT HIGH-CARE PRODUCTION
RISK ZONES
The Standard recognises that certain products are at significant risk of pathogen contamination if raw materials, finished product
operations and the production environment are not satisfactorily controlled. Production zones handling these products are
referred to as:
• high-risk
• high-care
• ambient high-care
These areas are not usually applicable to fresh produce (Category 5 products), although they are likely to apply to Category 6
products. Full definitions and explanations of the products that require high-risk, high-care or ambient high-care areas are
located in Appendix 2 of the Standard.
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 are not manufactured, further processed or packed at the site being audited, the site’s management of these
products is covered by the requirements in this section.
The inclusion of this section remains voluntary and sites should notify their certification body in advance of the audit should they
wish to include traded products with the scope of the audit.
APPENDICES
APPENDIX 1
Scope wording 35
APPENDIX 2
Root cause analysis 37
APPENDIX 3
Decision tree for metal detection 38
APPENDIX 4
Sources of further information 39
APPENDIX 5
Acknowledgements41
APPENDIX 1
Appendix 1 Scope wording

SCOPE WORDING
In order to standardise the terminology of the scope, to ensure that it clearly reflects activities on site, and to facilitate search
functions within the company listing in the BRC Global Standards Directory, the following format must be used for scope on
certificates.
Process description Washing, sorting, labelling, packing, processing, storage etc.
Product type Sub-category, example products
Organisation Field rigs, temporary packhouses, head office functions etc.
Examples of sub-categories and associated products are provided in the following list:
SUB-CATEGORY PRODUCE NAME

Citrus fruit Grapefruit, oranges, lemons, limes, mandarins, others
Tree nuts (shelled or unshelled) Almonds, Brazil nuts, cashew nuts, coconuts, hazelnuts, macadamia nuts, pecans, pine
nuts, pistachios, walnuts, others
For the purposes of the scope wording, coconuts and pine nuts are included in this
category, although botanically they are not tree nuts.
Pome fruit Apples, pears, quinces, medlar, loquat, others
Stone fruit Apricots, cherries, peaches, plums, others
Berries and small fruit Table grapes, wine grapes, strawberries, blackberries, dewberries, raspberries,
blueberries, cranberries, currants (red, black and white), gooseberries, rosehips,
mulberries, azarole (Mediterranean medlar), elderberries, others
Miscellaneous edible peel fruit Dates, figs, table olives, kumquats, carambola, persimmon, jambolan (Java plum), others
Miscellaneous inedible peel, Kiwi, lychee (litchi), passion fruit, prickly pear (cactus fruit), star apple, American
small fruit persimmon (Virginia kaki), others
Miscellaneous inedible peel, Avocado, bananas, mangoes, papaya, pomegranate, cherimoya, guava, pineapples,
large fruit bread fruit, durian, soursop (guanabana), others
Root and tuber vegetables Potatoes, cassava, sweet potatoes, yams, arrowroot, beetroot, carrots, celeriac,
horseradish, Jerusalem artichokes, parsnips, parsley root, radishes, salsify, swedes,
turnips, others
Bulb vegetables Garlic, onions, shallots, spring onions, others
Fruiting vegetables – Solanacea Tomatoes, peppers, aubergines (eggplants), okra (lady’s fingers), others
Fruiting vegetables – cucurbits, Cucumber, gherkins, courgettes, others
edible peel
Fruiting vegetables – cucurbits, Melons, pumpkins, watermelons, others
inedible peel
Fruiting vegetables – sweetcorn
Other fruiting vegetables
Brassica vegetables Broccoli, cauliflower, Brussels sprouts, head cabbage, Chinese cabbage, kale, kohlrabi,
others
Leaf vegetables Lamb’s lettuce, lettuce, scarole (broad-leaf endive), cress, land cress, rocket, rucola, red
mustard, leaves and sprouts of Brassica species, spinach, purslane, beet leaves (chard),
vine leaves, watercress, witloof, others
Herbs Chervil, chives, celery leaves, parsley, sage, rosemary, thyme, basil, bay leaves (laurel),
tarragon, others
Legume vegetables Beans (with pods), beans (without pods), peas (with pods), peas (without pods), lentils,
others
Stem vegetables Asparagus, cardoons, celery, fennel, globe artichokes, leeks, rhubarb, bamboo shoots,
palm hearts, others
Fungi Cultivated, wild, others
Sea weeds
Pulses, dry Beans, lentils, peas, lupins, others
Oil seeds Linseeds, peanuts, poppy seeds, sesame seeds, sunflower seeds, rape seeds, soya
beans, mustard seeds, cotton seeds, pumpkin seeds, safflower, borage, gold of
pleasure, hemp seeds, castor beans, others
Oil fruits Olives for oil production, palm nuts (palm oil kernels), palm fruit, kapok, others
For example:
‘The sorting, slicing, hand-floretting and packing of brassicas (e.g. cauliflower and broccoli), including field rigs, Abbey Farm
packhouse and head office functions.’
‘Classification and packing of fruiting vegetables (tomato and cucumber) by the Abbey Farm packhouse.’
Further information on scope wording can be found in the BRC Global Standards’ guideline for defining wording of scope.
APPENDIX 2
APPENDIX 2 ROOT CAUSE ANALYSIS

ROOT CAUSE ANALYSIS
An important part of an effective corrective action process is the identification of the root cause or underlying cause of the
non-conformity and the implementation of suitable action to prevent recurrence of the non-conformity. Root cause analysis is a
process of conducting an investigation into an identified problem, to allow the investigator(s) to understand the fundamental
cause of the problem and put it right. While there are a number of techniques for undertaking root cause analysis, one of the most
common and simplest to use is the ‘Five Whys’ technique. The technique is based on repeatedly digging deeper into the cause of
a problem by asking ‘why’ to get to the root of the issue. Usually, the root cause becomes evident after five steps but this is not
rigidly fixed and further investigation should be completed where required.
For example: During its audit, a site receives a non-conformity for knife control, as the procedure is not working correctly and the
site cannot demonstrate that all blades are checked regularly.
Following the audit, the site’s immediate corrective action is to update the knife check procedure to include a schedule for checks
and a record sheet. Whilst this may address the immediate business needs, it does not establish the reason why the old
procedure failed or prevent it from happening again in the future. Using the Five Whys technique, the root cause analysis should
ask a series of questions:
• Why was the old procedure ineffective? Conclusion – the mechanism relied on all blades being seen by the quality assurance
team at the end of the shift.
• Why wasn’t this effective? Conclusion – the blades were not easily identifiable and therefore it was unclear whether all the
blades were checked.
• Why wasn’t it clear whether all the knives were returned? (For example, why couldn’t they be counted?) Conclusion – knives
were not returned to a central point, as there were several storage locations.
• Why were there several storage locations? Conclusion – the knives were needed in several different areas of the site.
The conclusion of the root cause analysis should be to identify what should be changed to prevent recurrence. In the example
above, this might include:
• Introduce a system whereby all permitted knives must be clearly identified – for example, with an indelible number.
• Introduce an updated checklist or record to ensure that it is easy to establish whether all the knives have been returned.
• Establish and document the permitted storage locations to which all blades must be returned at the end of the shift.
• Ensure that staff fully understand and are trained in the new procedures.
The effectiveness of the root cause analysis and the corrective action plan should be assessed – for example, by inclusion in the
internal audit schedule.
BRC Global Standards has produced a guideline on root cause analysis which is available on BRC Participate or may be
purchased from the BRC bookshop (www.brcbookshop.com).
Details of BRC Global Standards training on root cause analysis is available from www.brcglobalstandards.com/training/courses
APPENDIX 3
DECISION TREE FOR METAL
DETECTION
Metal
Does a customer contract specify that
Yes detection
metal detection is required?
required
No
Does the product pass through a

foreign-body removal process capable of
detecting or removing material smaller
Metal detection
Yes than can be detected by a metal detector
not compulsory
(e.g. X-ray or filtration/fine non-metallic mesh
sieve at the last stage where contamination is
possible prior to packing)?
No
Are there robust, effective systems of

product inspection or controls of likely
Metal
sources of metal (e.g. knife controls) in
No detection
place that prevent the risk of contamination
required
(which are supported by the absence of metal
complaints)?
Yes
Is the product of a nature or usage such

that any metal contamination would
Metal detection Metal
Yes immediately and always be apparent to
not compulsory No detection
the customer and would consequently be
removed before usage of the product required
(e.g. unprocessed whole fruit and vegetables)?
APPENDIX 4
Appendix 4 Sources of further information

SOURCES OF FURTHER
INFORMATION
BRC GLOBAL STANDARDS

A series of globally recognised certification standards for manufacturers and for storage and distribution companies.
www.brcglobalstandards.com
BRC GLOBAL STANDARD FOOD SAFETY – ISSUE 8 INTERPRETATION

GUIDELINE
Guidance on how to obtain certification to Issue 8 of the BRC Global Standard for Food Safety and the implementation of
individual requirements across the food industry.
www.brcbookshop.com
BRC GLOBAL STANDARDS GUIDELINES

BRC Global Standards publishes a series of best-practice guidelines on topics including:
• complaint handling
• pest control
• internal auditing
• product recall
• traceability
• foreign-body detection
• preventive action and root cause analysis
• product safety rationale.
These are available on BRC Participate (www.brcparticipate.com) or may be purchased from the BRC bookshop
www.brcbookshop.com
CHEMICALS REGULATION DIRECTORATE

Information on pesticides and maximum residue levels (MRLs) in the UK.
www.pesticides.gov.uk
CODEX ALIMENTARIUS
The Codex Alimentarius Commission was created in 1963 by FAO and WHO to develop food standards, guidelines and related
texts such as codes of practice under the Joint FAO/WHO Food Standards Programme. It also provides information on Codex
pesticide MRLs in food.
www.codexalimentarius.org/standards/pesticide-mrls/en
FOOD AND DRUG ADMINISTRATION (FDA) OF THE UNITED STATES GUIDANCE

Bad Bug Book – examples of microbiological sources.
www.fda.gov/food/foodborneillnesscontaminants/causesofillnessbadbugbook/default.htm
Control of Listeria monocytogenes in Ready-To-Eat Foods: Guidance for Industry:
www.fda.gov/downloads/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/UCM535981.pdf
FOOD STANDARDS AGENCY/HORTICULTURAL DEVELOPMENT COMPANY

GUIDANCE
FSA/HDC Factsheet 13/10 Monitoring microbial safety of fresh produce.
https://horticulture.ahdb.org.uk/search/node/microbial%20safety
FRESHFEL
Membership association representing the views of fresh food producers in Europe.
www.freshfel.org
FRESH PRODUCE CONSORTIUM

Membership association in the UK providing assistance and guidelines to fresh produce packers.
www.freshproduce.org.uk
GLOBALGAP
A private-sector body that sets voluntary standards for the certification of production processes of agricultural (including
aquaculture) products.
www.globalgap.org
RASFF
The Rapid Alert System for Food and Feed (RASFF), established in 1979, enables the rapid exchange of information whenever a
risk to food or feed safety is identified. Members comprise 27 member states, the European Commission, the European Food
Safety Authority, Iceland, Liechtenstein and Norway. This is part of the Europa website.
http://ec.europa.eu/food/food/rapidalert/index_en.htm
It is possible to search by category (there is a fruit and vegetables category), by date range, by hazard and by country.
http://ec.europa.eu/food/safety/rasff/portal/index_en.htm
UNITED FRESH PRODUCE ASSOCIATION

Membership association in the United States providing assistance and guidelines to fresh produce packers.
www.unitedfresh.org
Note: Links and references to websites are intended to help the user with further information. BRC Global Standards cannot,
however, be responsible for the content or continued existence of any external website. It should also be noted that legislation
and standards change frequently and a user should confirm for themselves that any references are current and still applicable.
APPENDIX 5
Appendix 5 Acknowledgements
ACKNOWLEDGEMENTS
BRC Global Standards wish to acknowledge the contributions made by the following individuals:BRC Global Standards wish to
acknowledge the contributions made by the following individuals
John Figgins BRC Global Standards

John Kukoly BRC Global Standards
Jon Tugwell FPC
Sian Thomas FPC
BRC Global Standards
Floor 2
7 Harp Lane
London EC3R 6DP
Tel: +44 (0)20 3931 8150
Email: enquiries@brcgs.com
To learn more about the BRCGS certification programme

please visit brcgs.com
To learn more about the BRCGS online publication service for

certificated sites, please visit brcgsparticipate.com
To purchase printed copies or PDFs from the full range of

BRCGS publications please visit brcgsbookshop.com

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PART I AUDIT PROTOCOL

PART II RELEVANT REQUIREMENTS OF THE GLOBAL

• the requirements for high-care or high-risk production zones

DURATION AND TIMING

PART I AUDIT PROTOCOL

• accurately described in procedures

EXCLUSIONS FROM SCOPE

PRODUCT SAFETY RATIONALE

• Ambient, short shelf-life product (<7 days).

BRC Global Standards has published a full guide to PSR.

• the use of field rigs and/or temporary field packhouses

• what needs to be seen

AUDIT OPTIONS: ANNOUNCED/UNANNOUNCED

PART I AUDIT PROTOCOL

SEASONAL PRODUCTION SITES

RELATIONSHIPS BETWEEN HEAD OFFICE AND SATELLITE SITES

2 THE FOOD SAFETY

1.1 SENIOR MANAGEMENT COMMITMENT AND CONTINUAL IMPROVEMENT

• reducing customer complaints

1.1.6 CONFIDENTIAL REPORTING SYSTEM (WHISTLEBLOWER SYSTEM)

1.1.8 PROVISION OF TECHNICAL KNOWLEDGE AND INFORMATION

2.3 DESCRIBE THE PRODUCT – CODEX ALIMENTARIUS STEP 2

2.4 IDENTIFY INTENDED USE – CODEX ALIMENTARIUS STEP 3

• whether the product can be eaten raw, cooked or both

2.7 LIST ALL POTENTIAL HAZARDS ASSOCIATED WITH EACH PROCESS

Chemicals to consider include:

3.4 INTERNAL AUDITS

3.5 SUPPLIER AND RAW MATERIAL APPROVAL AND PERFORMANCE

The risk assessment must consider the potential for:

3.5.1.2 Documented supplier approval system

• the qualifications of agronomists and advisers

• packing on farm and in the field

Supplier/grower approval may also include assessments of:

• the company’s historical experience of the supplier

3.5.1.3 Ongoing supplier monitoring

3.5.1.4 Approved suppliers list

• BRC Global Standard for Agents and Brokers

• visual inspection on receipt

3.6.1 SPECIFICATIONS FOR RAW MATERIALS AND PACKAGING

Specifications should also include details of packaging.

3.7 CORRECTIVE AND PREVENTIVE ACTIONS

3.8 CONTROL OF NON-CONFORMING PRODUCT

• identifying the suppliers* of all lots/batches of raw materials

3.9.3 TESTS OF THE TRACEABILITY SYSTEM

The mass balance exercise is usually undertaken as follows:

• Select a batch or lot code of a specific raw material.

Day 1 10,000 × 4-pack + 2,000 × 10-bags Waste = 100 kg

4-PACKS 10-BAGS WASTE TOTAL

4.2 SITE SECURITY AND FOOD DEFENCE

4.5 UTILITIES – WATER, ICE, AIR AND OTHER GASES

4.8 STAFF FACILITIES

Toilet facilities must conform to the requirements of the Standard.

• post-harvest fungicides and wax treatments

• they are suitable and approved for food use

• the application date

• that the use of wood is covered by the HACCP assessment

4.10 FOREIGN-BODY DETECTION AND REMOVAL EQUIPMENT

• little mechanical equipment is used

4.11 HOUSEKEEPING AND HYGIENE

4.11.8 Environmental monitoring