Implementing A BRC Issue 8 Compliant Food Safety Management System 76

Implementing a BRC Issue 8
Compliant Food Safety Management

System
Tony Connor
Chief Technical Advisor, IFSQN
BRC Global Standard for Food Safety Issue 8
The key components to the BRC standard are:
✓ Senior Management Commitment
✓ A HACCP/food safety plan
✓ A Quality Management System
✓ Prerequisite Programmes
BRC Global Standard for Food Safety Issue 8
BRC GLOBAL STANDARD FOR FOOD SAFETY

Issue 7 Sections Issue 8 Sections
1 Senior management commitment 1 Senior management commitment
2 The food safety plan – HACCP 2 The food safety plan – HACCP
3 Food safety and quality management system 3 Food safety and quality management system
4 Site standards 4 Site standards
5 Product control 5 Product control
6 Process control 6 Process control
7 Personnel 7 Personnel
8 High-risk, high-care and ambient high-care
production risk zones
9 Requirements for traded products
1 Senior
Management
9 Commitment 2 The Food
Requirements
Safety Plan -
for Traded
HACCP
Products
BRC Global 3 Food Safety

8 High-Risk &
High-Care
Standard for & Quality
Management
Food Safety System
Issue 8
7 Personnel
Changes 4 Site
Standards
6 Process 5 Product
Control Control
BRC Global Standard for Food Safety
The requirements in sections 1–7 are applied to all operations.
Sites with product requiring high-risk, high-care or ambient high-care facilities

(as defined in Appendix 2) must meet the requirements in section 8.
Where a site also handles traded products (i.e. products not manufactured or
processed on the site but bought in and sold by the site), there are additional
requirements for these products as detailed in section 9.
8 HIGH-RISK, HIGH-CARE AND AMBIENT HIGH-CARE PRODUCTION RISK ZONES
1 Senior
Management
Commitment
2 The Food
8 High-Risk &
Safety Plan -
8.1 Layout, product flow and segregation
High-Care HACCP 8.2 Building fabric
8.3 Maintenance
BRC Global 8.4 Staff facilities
7 Personnel
Standard for 3 Food Safety
& Quality
8.5 Housekeeping and hygiene
Management 8.6 Waste/waste disposal
Food Safety System
8.7 Protective clothing
Issue 8
All in high-risk and high-care zones
6 Process 4 Site
Control Standards
5 Product
Control
Risk Assessments
Risk Assessments
Issue 8 Main Changes
Changes have included and considered:
✓ plan for development of product safety culture (Clause 1.1.2)
✓ enhanced requirements for environmental monitoring (New section 4.11.8
ENVIRONMENTAL MONITORING)
✓ additional requirements for food defence (4.2 Changed from SECURITY to
SITE SECURITY AND FOOD DEFENCE)
✓ clarifying the requirements for high-risk, high-care and ambient high-care
production risk zones (New section 8 HIGH-RISK, HIGH-CARE AND AMBIENT
HIGH-CARE PRODUCTION RISK ZONES)
✓ clarifying the requirements for sites manufacturing pet food (New section
5.8 PET FOOD)
✓ enhanced product packing and labelling controls
✓ considered US Food Safety Modernization Act (FSMA) requirements
BRC Implementation Process
• Learn about the BRC Global Standard for Food Safety
• Senior Management Implementation
• Implementation of Good Manufacturing Practices
• Food Safety Quality Management System Implementation
• Food Safety Plan/HACCP Implementation & Training
• Product and Process Controls
• Training
• Internal Audits & Corrective Actions
• Management Reviews & Actions for Improvement
• Self Assessment & Corrective Actions

FUNDAMENTAL REQUIREMENTS
BRC GLOBAL STANDARD FOR FOOD SAFETY FUNDAMENTAL REQUIREMENTS
Issue 7 Fundamental Requirements Issue 8 Fundamental Requirements
Senior management commitment and continual Senior management commitment and continual
improvement (1.1) improvement (1.1)
The food safety plan – HACCP (2) The food safety plan – HACCP (2)
Internal audits (3.4) Internal audits (3.4)
Management of suppliers of raw materials and Management of suppliers of raw materials and
packaging (3.5.1) packaging (3.5.1)
Corrective and preventive actions (3.7) Corrective and preventive actions (3.7)
Traceability (3.9) Traceability (3.9)
Layout, product flow and segregation (4.3) Layout, product flow and segregation (4.3)
Housekeeping and hygiene (4.11) Housekeeping and hygiene (4.11)
Management of allergens (5.3) Management of allergens (5.3)
Control of operations (6.1) Control of operations (6.1)
Labelling and pack control (6.2) Labelling and pack control (6.2)
Training: raw material handling, preparation, Training: raw material handling, preparation,
processing, packing and storage areas (7.1) processing, packing and storage areas (7.1)
BRC Section 1 Senior Management Commitment
Key requirements of Section 1.1 Senior Management Commitment and
Continual Improvement
1.1.1 Documented Policy to produce safe, legal and authentic products to the
specified quality
1.1.2 Food Safety and Quality Culture
1.1.3 Documented Food Safety Objectives
1.1.4 Senior Management Review
1.1.5 Meeting Program
1.1.6 Confidential Reporting System
1.1.7 Human and Financial Resources
1.1.8 Informed Of All Relevant Legislative, Scientific Information
Changes Section 1 Senior Management Commitment
1.1.1 Added authentic to
policy requirements
1.1.4 Management review
meetings : objectives
1.1.5 Employees report any
evidence of unsafe or out-of-
specification product or raw
materials
Fundamental requirement
Senior management need to demonstrate they
are fully committed to the implementation of
the food safety and quality management system,
meeting the requirements of the BRC Global
Standard for Food Safety and driving continual
improvement.
Key requirements of Section 1.1 Senior
Management Commitment and Continual
Improvement
1.1.1 Documented Policy to produce safe, legal

and authentic products to the specified quality
1.1.1 Documented Policy
1.1.2 Food Safety and Quality Culture
Plan for development
of product safety and
quality culture
Issue 8 Change
Plan for development

of product safety and
quality culture
(Clause 1.1.2)
Senior
Management
Monitoring & Policies &

Feedback Standards
Food Safety
Visible
Culture
Communication
Support
Education/
Resources
Training
Improvement

Improvement
1.1.4 Senior Management Review

1.1.5 Meeting Program
Section 1 Senior Management Commitment
1.1.6 New: The company

shall have a confidential
reporting system
Improvement
1.1.7 Human and Financial Resources

1.1.8 Informed Of All Relevant Legislative,
Scientific Information
1.2 Organisational Structure, Responsibilities and
Management Authority
Key requirements of Section 1.2
1.2.1 Organisation Chart
1.2.2 Employees Are Aware Of Responsibilities
1.2 Organisational Structure, Responsibilities and
Management Authority
Responsibilities and Authority
Responsibilities and Authority
Section 2 The Food Safety Plan – HACCP
There must be an implemented and effective
Food Safety Plan incorporating the Codex
Alimentarius HACCP principles
2.1 The HACCP Food Safety Team (Equivalent to Codex Alimentarius Step 1)
2.1.1 Multi-disciplinary Food Safety Team
2.1.2 Scope
2.2 Prerequisite Programmes
2.3 Describe The Product (Equivalent to Codex Alimentarius Step 2)
2.4 Identify Intended Use (Equivalent to Codex Alimentarius Step 3)
2.5 Construct A Process Flow Diagram (Equivalent to Codex Alimentarius
Step 4)
2.6 Verify Flow Diagram (Equivalent to Codex Alimentarius Step 5)
2.7 List all Potential Hazards Associated with each Process Step, Conduct a Hazard
Analysis and Consider any Measures to Control Identified Hazards (Equivalent to
Codex Alimentarius Step 6, Principle 1)
2.8 Determine the Critical Control Points (CCPs) (Equivalent to Codex Alimentarius
Step 7, Principle 2)
2.9 Establish Critical Limits For Each CCP

(Equivalent to Codex Alimentarius Step 8, Principle 3)
2.10 Establish A Monitoring System For Each CCP (Equivalent to Codex

Alimentarius Step 9, Principle 4)
2.11 Establish a Corrective Action Plan
2.12 Establish Verification Procedures

2.13 HACCP Documentation and Record-keeping (Equivalent to Codex

Alimentarius Step 12, Principle 7)
2.14 Review The HACCP Plan

HACCP Plans should include:

Process Step
Hazard
Control Measure
Critical Limits
Monitoring Procedures
Responsibilities
Corrective Action
Reference to relevant Records
Issue 8 Changes
2 The food safety plan – HACCP
✓ Incorporating Codex Alimentarius HACCP principles

✓ Training
✓ Prescribed Hazards
✓ Review – changes may be reflected in safety policy
and objectives
Issue 8 Changes
✓ Incorporating Codex
Alimentarius HACCP principles
Issue 8 Changes
2.7.1 The HACCP food safety team shall identify and record all the
potential hazards ……… consideration of the following types of hazard:
✓ microbiological
✓ physical contamination
✓ chemical and radiological contamination
✓ fraud (e.g. substitution or deliberate/intentional adulteration)
✓ malicious contamination of products
✓ allergen risks (see clause 5.3)
FSMA §117.130 Hazard analysis
(b) Hazard identification. The hazard identification must consider:
Known or reasonably foreseeable hazards that include:
(i) Biological hazards, including microbiological hazards such as parasites, environmental
pathogens, and other pathogens;
(ii) Chemical hazards, including radiological hazards, substances such as pesticide and
drug residues, natural toxins, decomposition, unapproved food or color additives, and
food allergens; and
(iii) Physical hazards (such as stones, glass, and metal fragments); and
(2) Known or reasonably foreseeable hazards that may be present in the food for any of
the following reasons:
(i) The hazard occurs naturally;
(ii) The hazard may be unintentionally introduced; or
(iii) The hazard may be intentionally introduced for purposes of economic gain.
Section 3 Food Safety and Quality Management System
There are requirements for:
3.1 Food safety and quality manual
3.2 Document control
3.3 Record completion and maintenance
3.4 Internal audits
3.5 Supplier and raw material approval and performance monitoring
3.6 Specifications
3.7 Corrective and preventive actions
3.8 Control of non-conforming product
3.9 Traceability
3.10 Complaint-handling
3.11 Management of incidents, product withdrawal and product recall
3.1 Food safety and quality manual
3.2 Document control
3.3 Record completion and maintenance
BRC Issue 8 Changes
Electronic documents and records
Section 3.4 Internal Audit
Fundamental requirement – verify

the food safety plan and that
systems meet the requirements of
the Standard
Changes to Section 3.4 Internal Audits
Changes to Section 3.4 Internal Audits
Section 3.5 Supplier and Raw Material Approval and
Performance Monitoring
3.5.1 Management of Suppliers of Raw Materials and
Packaging
Changes to Section 3.5 Supplier and Raw Material
Approval and Performance Monitoring
Supplier and Raw Material Approval
Valid certification to the applicable BRC Global
Standard or GFSI benchmarked standard.
The scope of the certification shall include the
raw materials purchased.
Certificate and Scope Validation Directories:
BRC - https://brcdirectory.co.uk
SQF - https://www.ac.parkcitygroup.com/application/vwavecgi/public/register.cgi/search/blcares
FSSC 22000 - http://www.fssc22000.com/documents/certifiedorganizations/complete-list-version-4.xml?lang=en
IFS - https://www.ifs-certification.com/index.php/en/tools/ifs-database
Certificate and Scope
Validation Directories:
Certificate and Scope
Validation Directories:
Section 3.5 Supplier and Raw Material Approval and
Performance Monitoring
Or Approval by Supplier
audits, with a scope to
include product safety,
traceability, HACCP
review and good
manufacturing practices,
….
Approval and Performance Monitoring
Where this supplier audit is completed by a 2nd

or 3rd party there is a need to demonstrate the
competency of the auditor, confirm the scope
of the audit and obtain and review a copy of
the full audit report.
Approval
Where a valid risk-based
justification is provided
and the supplier is
assessed as low risk only,
a completed supplier
questionnaire may be
used for initial approval.
Changes to Section 3.5 Supplier and Raw Material Approval
Process for the ongoing

review and monitoring of
suppliers, based on risk
and using defined
performance criteria.
Changes to Section 3.5 Supplier and Raw Material Approval
Approval and monitoring

of suppliers of services
based on risk
Outsourced processors
approval and monitoring
procedure shall be based
on risk
Changes to Section 3.6 Specifications
Section 3.7 Corrective and Preventive Action
Section 3.7 Corrective and Preventive Action
Fundamental Requirement
The site shall be able to demonstrate that it uses the
information from identified failures in the food safety
and quality management system to make necessary
corrections and prevent recurrence.
Procedure for the Completion of Root Cause Analysis
Section 3.8 Control of Non-conforming Product
Section 3.9 Traceability
Changes to Section 3.9 Traceability
Traceability System Diagram
1 2 3 4 5 6 Culture
WMP Stabiliser Sugar
AMF Delivery SMP Delivery Delivery
Delivery Delivery Delivery
Supplier & Batch QMR Goods In Record

7 8 9 10 11
12 Culture
AMF Storage WMP Stabiliser Sugar
SMP Storage Storage
Storage Storage Storage
Ingredient & Batch QMR Storage Record

13 14
AMF AMF 19
Warming Decanting Waste Bags
Removed
Ingredient & Batch QMR Batch Mix Record
18 22
Waste 17 21 20
15 16 AMF Yoghurt Base RO Water
Drums AMF Storage Debagging RO Water
Warming Blending Heating
Removed
25 24
27 26 23
Homogenisatio Transfer &
Cooling Pasteurisation Filtration
n Holding
Batch QMR Batch Process Record
Section 3.10 Complaint Handling
Section 3.11 Management Of Incidents, Product
Withdrawal And Product Recall
Changes to Section 3.12 Customer Focus and
Communication
Section 4 Site Standards
4.1 External standards
4.2 Site security and food defence
4.4 Building fabric, raw material handling, preparation, processing, packing
and storage areas
4.5 Utilities – water, ice, air and other gases
4.6 Equipment
4.7 Maintenance
4.8 Staff facilities
Section 4 Site Standards
4.9 Chemical and physical product contamination control: raw material
handling, preparation, processing, packing and storage areas
4.10 Foreign-body detection and removal equipment
4.12 Waste/waste disposal
4.13 Management of surplus food and products for animal feed
4.14 Pest management
4.15 Storage facilities
4.16 Dispatch and transport
4.1 External standards
4.2 Changed from
SECURITY to SITE
SECURITY AND
FOOD DEFENCE
Requirement for a Documented Threat Assessment Plan
Section 4.3 Layout, Product Flow and Segregation
The factory layout, flow of processes and
movement of personnel shall be sufficient to
prevent the risk of product contamination and
to comply with relevant legislation.
Controls for products requiring high-risk, high-

care and ambient high-care processing
environments moved to Section 8
4.4 Building fabric, raw material handling,
preparation, processing, packing and storage areas
The fabric of site, buildings and

facilities should be applicable
4.4 Building fabric, raw material handling,
preparation, processing, packing and storage areas
✓ The water supply

✓ Water distribution
✓ Monitoring of gases and steam
Section 4.6 Equipment
4.7 Maintenance
✓ Maintenance schedule
✓ Equipment inspection
✓ Temporary repairs
✓ Clean-up after maintenance work
Changes to Section 4.7
Maintenance
✓ Documenting Temporary repairs

✓ Equipment inspection by an authorised member of staff
✓ Materials and parts of an appropriate grade or quality
Section 4.8 Staff Facilities
✓ Changing facilities
✓ Storage of personal items
✓ Segregation of personal items from work clothing  
✓ Hand-washing facilities
✓ Toilets
✓ Smoking areas
✓ Staff food
✓ Catering facilities
4.9 Chemical and Physical Product Contamination
Control
Control
Chemical Control
Storage and handling of non-food chemicals

Strong scents and taints
Control
Control
Control
Addition 4.9.6 Other Physical Contaminants
4.10 Foreign-Body Detection and Removal Equipment
The risk of product contamination shall be reduced or

eliminated by the effective use of equipment to remove or
detect foreign bodies.
Typical equipment to be considered may include:
✓ Filters/sieves
✓ Metal detection
✓ Magnets
✓ Optical sorting equipment
✓ X-ray detection equipment
Metal Detectors and X-Ray Equipment
Metal detection equipment shall be in place unless risk

assessment demonstrates that this does not improve the
protection of final products from metal contamination.
Containers
Based on risk assessment, procedures shall be implemented

to minimise foreign-body contamination originating with the
packaging container.
Section 4.11 Hygiene And Housekeeping
Acceptable and Unacceptable Cleaning Performance
Food Contact Surface – Filler Nozzle
Monitoring method:
ATP Swab after cleaning before Start Up
Action Limits:
< 10 rlu – Okay to Start Up
10 – 30 rlu – Sanitise and Reswab
> 30 rlu – Full Clean and Reswab
New section 4.11.8 ENVIRONMENTAL MONITORING
Open product areas:
New section 4.11.8
Priority Order for Environmental Sampling

High risk (chilled and frozen)
High care (chilled and frozen)
Ambient high care ENVIRONMENTAL
Low risk
Flow & entrances to the above areas MONITORING
Enclosed product areas:
Warehouses
Storerooms
Flow & entrances to the above areas
Non-product areas:
Canteens
Laundries
Offices
Flow & entrances to the above areas
Environmental Monitoring
Food Contact Surface – Inside Storage Tank
Food Contact Surface – Foil Lidding
Non-Food Contact Surface – Inside Door Filler Cabinet
Priority Order
Non-Food Contact Surface – Cleaning Equipment
Non-Food Contact Surface – Floor under Filler
Non-Food Contact Surface – Outside Storage Tank
Non-Food Contact Surface – Drain
Non-Food Contact Surface – Wall
Non-Food Contact Surface – Floor near Entrance
Non-Food Contact Surface – Hand Wash Sink
Filling Room
Hand Wash
Sink
Schedule
Food Contact Surface – Inside Storage Tank Weekly Target Monthly Target
Food Contact Surface – Filler Nozzle Weekly Levels Monthly Levels
Food Contact Surface – Foil Lidding Weekly TVC < 10 Monthly Salmonella Absent
Non-Food Contact Surface – Inside Door Filler Weekly Y&M < 10 Monthly Listeria Absent
Cabinet Weekly Entero Entero < 1 Monthly E.Coli O157 Absent
Non-Food Contact Surface – Cleaning Equipment Weekly E.Coli E.Coli < 1 Monthly Staph *Absent
Non-Food Contact Surface – Floor under Filler Monthly Quarterly aureus* Contact
Non-Food Contact Surface – Outside Storage Tank Monthly Quarterly *< 10
Non-Food Contact Surface – Drain Monthly Quarterly Non-
Non-Food Contact Surface – Wall Monthly Quarterly contact
Non-Food Contact Surface – Floor near Entrance Monthly Quarterly
Non-Food Contact Surface – Hand Wash Sink Monthly Quarterly
4.12 Waste/Waste Disposal
Systems should be in place to minimise the accumulation of
waste including arrangements to control the collection,
collation and disposal of waste material.
4.13 Management of Surplus Food & Products for
Animal Feed
Surplus customer branded products should
be disposed of as per customer
requirements and the brand name removed
from the products whilst under control of
the factory.
Products intended for animal feed should
be segregated, protected from
contamination.
Section 4.14 Pest Management
The whole site shall have an effective preventive pest

management programme in place to minimise the risk of
infestation and resources shall be available to respond
rapidly to any issues which occur to prevent risk to products.
Changes to Section 4.14 Pest Control Management
The whole site shall have an effective preventive pest

control programme in place….......
Pest management programmes shall comply with applicable
legislation.
Changes to Section 4.14 Pest Management
Changes to Section 4.14 Pest Management
Adequate measures in place to prevent

birds from entering buildings or roosting
Section 4.15 Storage Facilities
Section 4.16 Dispatch and Transport
✓ Dispatch and transport procedures

✓ Vehicle inspection
✓ Vehicle temperature control
✓ Vehicle maintenance and hygiene
✓ Transport procedures
✓ Third-party contractors
All vehicles or containers used for the transport of raw

materials and the dispatch of products shall be fit for
purpose.
Section 5 Product Control
5.1 Product Design & Development
5.2 Product Labelling
5.3 Management of Allergens - Fundamental
5.4 Product Authenticity Claims and Chain of Custody
5.5 Product Packaging
5.6 Product Inspection and Laboratory Testing
5.7 Product Release
5.8 Pet Food
5.1 Product Design & Development
5.2 Product Labelling
Changes to Section 5.2 Product Labelling
5.2.5 Where cooking instructions are provided to ensure product
safety, they shall be fully validated …...
Section 5.3 Management Of Allergens
Fundamental requirement - A system must be in place for the
management of allergenic materials which minimises the risk of
allergen contamination of products and meets legal requirements
for labelling in the country of sale.
Section 5.4 Product Authenticity Claims and Chain of Custody
Changes to Section 5.4 Product Authenticity Claims and
Chain of Custody
The output of the vulnerability assessment shall be a documented
vulnerability assessment plan.
Section 5.5 Product Packaging
Problems with obsolete packaging (including labels)
Accountants!
Problems with obsolete packaging (including labels)
Accountants!
☒Stock write off/Value

☒Cost of disposal
Excess stock due to poor planning/stock control

Section 5.6 Product Inspection and Laboratory
Testing
Product inspection and analyses which are critical to
confirm product safety, legality, integrity and quality,
The significance of laboratory results shall be
understood and acted upon

Section 5.7 Product Release
New section 5.8 PET FOOD
Section 6 Process Control
6.1 Control of Operations

6.2 Labelling and Pack Control
6.3 Quantity - Weight, Volume and Number Control
6.4 Calibration and Control of Measuring and
Monitoring Devices
6.1 Control of Operations
Fundamental Requirement - The site shall operate to

documented procedures and/or work instructions that
ensure the production of consistently safe and legal
product with the desired quality characteristics, in full
compliance with the HACCP food safety plan.
Changes Section 6.1 Control of Operations
Equipment Settings
Section 6.2 Labelling and Pack Control
Fundamental Requirement - The management controls of
product labelling activities shall ensure that products will be
correctly labelled and coded.
Labelling and
Pack Control
Best Before
17/10/19
Best Before
17/10/19
Commitment to Food Safety
Certification
FDA Recalls Reported May 2013
Allergen Labelling Related Other
Undeclared walnuts Listeria monocytogenes
Undeclared sulfites Salmonella
Undeclared nuts Listeria monocytogenes
Undeclared peanuts Salmonella
Undeclared milk Salmonella
Undeclared milk and soy Foreign material
Undeclared eggs Salmonella
Undeclared milk May contain fragments of clear plastic
Undeclared walnuts and milk
Undeclared wheat, eggs, and milk
Undeclared egg and soy
Undeclared almonds, coconut and soy
Undeclared milk and soy
If you take nothing else from this presentation today then note this - > 60% of
Recalls in May were related to Allergen Management/Labelling/Information
International Food Safety & Quality
6/26/2013 143
Network
FDA Recalls, Market Withdrawals & Safety Alerts
Date Brand Product Description Reason / Problem Company
01/23/2019 Simple Truth Organic Fruit Puree with Nonfat Greek Undeclared Milk Perrigo Company
Yogurt pouch
01/17/2019 Ottogi Various noodle products Undeclared egg Ottogi America, Inc.
01/07/2019 Lunch Box Italian Sub and Ham & Cheese Listeria monocytogenes Grand Strand Sandwich Company
Sandwiches and Ham & Swiss potential contamination
Croissants
01/04/2019 Shamrock Farms 2% Reduced Fat Vanilla Half Undeclared almond Shamrock Farms
Gallon Milk
01/04/2019 Clancy’s Wavy Potato Chips Undeclared milk Olde York Potato Chips
01/02/2019 Oskri, Thrive Organic Sunflower Butter Potential Listeria Oskri Organics Corporation
monocytogenes
contamination
12/26/2018 Eat Smart Salad Shake Ups several flavors Listeria monocytogenes Apio Inc.
potential contamination
12/20/2018 Funky Chunky Nutty Choco Pop Undeclared Almond and Funky Chunky, LLC
Cashew Tree Nut
5.1 Product
Design &
Development
6.2 Labelling
5.2 Product
and Pack
Labelling
Control
Packaging
6.1 Control of
and Label 5.3
Management
Operations
Control of Allergens -
Fundamental
5.4 Product
Authenticity
5.5 Product
Claims and
Packaging
Chain of
Custody
Product Label and Labelling Control
3.5.2.2 - changes to raw materials (including labels) are communicated to goods receipt
personnel
5.5.3 - a procedure to manage obsolete packaging (including labels)
6.2.1 - control of offline coding and printing of packaging materials
6.2.4 - good practices for online verification equipment (e.g. bar code scanners)
7.1.5 - relevant personnel receive training on the labelling and packing processes
Section 6.3 Quantity – Volume, Weight and
Number
Changes to Section 6.3 Quantity – Volume, Weight
And Number
Procedures for the operation and testing of online check
weighers
Section 6.4 Calibration and Control of Measuring
and Monitoring Devices
Identify and control measuring equipment used to monitor

critical control points and product safety, legality and quality.
Section 7 Personnel
7.1 Training: raw material handling, preparation, processing,

packing and storage areas
7.2 Personal hygiene: raw material handling, preparation,
processing, packing and storage areas
7.3 Medical screening
7.4 Protective clothing: employees or visitors to production
areas
7.1 Training
The company shall ensure that all personnel performing work
that affects product safety, legality and quality are demonstrably
competent to carry out their activity, through training, work
experience or qualification.
7.1 Training: raw material handling, preparation,
processing, packing and storage areas
There are specific requirements for:

Initial training and supervision
Critical control point (CCP) training
Documented training programme
Allergen training
Training on the site’s labelling and packing processes
Training records
Competency review
7.1 Training
Section 7.2 Personal Hygiene
Section 7.2 Personal Hygiene
✓ Documented personal hygiene policy
✓ Hand-washing  
✓ Cuts and grazes   
✓ Personal medicines
Section 7.3 Medical Screening
✓ Illness notification procedures for

employees
✓ Illness notification procedures for
visitors to the site
✓ Documented infectious disease
procedure
Section 7.4 Protective Clothing: Employees or
Visitors to Production Areas
Section 8 High-Risk, High-Care and Ambient High-
Care Production Risk Zones

8.2 Building fabric
8.3 Maintenance
8.4 Staff facilities
8.6 Waste/waste disposal
8.7 Protective clothing
8.3 Maintenance in High-Risk
and High-Care Zones
There are addition requirements for:
✓ Control of equipment removal and return

✓ Control of portable equipment
8.6 Waste/Waste Disposal in High-Risk, High-Care
Zones
Waste disposal systems shall ensure that the risk of
contamination of products is minimised
8.7 Protective Clothing in High-Risk and High-Care
Zones
Laundry Operation: Segregation between clothes for high-

risk, high-care and low-risk areas
Section 9 Requirements for Traded Products
9.1 Approval and performance monitoring of

manufacturers/packers of traded food products
9.2 Specifications
9.3 Product inspection and laboratory testing
9.4 Product legality
9.5 Traceability
Some Useful Links:
FDA Food Defense Plan Builder

Food Authenticity Network
The National Food Crime Unit
RASFF - Food and Feed Safety Alerts
Fight food fraud
Food Fraud Vulnerability Assessment
Guidance on Allergen Management
European Food Safety Authority
BRC Global Standard for Food Safety Resources
Some Food Safety Fridays Webinars that might be useful:
BRC Issue 8 – Root and Branch Review and How to Address the Requirements
How to Set Up a Sampling Zone for an Environmental Monitoring Program
Food Safety Culture Development
Product Development – How Product Developers affect Food Safety
Best Practices for Effectively Implementing an ATP Sanitation Verification System
Allergen Management
Implementing a BRC Issue 8 Compliant
Food Safety Management System
Any Questions
Tony Connor
Chief Technical Advisor, IFSQN

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Implementing a BRC Issue 8

Compliant Food Safety Management

BRC GLOBAL STANDARD FOR FOOD SAFETY

BRC Global 3 Food Safety

Sites with product requiring high-risk, high-care or ambient high-care facilities

• Senior Management Implementation

• Implementation of Good Manufacturing Practices

• Food Safety Quality Management System Implementation

• Food Safety Plan/HACCP Implementation & Training

• Product and Process Controls

• Internal Audits & Corrective Actions

• Management Reviews & Actions for Improvement

• Self Assessment & Corrective Actions

1.1.1 Documented Policy to produce safe, legal

Plan for development

Monitoring & Policies &

1.1.3 Documented Food Safety Objectives

1.1.4 Senior Management Review

1.1.6 New: The company

1.1.7 Human and Financial Resources

2.9 Establish Critical Limits For Each CCP

2.10 Establish A Monitoring System For Each CCP (Equivalent to Codex

2.12 Establish Verification Procedures

2.13 HACCP Documentation and Record-keeping (Equivalent to Codex

2.14 Review The HACCP Plan

HACCP Plans should include:

2 The food safety plan – HACCP

✓ Incorporating Codex Alimentarius HACCP principles

Fundamental requirement – verify

Certificate and Scope Validation Directories:

Where this supplier audit is completed by a 2nd

Process for the ongoing

Approval and monitoring

Supplier & Batch QMR Goods In Record

Ingredient & Batch QMR Storage Record

Controls for products requiring high-risk, high-

The fabric of site, buildings and

✓ The water supply

There are requirements for:

There are requirements for:

✓ Documenting Temporary repairs

Storage and handling of non-food chemicals

The risk of product contamination shall be reduced or

Typical equipment to be considered may include:

Metal Detectors and X-Ray Equipment

Metal detection equipment shall be in place unless risk

Based on risk assessment, procedures shall be implemented

Priority Order for Environmental Sampling

The whole site shall have an effective preventive pest

The whole site shall have an effective preventive pest

Adequate measures in place to prevent

There are requirements for:

✓ Dispatch and transport procedures

All vehicles or containers used for the transport of raw

☒Stock write off/Value

Excess stock due to poor planning/stock control

6.1 Control of Operations

Fundamental Requirement - The site shall operate to

Identify and control measuring equipment used to monitor