BRCGS Food Version 9

INTEGRA
BRCGS Food Safety Issue 9

What's changed?
BRCGS Food Safety Issue 9 12/12/2022 1

Important changes
INTEGRA
Why upgrading?
GFSI Benchmark Continued evolution of Product recalls and

Sector specific product safety culture withdrawals (and
requirements and processes
for slaughter fraud prevention for managing
Changes in global food

Emerging new products
safety legislation and
New auditing techniques safety risks
Standards e.g.: Codex,
and approaches High risk/High Care
ISO
Products
22003-2

Important changes
INTEGRA
Timeline
Mandatory from 01 February 2023 forwards

Important changes
INTEGRA
Scope of the standard
The Standard sets out the requirements for the manufacture, processing and
packing of:
Pet foods and

Animal feed
Raw materials or
Processed foods Primary products Animal feed is Traded Products
ingredients
new within
BRCGS Issue 9

Important changes
INTEGRA
Change in the unannounced audits window
 The unannounced audit may occur at any stage within the last 4
months of the audit cycle.
 A site may select up to 10 non-audit days

 Sites with a six-month audit window (e.g. sites certified to the C or D grade standard) may
nominate up to 5 days

Important changes
INTEGRA
Audit option in issue 9
 Option 1 – Announced audit program (with mandatory unnanounced audit every 3

years)
 Option 2 – Blended announced audit program (with mandatory unnanounced audit

every 3 years)
 Option 3 – Unanounced audit program

Important changes
INTEGRA
Blended announced audit program
 The audit is split into two separate parts: a remote audit followed by an
on-site audit.
 The blended audit option is available for announced recertification
audits only and not for initial audits
• Announced remote audit
Part 1 • Occurs within the 56 days prior to

the audit due date
• Announced on-site audit
Part 2 • Occurs within 28 days of the remote

audit (Part 1)

Important changes
INTEGRA
Changes to the requirements

1.1 Senior management commitment and continual improvement
 Policy to include commitment to continuously improve the site’s food safety and
quality culture
 The food safety culture plan shall include measures needed to achieve a positive
culture change:
 Clear and open communication on product safety
 Training
 Feedback from employees
 The behaviours required to maintain and improve product safety processes
 Performance measurement of activities related to the safety, authenticity, legality
and quality of products
 The plan shall be reviewed and updated at least annually, at a minimum.

Important changes
INTEGRA

1.1 Senior management commitment and continual improvement
 The most senior production or operations manager shall participate in the opening
and closing meetings and a member of the senior management team shall be
available for a discussion on effective implementation of the food safety and quality
culture plan

Important changes
INTEGRA

1.2 Organisational structure, responsibilities and management authority
 Staff shall be aware of the need to report risks or evidence of unsafe products
 Food safety, quality, legality and authenticity remains the responsibility of the site
when using external expertise

Important changes
INTEGRA

2. The food safety plan – HACCP
 Where the control of a specific food safety hazard is achieved through prerequisite
programmes or control measures other than CCPs, this shall be validated
 HACCP or food safety plans shall be validated prior to any changes which may
affect product safety, to ensure that the plan will effectively control the identified
hazards before implementation.

Important changes
INTEGRA

3.4 Internal audits
 Fabrication inspections are more clearly described (e.g. doors, walls, facilities and
equipment)
 The results shall be reported to the responsible personnel
 Corrective actions, and timescales for their implementation, shall be agreed and verified
 Results of the inspections shall be reviewed in the management review meetings

Important changes
INTEGRA
3.4 Management of outsourced processing
 Definition has been expanded: Outsourced processing is any intermediate process step
(including production, processing or storage). During outsourced processing, the
product leaves the site for the completion of the outsourced processing before
returning to the site. The audited site may or may not complete the additional packing
or processing steps of the product.
 Outsourced process shall form part of the site’s food safety plan (HACCP plan).
 Requirements for outsourced processing shall be agreed in a service specification
(similar to a finished product specification).
 Outsourced processing operations shall maintain product traceability
 A documented acceptance procedure for products where part of the processing has
been outsourced shall be established.

Important changes
INTEGRA
3.7 Corrective and preventive actions
 Corrective action procedure for handling and correcting issues and include the root
cause analysis and implementation of preventive action
 Where a non-conformity places the safety, authenticity or legality of a product at risk, or

where there is an adverse trend in quality, this shall be investigated and recorded

Important changes
INTEGRA
3.11 Management of incidents, product withdrawal and product recall
 Significant food safety, authenticity or legality incident shall be notified to the CB

within 3 working days.
 The company shall provide sufficient information (corrective action, root cause analysis,
preventive action plan) within 21 calendar days.

Important changes
INTEGRA
4.1 External standards and site security
 Visitor recording system shall be in place
 Visitors, contractors and staff need to be aware of procedures for access
 All visitors must have someone on site responsible for them

Important changes
INTEGRA
4.2 Food Defence
 Responsible for food defence shall understand potential food defence risks at the site
and the principles of food defence
 Where there is a legal requirement for specific training, this shall be in place.

Important changes
INTEGRA
4.4 Building fabric, raw material-handling, preparation, processing,

packing and storage areas
 Elevated walkways supplemented with access steps or mezzanine floors

 Care needs to be taken in design, cleaning and maintaining areas above,
adjacent/near production
 Plastic strip curtains shall be maintained in good condition, clean, fitted correctly and
shall not pose a food safety risk.

Important changes
INTEGRA
4.6 Equipment
 A documented purchase specification is needed for any new equipment:

 Detailing the requirements
 Reference to relevant legislation
 Requirements for contact surfaces
 Suitable for intended use
 Evidence that equipment meets the site requirements must be available prior
to supply

Important changes
INTEGRA
4.6 Equipment
 Documented risk-based commissioning procedure shall be in place
 Documented cleaning and inspection before use
 Inspected by authorised staff before being accepted
 Update of existing site procedures (e.g. training, operating procedures, cleaning,

environmental monitoring, maintenance schedules,…)
 Design and placement shall ensure effectively cleaning and maintenanced

Important changes
INTEGRA
4.6 Equipment
 There must be a documented procedure which covers how food safety and equipment
integrity will be maintained during movement of the equipment
 Procedures shall be in place to bring equipment back into use, including cleaning
 Equipment not used shall be cleaned and appropriate stored
 Equipment stored in production and storage areas shall be kept clean
 Stored equipment that is not daily used shall be cleaned prior to use

Important changes
INTEGRA
4.6 Equipment
 Mobile equipment shall not pose a risk to the product
 Where the use of mobile equipment in external areas cannot be avoided and poses a
risk to the product, the equipment shall be cleaned and disinfected prior to entering
production areas.
 Battery-charging equipment shall not be stored where they are a possible source of
product contamination

Important changes
INTEGRA
4.9.6 Other physical contaminants

 Physical contaminants are no longer limited to pens, a longer list of examples is
given
 Procedures shall be implemented to minimise all types of foreign-body contamination
4.10.3 Metal detectors and X-ray equipment

 New clause on X-ray
 It is important that the effectiveness is verified
4.10.7 Other foreign-body detection and removal equipment

 New clause on all other foreign-body detection than metal dection and X-ray
 Again the effectiveness must be verified

Important changes
INTEGRA
5.1 Product design/development
 A process for new product development and changes to existing products must be
formalised
 Safety, legality and integrity maintained
5.2 Product labelling

 Label made by customer:
 Information for accurately creating

 Information on changes

Important changes
INTEGRA
5.4 Product authenticity, claims and chain of custody
 Responsible for food fraud shall understand potential food fraud risks of raw materials
and the principles of vulnerability assessment.
 Minimal yearly review of the assessment and whenever there is:

 A change in raw materials or a supplier
 Emergence of a new risk
 A significant product safety incident on authenticity

Important changes
INTEGRA
5.6 Product inspection, on-site product testing and laboratory analysis
 Issue 8 sections 5.6.1 Product inspection and testing and 5.6.2 Laboraty testing have
been combined.
5.8 Pet food and animal feed

 Additonal requirements on
 Supplier approval for all medicated raw materials
 Specific staff training on the correct handling of medicated materials
 Waste disposal mechanisms that include the safe and legal disposal of medicated raw materials
and products
 Meet the relevant legislative requirements both in the country of production and in the
country of sale

Important changes
INTEGRA
5.9 Animal primary conversion
 New section
 Risk assessment for potential prohibited substances
 There must be traceability of all the edible parts of the carcass
 Establish postslaughter times and temperatures to ensure product safety
6.1 Control of operations
 The site must consider and manage any potential product safety, authenticity and
legality risks of products or materials outside of the scope of the BRCGS audit

Important changes
INTEGRA
7.4 Protective clothing: staff or visitors to production areas
 Clarification on laundering of protective clothing
 Home laundering is exceptional but acceptable where:
 Protective clothing is not used for food safety purposes
 Protective clothing is used in low risk areas or enclosed products

Important changes
INTEGRA
8.2 Building fabric in high-risk and high-care zones
 Documented procedure exist to ensure removeable walls are used in a control way
 Tight fitting
 Their use is managed
 Movement only by trained and authorised staff
 Cleaning and reconditioning procedures in place and completed prior to production
8.5 Housekeeping and hygiene in high-risk and high-care zones

 CIP equipment shall not pose a risk

Important changes
INTEGRA
9.1 The food safety plan – HACCP
 The company shall:
 Have a HACCP or food safety plan specifically for the traded products
 Incorporate the traded products into its existing HACCP

INTEGRA
Good luck
THANK YOU

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INTEGRA

BRCGS Food Safety Issue 9

BRCGS Food Safety Issue 9 12/12/2022 1

GFSI Benchmark Continued evolution of Product recalls and

Changes in global food

BRCGS Food Safety Issue 9 12/12/2022 2

Mandatory from 01 February 2023 forwards

BRCGS Food Safety Issue 9 12/12/2022 3

Scope of the standard

Pet foods and

BRCGS Food Safety Issue 9 12/12/2022 4

Change in the unannounced audits window

 A site may select up to 10 non-audit days

BRCGS Food Safety Issue 9 12/12/2022 5

Audit option in issue 9

 Option 1 – Announced audit program (with mandatory unnanounced audit every 3

 Option 2 – Blended announced audit program (with mandatory unnanounced audit

 Option 3 – Unanounced audit program

BRCGS Food Safety Issue 9 12/12/2022 6

Blended announced audit program

• Announced remote audit

Part 1 • Occurs within the 56 days prior to

• Announced on-site audit

Part 2 • Occurs within 28 days of the remote

BRCGS Food Safety Issue 9 12/12/2022 7

Changes to the requirements

BRCGS Food Safety Issue 9 12/12/2022 8

Changes to the requirements

BRCGS Food Safety Issue 9 12/12/2022 9

Changes to the requirements

BRCGS Food Safety Issue 9 12/12/2022 10

Changes to the requirements

BRCGS Food Safety Issue 9 12/12/2022 11

Changes to the requirements

 The results shall be reported to the responsible personnel

 Results of the inspections shall be reviewed in the management review meetings

BRCGS Food Safety Issue 9 12/12/2022 12

Changes to the requirements

3.4 Management of outsourced processing

BRCGS Food Safety Issue 9 12/12/2022 13

Changes to the requirements

3.7 Corrective and preventive actions

 Where a non-conformity places the safety, authenticity or legality of a product at risk, or

BRCGS Food Safety Issue 9 12/12/2022 14

Changes to the requirements

3.11 Management of incidents, product withdrawal and product recall

 Significant food safety, authenticity or legality incident shall be notified to the CB

BRCGS Food Safety Issue 9 12/12/2022 15

Changes to the requirements

4.1 External standards and site security

 Visitor recording system shall be in place

 Visitors, contractors and staff need to be aware of procedures for access

 All visitors must have someone on site responsible for them

BRCGS Food Safety Issue 9 12/12/2022 16

Changes to the requirements

4.2 Food Defence

BRCGS Food Safety Issue 9 12/12/2022 17

Changes to the requirements

4.4 Building fabric, raw material-handling, preparation, processing,

 Elevated walkways supplemented with access steps or mezzanine floors