Standards in the food industry are constantly evolving. It is an industry that never sleeps — the desk lamps are always on as food scientists and other industry experts tirelessly research, analyse, review, collaborate, assess, and improve the standards we work with every day. For all of us that work so intimately with food safety standards, we take a deep breath and wonder how much work the new changes will bring. We can draw comfort that Issue 9 of the BRCGS Global Food Safety Standard will not require a revamp of our entire food safety system, however, it does ask that we focus our attention on strengthening the fundamental components of our food safety system to improve food safety controls.

Follow along as we provide a summary of the key changes and how these will impact your food safety system.

How much has changed in Issue 9?

Although a few minor changes to the wording have been made to aid clarity, most of the clauses have remained unchanged. Sites can focus on the key changes which are easy to identify in the BRCGS Global Standard Issue 9 Guide to Key Standards and will ensure that you are ready for the Certification to Issue 9.

The main areas that have changed are:

• Product Safety Culture
• HACCP/Food Safety Plan
• Outsourced Processing
• Emphasis on Root Cause Analysis
• Equipment
• Animal Primary Conversion
• Requirements For Traded Products
• Updating and Reviewing of Additional Modules
• Colour-Coding of Audit Requirements
• Changes to Audit Protocol

Let us explore the changes in these areas in more detail.

1. Product Safety Culture

Requirement 1.1.2 has experienced a major revamp with an emphasis on the Food Safety Culture plan that needs to include measures that positively impact culture change.

The plan should include activities such as:

• Clear and transparent communication on food safety
• Training
• Employee feedback
• Identifying behaviours that are needed to maintain and improve processes impacting product safety
• Performance measurement of activities that impact product safety, quality, legality, and authenticity

There should also be an action plan as to how the above activities will be implemented and measured with time frames for completion, as well as how the activities will be reviewed to determine their effectiveness.

• HACCP/Food Safety Plan

There are a few important changes to note in certain clauses.

Clause 2.3.2 refers to the sources of information that must be collected, maintained, documented, and updated for the hazard analysis. It has been amended to include additional examples of information sources, such as a copy of any existing HACCP plans and a map of the premises and equipment layout.

Clause 2.6 refers to the verification of the process flow diagram. Here, the accuracy of the flow diagram needs to be reviewed using an on-site audit at least annually, as well as whenever changes to the process occur. This is to ensure that any changes are incorporated into the HACCP Plan promptly to manage potential hazards effectively.

Clause 2.7.2 has also been amended to ensure emphasis on the significant hazards i.e., those that are reasonably expected to occur at unacceptable levels when conducting the hazard analysis.

Clause 2.7.4 is new. Where specific hazards are controlled via a pre-requisite programme or a control measure other than a critical control point (CCP), these controls will need to be documented and their adequacy validated.

Clause 2.12.1 is also new. It requires that any changes to the HACCP or food safety plans that may affect product safety must be validated to ensure that identified hazards are effectively controlled before implementation.

Clause 2.14.1 in Issue 8 has become Clause 2.12.3. The colour-coding of the requirement is now a dual colour-coding which means that the review of the HACCP Plan should include an audit of the production facilities, GMPs on-site, as well as the system i.e., documents and records.

• Outsourced Processing

Clause 3.5.4.1. Here, the definition for Outsourced Processing was clarified as: “Any intermediate process step (including production, processing or storage) in the manufacture of a product which is outsourced to a third party or undertaken at another site, and subsequently returned to the site”. The outsourced process needs to be declared to the customer and approval granted where required.

Clause 3.5.4.2. The approval and monitoring process of outsourced suppliers has been updated to reflect the GFSI requirements. The audit scope for supplier audits has also been expanded to include product security, as well as a food defence plan and product authenticity plan.

Clause 3.5.4.3. This clause has been modified to emphasise the importance of identifying and controlling any hazards that are associated with the outsourced process and including these in the site’s HACCP Plan.

Clause 3.5.4.4 is new. It requires a formal documented service specification that has been agreed to with the service provider. The objective of the specification is to ensure product safety, legality, quality, and authenticity and should include any specific product handling instructions.

Clause 3.5.4.5 is also new. It requires that the outsourced operation is conducted as per the documented service specification and that product traceability is maintained.

• Corrective and Preventative Actions

Clause 3.7.1 has been expanded to elaborate on the need for a root cause analysis.

Clause 3.7.2 has also been expanded to include the requirements for a root cause analysis to prevent the recurrence of non-conformities and to include ongoing improvements when trends indicate a significant increase in a type of non-conformity.

Consult the BRCGS Issue 9 Interpretation Guide for valuable guidance on the need for a root analysis tool and helpful examples of root cause analysis techniques.

• Equipment

In Clause 4.6, the scope of the description of equipment within the statement of intent has been clarified as all production and product handling equipment.

Clause 4.6.1 has been expanded to include the need for a formal purchase specification for any new equipment purchased from a manufacturer — refurbished as well as second-hand equipment. The specification document should specify legal requirements where relevant, suitability for food contact, as well as the intended use of the equipment.

Clause 4.6.2 focuses and elaborates on the design aspects of equipment which must be considered to ensure that equipment is designed to prevent product contamination.

Clause 4.6.3 is new. It requires the following:

• A documented commissioning procedure based on risk when installing new equipment on site
• A documented hygiene clearance procedure after installation
• An inspection of the equipment by an authorised staff member before its operation
• An update to other site procedures affected by the new equipment

Clause 4.6.4 is another new clause that requires product safety and equipment integrity be considered before moving any static equipment.

New clause, Clause 4.6.5, requires that, where equipment is not used or taken out of service, it should be cleaned before storage and stored in a way that does not pose a risk to the product. Equipment stored in the production area should be kept clean, and cleaned and sanitised (where necessary) before using it again.

Clause 4.6.6 was introduced to ensure that, where mobile equipment such as forklifts and pallet jacks are used in open product areas, they do not pose a risk to product safety. Where there is any risk, the equipment should be cleaned and disinfected before entering the production areas.

New clause, Clause 4.6.7, refers to battery-charging equipment and requires that, where they pose a food safety risk to products, they should not be stored in open product areas unless the batteries are fully sealed and/or maintenance-free.

• Animal Primary Conversion

Clause 5.9 includes a new statement of intent that requires sites to have controlled processes that ensure products are safe and fit for their intended use.

Clause 5.9.1 is a new clause that requires sites to complete a risk assessment where the country of sale or intended use has specific legislative requirements relating to prohibited substances (e.g., pharmaceuticals, veterinary medicines, heavy metals, and pesticides). The results of the risk assessment should also be included in the supplier approval and monitoring process so that risks are managed within the supply chain.

New clause, Clause 5.9.3, requires that traceability procedures be implemented and maintained for all edible parts of the carcass.

Clause 5.9.4 is a new clause which requires defined time and temperature requirements for chilled or frozen edible parts of the carcass for all post-slaughter processes such as cooling, processing, storage, and transport.

•  Requirements For Traded Products

Food Safety Plan Clause 9.1 is a new section that requires sites to have a HACCP plan for all processes that it is responsible for to ensure that hazards are identified, and risks are managed.

New clause, Clause 9.1.1, deals with the requirement for a HACCP or food safety plan specifically for traded products handled on-site. The site can include the traded products and processes it is responsible for into its existing HACCP plan.

• Updating And Reviewing of Additional Modules

The following additional voluntary modules have been reviewed and updated.

• Module 10: Global G.A.P Chain of Custody
• Module 11: Meat Supply Chain Assurance
• Module 13: Meeting FSMA requirements for Food

• Colour-Coding of Requirements

Activities that are audited during the assessment of the production areas and facilities are colour-coded to differentiate from those activities that are audited as part of systems i.e., documentation and records.

The colour coding also identifies which clause requirements may be audited remotely as part of a blended audit and which must be audited when the auditor is on site.

1. Changes To Audit Protocol

There are three key changes to note here.

• Announced audits are to include a mandatory unannounced audit every three years.
• Blended announced audit programmes are split into two parts, a remote audit followed by an on-site audit.
• The audit protocol for unannounced audits has remained largely unchanged with the Issue 9 revision.

When will companies be audited against Issue 9 of the Global Standard for Food Safety?

Companies will be audited against the new Issue 9 standard from 1 February 2023. Certificates issued against Issue 8 remain valid for the duration indicated on the certificate.

How Can Entecom Help You?

Entecom offers the following training courses to help your company align with the BRCGS Global Food Safety Issue 9 requirements:

• BRCGS Global Food Safety Issue 8 to Issue 9 Bridging Course
• BRCGS Global Food Safety Issue 9 Implementation Course
• Food Safety Culture for Management
• Root Cause Analysis Workshop

We also offer Digital Compliance Software to help you manage your BRCGS Food Safety System with ease.

Contact us on info@entecom.co.za or (041) 3661970 for more information.

Download the BRCGS Global Standard Food Safety Issue 9 eBook here: https://www.entecom.co.za/brcgs-global-standard-food-safety-issue-9-whats-changed/