BRCGS FOOD SAFETY ISSUE 9: WHAT TO EXPECT
1 JULY 2022 ◦15 MINUTES
In this episode, we speak to Food Technical Manager at LRQA, Mark Fincham to discuss the BRCGS Food Safety Issue 9, which is scheduled to be published in August 2022.
What is BRCGS standard?
Well the BRCGS standard is a food safety standard and it is part of a suite of products which the BRCGS offer. The BRCGS food safety, or food standard is a standard which has been around a good number of years now, and the first issued one I believe was about fifteen, twenty years ago so it’s been going for quite some time.
Food safety standard which the BRCGS covers is what is called a GFSI benchmark standard. Now GFSI stands for Global Food Safety Initiative and they’re a group of stakeholders in food safety, both food manufacturers and also retailers and they have put together a benchmark of requirements and it means that you can benchmark other food safety standards as comparable.
So BRCGS is compared with the IFS standard and the FSSC 22000 standard, they’re the main standards which are in the benchmarking scheme but there are others. So the BRCGS food safety standard is a standard which is quite commonly requested by retailers and other food manufacturers or suppliers and it gives a consistency or a certification that the company or the manufacturer is making a food product which is of a quality and food safety standard and it’s something that certification bodies audit against.
As I said there are currently, we’re on issue eight and we’ll soon be moving to issue nine of the standard. The standard has developed over the years incorporating new ideas and concepts and keeping up-to-date, and also keeping up-to-date with the benchmarking requirements that I mentioned earlier with GFSI.
The current standard food eight has been around and operating since August 2018 so every three or four years the BRCGS update the standard and the process is now taking place for BRCGS version nine.
As we stand at the moment there is a draft version of BRCGS version nine which was published for public consultation in December. The standard itself, BRCGS version nine, is due to be published in August 2022 so in a few months’ time and this will replace the current version, version eight in six months’ time. So there is a hard change over on the 1st of February, so all audits planned after the 1st of February will be against the new version, version nine not against version eight. The current version eight is still the one you will have an audit against at this moment in time until the 1st of February.
You mentioned BRCGS food safety issue nine which will be published later this year, can you talk a bit more about what changes we can expect with this update?
Yes, certainly the standard has been changed but not dramatically. I think a point to make is that it’s more an evolution of ideas rather than a radical change in requirements and this is not uncommon with all the versions of the BRC standards that have being published, they don’t often make sort of seismic jumps in requirements, it’s a transition or a working on the existing requirements and BRCGS version nine is fundamentally following that pattern.
One of the key changes from the version eight standard was this aspect of bringing in food safety culture and development of food safety culture, and in version nine this has now been taken a stage further. So now they’re looking at introducing ways and concepts that you can actually develop a positive understanding of the importance of food safety culture within the organisation. So they’re looking at means of developing systems and mechanisms to improve everybody’s understanding of food safety, quality and making sure that this is actually developed and pushed through in more detail than the previous version of the standard. So it’s a slight change in emphasis, they’re putting more emphasis on the communication side of things.
The other interesting areas where there’s been some change is that in the policy, the old policy, the policy requirements in the issue eight of the standard mainly covered a commitment to meeting food safety and legal requirements but it’s also included a commitment to improving quality culture, so again there is development on this quality culture theme. It’s actually quite an important concept to try and improve and it’s interesting that you can actually have organisations who have excellent procedures but if the quality culture is not right in the organisation, then the implementation of these procedures and the system often isn’t particularly effective. So this is an area that was introduced in version eight and augmented and built upon in issue nine.
Another area where there’s been a change is that the standard has always previously talked about food safety and quality but now it’s also covering integrity and authenticity into the standard. So where there are references to making the requirements to actually set a system up to meet these points is also to bring authenticity.
Now this is coming back to a problem or a growing problem of actually ensuring that the products you’re manufacturing is authentic, you think back to scandals around horse meat a few years ago, ten or fifteen years ago and the standard has been developing mechanisms for assessing authenticity of the products and the materials that go into the products, but this again is bringing this idea of developing systems to meet food safety quality and authenticity and this is mentioned in a number of places in the standard so again it’s a slight change in emphasis of the requirements.
The other areas which the standard has amended are mainly minor details, so for instance in Section Three which is the quality management system there is slight tweaks to the requirements for carrying out a review of plant services on an annual basis which wasn’t so obvious in the previous version of the standard. And in Section Four which is about the way of doing things, the actual manufacturing side of it there’s been actually very few changes but there’s little like a need to actually assess plastic strip curtains, so it’s that kind of minor change which is happening throughout the standard.
Another area which is probably worthy of note is that in Section Nine which is the traded goods section, so this is a section which is a voluntary section you can choose to be audited against or not and this is for people who are bringing products they don’t manufacture on site but sell it. And there’s now a requirement to have a HACCP covering the food safety requirements of that product in the system to actually ensure that the product you’re bringing in has been assessed for its safety and also, its authenticity.
So if you’re looking actually at the changes in the requirements of the standard these are actually quite few and far between, other than the comments in the areas I’ve talked about already. But one point which is worthy of noting is that the protocol has been updated to bring in a number of recent changes in the way the audits are taking place and there’s two notable points here.
Firstly and it’s coming out of the Covid pandemic is that you can have an option to have what is known as a blended audit, a blended audit is where 50% of the audit is carried out remotely and 50% is carried out onsite. The onsite part is not surprisingly the audit of the manufacturing operation so the doing bits, the physical activities that take place, and then the offsite remote audit is the audit of the records, management system elements. Now this was introduced about six months ago, a year ago now probably but is now a formal and firm part of the standard and an option you could choose if you so wanted to.
The other part which is a change in the protocol is that, and again this is a GFSI requirement on the announced audit scheme there is now a requirement to have one in the three, a one audit in a three year cycle which is unannounced. This process has started already and what the standard is doing is really putting this requirement into the protocol so in simple terms in a cycle, and the cycle actually started in February 2021, in a three year cycle one audit has to be unannounced and this process is actually undertaken now and you will be receiving an unannounced audit probably in the near future if you haven’t received one already if you are in the announced scheme. But the standard does define the controls for this apart from being, so they’re communicated separately so it’s bringing it up-to-date. And the protocol changes are probably slightly more significant than some of the changes in the actual standard itself.
So if I had an overall comment on the process, it’s minor tweaking to the standard, it’s building on the quality culture and really bringing in this idea that the standard is looking at food safety, quality, and authenticity.
What does this update mean for BRCGS Version Eight users and could you also explain what it would mean for those who are new to the BRCGS food safety standard entirely.
What I’ll do first is I’ll cover off what happens if you currently hold a BRC food eight certificate. As I said before the standard itself is published in August of this year, that’s August 2022. What the BRC have done and tended to do for the last few years is they have a six month implementation period, and this six month implementation period is there to allow users of the standard to review their systems and build in the new requirements. And for certification bodies to actually go through the process of training their auditors to be ready for audits against the new version of the standard.
So that means come the 1st of February 2023, all audits will be conducted against the Version Nine of the standard so if your audit was due on the 31st of January 2023, you’ll be audited against Version Eight. If your audit is due after the 1st of February 2023, you’ll be audited against the BRC Version Nine of the standard and that’s simply it. So knowing when your audit is due then it means that you will have the audit at that moment in time.
Now, if you’re new to the standard and you’ve never been audited before what standard you’re going to be audited against is rather dependant on when you have your audit, and this is really something which you need to consider. So if you plan to have your audit before the 1st of February it’ll be Version Eight. If you plan to have your audit after the 1st of February it’ll be Version Nine. So this is something worth bearing in mind when you are developing your systems is to make sure you have a clear idea of what standard you want to be audited against.
I personally think that unless you’ve got, if you were planning to have your audit in early 2023, I would wait until after the 1st of February and go for the new version of the standard although it really doesn’t matter, I think the important thing is that you know what standard you’ll be audited against and that’s very simple and it’s based on this simple cut off date of the 31st of January when Version Eight finishes.