BRC Global Standard for Food Safety issue 6

psithurismaccountantUrban and Civil

Nov 29, 2013 (3 years and 8 months ago)

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BRC Global Standard for Food Safety issue 6


Frequently Asked Questions BRC Food Standard issue 6


Answers to general questions regarding how BRC certification works can be
found
here
. Specific questions relating to the clauses and protocol of the
Global Standard for Food Safety Issue
6

are detailed below.


The BRC operate an enquiry service and if you are unable to find an answer
to your particular question then please contact
brcglobalstandards@brc.org.uk
.


General Questions


Background

The Transition from issue 5 to Issue 6


When will audits begin against the new Issue 6 Standard?


As from the 1st of January 2012 all audits will
be carried out against issue 6 of
the Food Standard.


We have our audit planned for February 2012 but we will not have had
time to build up records showing that all of the changes made since
issue 5 have been completed. What will be expected?


We recognise

that for audits completed up to April 2012 it may not be possible
for sites to have the usual 3
month
s
’ worth

of records to be able to
demonstrate that the changes required for issue 6 have been fully
implemented. Certification Bodies have been told to en
sure that sites are able
to demonstrate that the new requirements for issue 6 have been included
within their quality systems and would be effective. It is accepted that these
may not all be supported by historical records. Examples of this would include
f
or instance timed traceability tests, GMP audit records, Root cause analysis
of complaints and corrective actions.


After April 2012 it would be expected that sites should have sufficient records
to support the implementation of new issue 6 systems.


I a
m not due to have an audit until September 2012 will customers still
accept my issue 5 certificate until then?


Yes. Whenever there is a change from one issue of the standard to the next
the existing certificates remain valid and acceptable to customers up

until that
certificate expires



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We are adding a new production line to the factory which is due to be
completed in February but our issue 5 certificate does not expire until
October will we have to have a new audit against issue 6 for the new
line
?


No.
If you would prefer to have an extension to scope for your existing issue 5
certificate instead this would be acceptable. In most cases a visit is required
to review the changes before a scope extension is granted and particularly
where a certificate is cl
ose to expiry it may be preferable to have an early
issue 6 audit instead. .


Audit Duration


Will the audits against issue 6 take longer and therefore be more
expensive?


The BRC introduced a new audit duration calculator at the beginning of 2011
which i
ncreased the typical audit duration from 1.5 days to 2 days. We do not
expect the Issue 6 audits to result in the need for a longer total time for the
audit although we do expect more time to be spent in the factory and less time
auditing paperwork. The au
dit duration calculator has been updated for issue
6 to show the distribution of time expected between the factory and the office
parts of the audit.


The cost of the audit is determined by the Certification Body and not by the
BRC and varies around the wo
rld depending on local auditor wage rates. The
changes made for the new Issue 6 should not have added to the cost of the
audit.


Audit duration
-

Will audit duration calculator change for unannounced
audits?



It is not expected that the time required for
unannounced audits will be
significantly different from that for the announced audit program i.e. typically a
total audit time of 2 days.


GFSI Recognition


Will issue 6 of the Food Standard continue to be a GFSI recognised
Standard?


Yes. The standard was

written to conform to the latest GFSI Benchmark
document issue 6 and an application has been made for benchmarking. All
existing GFSI benchmarked standards are required to re
-
submit for


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benchmarking against this new version of the Guidance Document and wi
ll be
assessed during 2012.


Background to changing the Standard



Why did issue 5 of the Standard need changing?


Food safety does not stand still new risks, legislation and practices to improve
food safety emerge so as a matter of principle and in line w
ith GFSI
benchmarking requirements the BRC Standards need to be periodically
reviewed and updated. The most significant changes in issue 6 are around
the audit options and methods of audit however the new issue also includes
more specific requirements on a
spects of best practice to ensure consistency.


What was the intent of merging clauses?


The BRC working group used the rewrite of the standard as an opportunity to
ensure that each clause was of a more ‘equal’ weighting. This ensures that
the rules for
grading failures against each requirement i.e. major or minor can
be applied more consistently by all auditors. The resultant distribution of
clauses also now reflects the greater emphasis on the practical implication of
food safety
.


Why has the 90 days f
or corrective action for initial audits been removed
from issue 6?


The introduction of the Enrolment scheme for initial audits against issue 6 has
replaced the need for this. Sites that are not able to comply with the
requirements of the standard and need

time to put in place more substantial
improvements will now automatically be accepted into the Enrolment scheme.


Risk assessment
-

What would you expect to see for a risk assessment,
since the Standard now bases many of the requirements on this?


Some s
ort of documentation would be expected to be seen as evidence of the
thought process and conclusions made as to the risks to products. However,
the principles and objectives behind 'risk assessment' are to ensure that the
company has considered the issues
pertinent to the requirements and can
justify the reasons for their policy or procedures, responding to the challenge
by an auditor. In some instances it would be appropriate to have a detailed
document (along the principles of a HACCP plan) showing those
considerations, an example may be the risk rating for suppliers and the
subsequent approval process or the risks to product from physical
contamination which would be included within the HACCP plan. However,
other requirements such as the policy on where b
eard snoods shall be worn
could be evidenced in other ways such as a documented policy, to the
understanding by staff and the reasoning behind this policy. This would


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include considerations of best practice within the industry and be open to
challenge

by a
n auditor. The need for a documented risk assessment would
be particularly pertinent where you have decided not to adopt procedures for
a particular requirement e.g. not wearing beard snoods in a particular area.

Audit Reports


Will the audit report be ver
y different for issue 6 audits?


The BRC working group took the opportunity to revise the audit report format
to ensure that this was more focused on providing the information customers
required for their due diligence and supplier management. The new form
at
provides more summary information about the site performance and the
products and risks associated with the product the report. The detail within the
main report has been refocused to provide more information on how the site
implements their food safety

and quality programs and less detail on the
supporting management systems. This is designed to reduce the time and
therefore costs of producing the report whilst providing the key information in
a more accessible form.


Why have BRC introduced the produc
t safety rationale within the
report?


This provides users of the report with a clear over view of the basis for the
safety of the products. It also ensures that the auditor and the site have
carefully considered the rational for the safety of the products

and that these
have been addressed within the HACCP study



Surveillance audit reporting
-
If a Certification Body undertakes a
surveillance audit of a certificated site, for instance to follow up
concerns, do they submit this report to the BRC?


Where a C
ertification Body needs to carry out an additional visit to a site for
instance for surveillance or investigation of an issue the CB will provide a visit
report for the site. This will not be in the style of the official BRC audit report
so that this is no
t confused with the full audit report. This report does not need
to be uploaded to the BRC Directory, however should be available to BRC on
request. Where the surveillance visit results in the suspension or withdrawal
of a certificate, the BRC shall be not
ified.


S
cope



Why have the BRC working group made changes to what can be
included
and excluded from

the scope of the audit and certification.




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To effectively and consistently meet the requirements expected by the
Standard sites need to operate a food safety culture and consistent way of
working. It would generally be expected that the whole of a site should
therefore be operating to the
same stan
dards and the certification scope apply
to the whole site. The exclusions of some processes and areas can lead to
double standards and is not within the spirit of what BRC certification is
intended to demonstrate.

Whilst exclusion of some product areas will be
accepted the standard gives new guidance on conditions which must be met
when making such exclusions.


What are factored goods
?


Factored goods are products which are purchased sold or distributed by a site
but which undergo no process at the audited factory.
Factored goods are
often products bought in by a company to compliment the range of products
manufactured at the site to provide a more comprehensive product range.
Packing or repacking operations are cl
assed as a process and would not be
classed as factored goods.


Scope Factored Goods
-

My Company handles mostly factored goods
with a small amount of cheese cutting and packing. Therefore we have
always had the Food Standard. Should I now go for the S&D
Standard, in
fact do I now need both?


As factored goods are not included within scope it may be appropriate for the
company to have both Storage and Distribution


including the wholesale
module as well as Food standard for the cheese cutting and packing
operation. The two audits may be carried out simultaneously where the
auditor is suitably qualified to reduce costs.


If a winery does most of their own bottling but uses a service provider
for bottling their sparkling wine which then comes back to them

for final
approval and marketing can this be included within the scope?


No
.

In this case bottling would be included in the scope but bottling of
sparkling wine should be shown as an exclusion.


Defining product scopes on the audit report
-

Can crop monit
oring be
included within the defined scope?


The activities of growing are not within the scope of the BRC audits and are
covered by various farm assurance schemes such as GLOBALGAP. We
would not expect to see the word monitoring on the BRC audit report sc
ope.
Monitoring is part of the process of supplier and raw material approval which
should be expected of all sites


all be it for fresh produce this activity may be
a much more active engagement with the grower particularly where crops are
grown under con
tract.



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New Factories


When can we book an audit for our newly built factory?


Manufacturing units that are newly built or ‘commissioned’ must ensure that
systems and procedures in place are compliant before an initial BRC audit is
undertaken. It is at the
discretion of the company when they wish to invite a
certification body to carry out an
audit;

however they must be able to
demonstrate that systems and processes are well established, compliant and
monitored. It is unlikely that full compliance can be sat
isfactorily demonstrated
within a 3 month period from commencement of operation. A company may
wish to consider a pre
-
assessment towards the end of this 3 month period.
With respect to a new production site within an established company, the site
systems a
nd procedures may reflect that systems already established with
other sites within the company, but a full audit must establish compliance
against BRC requirements for the new site.

H
ead office audits



What happens to the non
-
conformances raised at these

audits


are they
included as part of all the other sites audits or only the site on which the
head office resides (if, of course, there is one production site close by or
on the same premises)?


Any non
-
conformities should be included in the report of th
e first site after the
Head office audit. If
any of these head office non
-

conformities are not
corrected
then
these will be
included in subsequent site reports. This is
described in the standard on page 111


Standard Specific Questions

Section 1 Manageme
nt commitment


Clause 1.1.7 What is defined as ‘a current issue’ of the Standard as
required by clause 1.1.7?


An ‘original’ issue of the Global
Standard for Food Safety Issue 6

must be
available on site. These are available through the BRC Bookshop in var
ious
languages, in print and as a PDF (where usage rules apply). This must not be
a photocopy and should be made available to all relevant staff to ensure they
understand The Standard’s requirements.


Clause 1.1.8 When will a major non
-
conformity be awarde
d against
maintenance of certification?




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A major non
-
conformity will be awarded where the company has not
undertaken an audit within the audit due date (as indicated on the certificate).
It is recognised that there may be specific circumstances where audit
s cannot
occur within the certification cycle for instance packing of seasonal product, or
access restrictions to the site and these are outlined within the Standard
protocol Section III paragraph 12. Moving the audit date to a more
‘acceptable’ date for r
easons of combining audits, lack of personnel or
undertaking building work is not an acceptable reason for missing the due
date. It is not a justifiable reason to delay audits where sites are not in full
production, since there is a 28 day window in which
the audit can occur and it
is presumed that there will be occasions within that period where production is
planned. Audits must however be undertaken whilst there are products are
being manufactured. Justified reasons should be agreed with your
Certificati
on Body prior to any delay with your audit booking. It is the
certificated company’s responsibility to ensure a suitable audit date is agreed
within the appropriate timescale. Where the company is not required to have
certification by customers and where c
ertificates have lapsed for more than 6
months re
-
entry to the BRC Certification scheme will be considered as a new

application and the clause 1.1.8

will not apply.


Clause 1.1.9
-

who are defined as the ‘most senior’ production or
operations manager on si
te to attend meetings?

The objective behind this requirement is to ensure that the conclusions of the
audit and any actions required to correct non
-
conformities are effectively
understood, agreed and there is the authority to ensure these are carried out.
Whilst it may be the case that the most senior personnel may be absent on
the day of the audit, there will always be someone on site that will be
responsible for the daily running of the site.


Clause 1.1
.10

What should happen if a declared corrective acti
on plan
for a root clause has not been implemented at the next audit?


This would result in a non
-

conform
ity

against clause 1.1
.1
0


Where a non
-

conform
ity

has recurred from the previous audit this may be
raised both against the individual clause which ha
s been failed and also may
be evidence of failure against 1.1
.1
0


Clause 1.10
.

Do

I have to do root cause analysis for my non conformities
under Issue 5 in time for my first Issue 6 audit?


It will be expected that sites will have read and familiarized themselves with
the requirements of the issue 6 and started to
have
adopt processes and
procedures before their issue 6 audit. As a guide we would expect records
showing adoption of new issue 6

requirements

to be available for the

3
months before their audit if the audit takes place after April 2010





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Clause 1.2.1 How do you audit effectiveness of deputies


This is not just about having a documented organisation structure but should
include an
assessment of how people are managed
so that for instance there
is cover for holidays
. Deputies must be suitably competent to pick up tasks
which they may need to deputise for. A deputy may be a more senior
manager in the structure.


Section 2 HACCP


Food

Safety Plan


Clause 2 What documentation do you need to keep for HACCP?


You need to ensure that the information on which the HACCP plan is based is
referenced and available on request by the auditor. This may include
published literature on known hazard
s, codes of practice or legislation. You
need to keep records of HACCP team meetings and the decisions which were
reached. You should have documents to demonstrate how the decisions for
establishing CCPs were reached.


Clause 2.1 How many people should mak
e up the HACCP food safety
team and what training do they require?


The number of people on the HACCP food safety team should be pertinent to
the size and structure of the company as the team should include
representatives of each department with responsib
ility for operation of The
Standard. It should not be too large and note that 1 person does not constitute
a ‘team’. It would be expected that participants should have appropriate
training, with particular regard to the team leader. This may be achieved
th
rough external, industry recognised training specific to HACCP but may
equally be achieved by a good quality internal course. At the audit, the
competency and understanding of the HACCP team would be assessed as
well as the quality of the resultant HACCP p
lan. Note that if the HACCP plan
has been prepared with the help of an external consultant, internal staff must
still be fully conversant with the plan, principles and practices associated with
it. Records need also to demonstrate the training of the exter
nal consultant in
HACCP principles.


Clause 2.10.2: … “checking and verification of electronic records
associated with the monitoring of CCP’s…”


what would be the
minimum required here as evidence of compliance?


This is likely to depend upon the part
icular record and the form it takes. This
may include the addition of an electronic signature to the record to
demonstrate checking or may take the form of an electronic or physical form
completed to demonstrate an electronic record has been checked. Elect
ronic
records should where ever possible include an electronic record of any
changes.



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Section 3 Food Safety and Quality Management System


Clause 3.1.1 Do procedures all have to be documented?


‘Procedures’ are referenced frequently within the Standard. A

procedure must
be documented (refer to glossary).


Clause 3.4.2 What training do internal auditors have to have completed
and what does ‘independent from audited department’ mean?


Internal auditors should be able to show via training records that they ha
ve
received formal training either via attendance of an external course or via
training within the company. Training should cover the planning and
scheduling of internal audits, preparing reports and follow up of audit findings.
The objective behind the re
quirement for auditors to be independent of the
area being audited is to ensure that the audit is rigorous and thorough and is
not influenced by the work which may need to be carried out to effect
corrections and improvements. Auditors should not be biased

or influenced.
External auditors may need to be used where there are insufficient internal
resources

.

Clause 3.4.5.2 Filtration of compressed air


can the filter be anywhere
in the compressed air system and what size filter is expected?


The objective
of the filter is to prevent dust particles and lubricating oil from
the compression system from contaminating the products. The best position
and size of the filter may vary depending on the position of the compressor
and lay out of the compressed air syst
em and the source of the air used. The
site should be able to justify the effectiveness of the filtration system
employed


Clause 3.5.4.1: …”declaration to brand owner of outsourced processes
.”



is this only for retail branded products or for particular m
arkets e.g.
the
UK?


No this requirement applies to any product manufactured on behalf of a
customer. The standard isn’t applied differently for different markets or
different customers.


Clause 3.9.2 How accurate does the quantity check / mass balance on

traceability need to be?


It is unlikely that the mass balance check will be able to account for all
materials to an accuracy of 100%
;

however, the company needs to justify the
discrepancies and demonstrate they understand the nature of the variance
throu
gh dehydration of fresh ingredients, typical wastage on equipment and


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portion variances for example. The principle of this requirement is to ensure
that the traceability system is effective and mass balance is a key measure of
this workability and highligh
ts areas for improvement.


Clause 3.10 Would I be expected to do root cause, trend analysis
etc.

for
complaints that are caused by customer abuse?


If there were the same repeated complaints being received then a root cause
analysis should be undertaken to

see if there is an issue with the packaging
instructions for the product which may be leading to customer abuse. A
change in this may reduce complaints.


Clause 3.5.3 How do you manage outsourced activities e.g. cleaning


what records would you expect to

see?


The performance of the supplier should be formally reviewed at a frequency
appropriate to the service. In the case of an out sourced cleaning service the
standards of cleaning would be expected to be assessed as part of the audit
process (3.4.4) an
d records maintained of feedback on performance to the
cleaning company


for instance a report book is often used.


Other services such as Pest control, laundry services may be reviewed with
the supplier on a 6 monthly or annual basis and a record kept of the review for
instance minutes of such a meeting.


Section 4 Site Standards


Clause 4.2.3 What is the “registratio
n” that this clause requires?


This clause relates to legal requirements to register premises with
enforcement authorities pertinent to food safety and quality and includes as
examples the requirement for food businesses to be registered with the local
aut
hority in the UK under Regulation (EC) No. 852/2004 on the Hygiene of
Foodstuffs, Article 6(2) or that food premises in the USA must be registered
with the US treasury under the 'Public Health Security and Bioterrorism
Preparedness and Response Act of 2002
'. It does NOT include other legal
registrations related to personnel health and safety such as fire regulations or
employment law as this is outside the scope of the Standard

.

Clause 4.3.1 Why is an area containing cooked meats not always
considered to b
e a high risk area?


High Risk areas contain only components/foods which have undergone a
cook or similar process to achieve a 6 log reduction of Listeria. Where a single
area has by necessity to include some components which have received a
lesser kill as

well as fully cooked components for instance a sandwich
preparation area this will be classed as a high care area.



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Clause 4.3.1 How should the production zone categories be interpreted
for products which meet the product characteristics for high care bu
t
are fully enclosed for instance within enclosed packaging equipment
until filled and sealed e.g. dairies filling milk into cartons.


In such circumstances the

production area would be considered as an
enclosed product area although additional precautions

would be required
when breaking into the lines or filler for maintenance.

Where ever equipment
is entered for instance to free product jams, cleaning
etc.

the necessary
hygiene requirements to ensure the safety of the products must be completed
before re
commencing packing.



Clause 4.3.1 If mayonnaise is produced in the same area as ready meals
does the area become high risk or high care?


It is necessary to ensure that where a range of products are produced that the
appropriate risk area is applied to th
e particular product. This may identify a
need for segregation between areas. Mayonnaise may be either
h
igh care or
low risk depending upon the recipe and process most mayonnaise is ambient
stable and would
be considered as
low risk. Ready meals similarly
may fall
into low risk, high care or high risk depending on process given, cooking
instructions and expected customer usage.


Clause 4.3.5. What would be an acceptable alternative to a physical
barrier
between low risk and

a
h
igh
c
are operation? Would time

separation be acceptable?


Time separation would be an acceptable alternative in
h
igh care areas (but
not high risk). The auditor must critically examine the arrangements for this to
ensure that potential risks for contamination have been addressed and th
at
the procedures for time segregation are consistently workable before
accepting this solution. This must be described within the audit report.


Clause 4.5.1 Can
a

company rely on the chemical
analysis provided

by
the water authority or do they have to su
b
-
contact the chemical analysis
to an Accredited Laboratory.


The type of chemical checks should be based on a risk assessment. For
instance if as in the UK the water is supplied by a water authority an analysis
from the authority would suffice unless
there are other risks identified in the
delivery system e.g. Lead pipes. Where water is extracted from bore holes
and or sites have on site treatment facilities then additional checks will be
required to ensure the water is not contaminated either at the b
ore hole or in
treatment
.




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Clause 4.6.2 Requires equipment to be suitable for food contact where
appropriate and meet legal requirements


I can’t obtain a certificate of
conformity for machinery we’ve had on site for years, what can I do?


The requirement

is designed to ensure that manufacturers are complying with
relevant legislation, for example the EU ‘Materials and articles intended to
come into contact with food Regulation 1935/2004’ and that such materials do
not constitute a hazard to food. General
principles should be to use approved
suppliers known to supply products designed for food use. All new food
contact
equipment should

be purchased with a certificate of conformity or
specification detailing its suitability for food
use;

this may
also be

confirmed by
a symbol or label on the product. Where this evidence is not available, then a
risk assessment should be carried out to justify its use and determine that it is
not a food safety risk. The risk assessment should consider factors such
as,

the
nature of the food contact surface material and its known characteristics
e.g. stainless steel is known to be a food grade material; length of contact
time with the food and the nature of the food and its potential for
contamination e.g. fatty foods may be

more at risk from migration of
contaminants from a plastic container for example. Further clarification should
be sought e.g. from equipment manufacturer or testing such as migration
tests where required.


Clause 4.8.4 What would be acceptable arrangement
s for changing
facilities for High care operations?


The objective of the clause is to ensure that protective clothing once applied is
not contaminated
particularly
by pathogens before entry into the high care
area. Time segregation i.e. a sh
a
red changing
facility with low risk staff but
with different shift start patterns would be acceptable. It may be necessary for
the changing facilities to be cleaned between different groups of workers
depending on risk. The auditor must be satisfied that the potential
risks have
been assessed and procedures are capable of being consistently operated
without abuse.



Clause 4.8.5 Are boot wash facilities acceptable on entrance to High risk
areas?


High risk areas need a higher level of environmental control than in high
care
areas due to the nature of the products handled. The use of clean footwear
worn only in the high risk area and effective measures for changing into such
footwear is the preferred option to meet the requirements of the Standard.

The use of boot wash f
acilities at the entrance to a high risk area will be
acceptable where this is managed and validated to effectively prevent the
introduction of pathogens. The site shall have undertaken a risk assessment
to identify the suitability of the boot wash facilit
ies and controls to manage the
effective sanitation of footwear. The controls shall have been validated by
microbiological swabbing of footwear and the floors and drains in the high risk
area, to demonstrate the absence of Listeria species.



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For such contr
ols to be effective it would be expected that this includes the
following:

The footwear shall be company issued and of a design which is easily
cleaned i.e. smooth upper surfaces, cleats on soles shall be sufficiently
spaced so as not to trap dirt which m
ay not easily be removed by boot wash
equipment.


Consideration of the potential for gross contamination of boots prior to boot
washing i.e. the footwear shall not be worn outside of the facility or in low risk
processing areas prior to entering the high
risk area.


The boot wash equipment shall be suitably designed, well maintained and
demonstrably effective to clean and sanitise the foot wear. F042 Issue 1 BRC
Global Standard for Food Safety Issue 6 Position Statements Released
8/5/2012 Page5


The mini
mum cleaning time and levels of detergent and sanitiser used shall
be determined, documented and controlled to ensure effective cleaning of
footwear.

Records shall be maintained of detergent/sanitiser checks, and effectiveness
of cleaning of the boot wash

facilities
.


Clause 4.8.6
dictates the requirements for hand washing facilities to be
used before entering production. Does this mean that roller towels can’t
be used?

This requirements clearly specifies what can and can’t be used and includes
that roller

towels cannot be used at hand washing stations in production areas
as they are not ‘single use’; they can however, be used in toilets but only if
they are not the only facilities provided before re
-
entering production.


Clause 4.8.6 Is there a relaxation
of the requirement for hand cleaning
facilities in low risk factories for example flour mills, breweries, produce
pack houses.


There remains a requirement for providing hand cleaning facilities
to enable
employees to wash their hands
before entr
y

to produ
ction areas (note this
may be in a changing or toilet area). The use of gel sanitisers alone does not
provide a suitable alternative as this does not clean the hands but
provides
only a partial sanitising effect.


Clause 4.9.3.4.3: …”records shall be main
tained of all container
breakages….” High speed filling lines in the wine/beverage industry
often incorporate automatic clean cycles following a breakage in the
filler but no records are kept. What does the standard expect in such
situations?



In such c
ircumstances the site must be able to demonstrate that the automatic
process they have established is effective in preventing the potential spread
of glass to other open containers, effectively removes all glass during the


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wash phase and separates effectiv
ely at risk product for disposal. Where this
can be shown to be effective then routine monitoring of the filler for glass and
an
effective

process to hold any suspect product could be accepted. The
procedure must be verified on a regular basis


Clause 4.10
.3.1 Metal Detection would a low or zero number of
customer complaints be justification for not having a metal detector? Do
different rules apply
when

packing branded or customer label
products?



Whilst complaint levels is a factor in making a decision o
n the
necessity

for
metal detection this alone will not be taken as justification that a metal
detector is not required


not least because it is well known that many
contamination issues go un reported by customers. Any justification for the
absence of m
etal detection should be based on the nature of the product
, risk
to the consumer

and alternative controls in place at the site which prevent
metal contamination. So for example metal in a meat pie or sausage would
probably only be detected when the produc
t is in the mouth where as a piece
of metal in a bag of potatoes would hopefully be found before consumption
-

presenting a low customer risk. The meat pie would be expected to be metal
detected.

It is important to recognise that the requirements of the st
andard apply
irrespective of whether the products are branded or retailer own label the
standard applies to the food safety and quality systems at the site. The BRC
Certificate demonstrates a minimum level of food safety at the site and must
be consistentl
y applied to all products within the audit scope.


Please see the decision tree shown in the
issue 6 Position Statements

document for f
urther information.


Clause 4.10.3.3 This requests “a belt stop system with an alarm where
the product
cannot

be automatically rejected

e.g. very large packs”. Are
there other instances where stop belt systems would be acceptable?



Other examples could in
clude delicate products where the use of a belt stop
system is necessary to prevent damage to the finished product e.g. quiches,
gala pies, freshly topped

decorated pies, decorated celebration cakes,
chocolate

gateaux

etc.
The BRC have produced a Position
Statement relating
to the acceptability of metal detectors
so for further information please
click
here
.



Section 5 Product Control




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Clause 5.2 I handle nuts on my site, but add a statement on my
packaging stating ‘it cannot be guaranteed that this product is free of
nut traces’


do I have to comply with any of the requirements of section
5.2?

Yes, you still have to carry out a risk as
sessment and consider what steps are
appropriate for your company to minimise the potential for cross
contamination.

Clause 5.2 I do not handle any allergen containing materials on my site
and am not making any ‘nut free’ claims, are the clauses of 5.2
applicable?


The following clauses would still be applicable 5.2.1.and 5.2.9


Clause 5.3 Do the requirements of this section apply to mandatory legal
claims such as country of origin labelling?


Yes
-

where ever information such as country of origin is mark
ed on a product
the manufacturer must be able to demonstrate that this is correct and this
section sets requirements to be met to achieve this.



Clause 5.3.2 Mass Balance for product claims. Is it necessary to carry
out a mass balance test on every produc
t where a claim is made?


The objective of the mass balance traceability is both to demonstrate that
sufficient detailed records are maintained to allow an accurate mass balance
test to be carried out at any time with any particular process and secondly to

check

that errors/mixing of products has not occurred i.e. the claim is valid.
The test shall be carried out at least once every 6 months however where
applicable products are produced using very different processes it may be
necessary to check more regul
arly to ensure that each production process is
controlled. It will not be necessary to check each individual product every 6
months unless this is a requirement of the particular scheme associated with
the claim.


The test should as a minimum take a batch
of incoming raw material (for
which the claim relates e.g. Aberdeen Angus Beef ) and identify where all of
this batch was used, this may include wastage and remaining stock if
appropriate. The test should be able to account for the use of all of
a

batch of

materials.

Section 6 Process Control


Clause 6.1.1. Do I have to emphasise “milk” in recipes if all I make is
cheese and all the recipes contain milk?


No If an allergen is used in
all

products manufactured at a factory there would
be no absolute requirem
ent to emphasise this on the recipe, however should
the product range change this would be required.



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Clause 6.1.4 Is it a requirement to undertake temperature distribution
studies in cold stores and freezers?


For small freezers the temperature
goes up
and down on defrost and whilst filling and emptying.


The objective is to ensure that products can be consistently stored within the
temperature ranges specified and are therefore not at risk of spoilage within
shelf life. The level of risk will depend upo
n the product, time spent in storage
and margin allowed by the temperature settings of the store. Temperature
distribution studies would not be necessary for small chill or cold stores where
product is stored only for short periods.

Section 7 Personnel



Clause 7.2.1 Is the wearing of wedding bands
including “
Rhukhi”
friendship bands (Hindu/Siekh) acceptable?


Where such jewellery cannot be effectively cleaned or may present a risk of
contamination this must either be removed or covered.


Clause 7.2.2: Requires hand cleaning to be performed on entry to the
production area. Does this apply in enclosed product areas?


Yes as this is good practice for the food industry


Clause 7.4: 2 Protective clothing has changed from issue 5 with the
remov
al of the wording “based on a risk assessment” how does an
industry now justify that they do not have protective clothing in the true
definition of clothing that is worn to protect the product from possible
contamination from the person. But rather clothi
ng/uniforms that are
worn to protect personal clothing from getting dirty.


The standard now states ‘suitable’ so instead of risk assessing the site must
define what is suitable for that process. Protective clothing but not necessarily
head coverings wou
ld be expected to be supplied to employees working in
enclosed product areas as for instance in a winery.


Clause 7.4. Does the company need to supply protective clothing to
contractors performing construction or maintenance work in their
facility? Or….do

they need to ensure that they are wearing protective
clothing that is appropriate to the area?


The intention of the clause is to ensure adequate protection for products. The
level of controls will depend upon the product risk zone and extent of work
unde
rtaken.




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Building as in construction work should be screened from production areas
and builders should not enter the active production area whilst production is in
process.


In low risk open product areas the company may supply protective clothing for
sub
-
contractors

or where provided by the contractor this needs to comply with
site requirements. Generally speaking we would not expect sub contract
engineers to be working in high care or high risk areas during production
periods. Where this is necessary the
subcontractors shall be supplied with the
company issued protective clothing and follow the site changing procedures
before entering the area in order to protect the products.


Clause 7.4.2 Are head coverings required in enclosed product areas e.g.
wine b
ottling, breweries?


The sta
ndard requires that protective clothing is
available that

fully contains
scalp hair to prevent contamination


Where the product and packaging is
fully protected from the risk of contamination for instance enclosed product
areas

head coverings would not be an absolute requirement. It should be
noted that whenever equipment is opened or lines broken into the staff
concerned must
wear

protective clothing and head coverings.



Clause 7.4.4 What would be an acceptable certification f
or Laundries?


There are a range of certification standards for Laundries operating in
different parts of the world. Where a certification scheme is used the site must
be able to demonstrate to the auditor that the scheme fulfils the requirements
of 7.4.4


Unannounced audit schemes


Are the new unannounced audit options available to sites that have
gained a grade A or B for
issue 5?


Where sites have already elected to have an unannounced audit under issue
5 the site should be contacted by the certification body and informed that
depending on when the unannounced audit will occur
(before or after 1
st

January)
this may be against issue
5 or 6. Sites must be given the opportunity
to withdraw from the unannounced scheme if they wish.


Sites achieving a grade A/A* or B/B* for issue 5 after 1st October 2011 can
opt in to the unannounced scheme for issue 6 so long as they do this within
the f
irst 3 months following their audit as per the scheme rules.




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Our site has already opted in to the unannounced audit programme
following the issue 5 audit.
Is it possible to change to the new option 2
unannounced programme?


Yes

-

this is possible if the c
ertification body are able
to accommodate the
change. Requests for a change to the option 2 must be made to the
certification Body as soon as possible


Enrolment Scheme


Can sites
that

fail to meet the requirements of issue 6 go into the
Enrolment scheme?


It has been agreed that in order to smooth the transition from issue 5 to issue
6 that where a site certificated for issue 5 fails to meet the requirements for
issue 6 at their initial issue 6 audit the site will automatically be in the
Enrolment scheme.
The site will therefore have a scored audit and no
certificate.


How will the weighting work for the Enrolment scoring system?


The weighting will be based on the severity of the
non
-
conformance

i.e.
Critical, Major, Minor and how the clause relates to the

3 levels in the GFSI
Global Markets Capacity Building Programme.


This GFSI have a programme
which
identifies particular requirements for
Basic Level

and
Intermediate level compliance as stepping stones to
achieving eventual certification against a GFSI b
enchmarked scheme such as
BRC. The requirements within BRC issue 6 have been matched to the
requirements at the different levels within the GFSI programme. Failure
against BRC requirements equivalent to GFSI Basic level will be more heavily
weighted than f
ailure against equivalent Intermediate level requirements.



Will BRC provide a scoring system to calculate the score for auditors?


Yes the BRC will be issuing a
spread sheet

to automatically calculate the
Enrolment scores.


Will there be a separate audi
t report template for enrolment.


Yes. The report format will be visually distinct to prevent confusion between
enrolment and certificated audit reports. The contents of the reports will be
identical except that the audit result section is based on a total

score and
score per section. The non
-

conformance reporting section will be slightly
different to allow for an action plan where correction cannot be achieved
within 28 days.


Do sites need to
s
elect ‘
E
nrolment’
when booking an audit?




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All initial audits of sites and
the first

audits
against

Issue 6 for existing
certificated sites to issue 5 will automatically be in the enrolment programme
.
In most cases the sites will gain certification and will be issued with the issue
6 audit and cert
ificate.



Our site was not certificated and received the enrolment audit report.
How soon can I undertake a new audit?


The sites in the Enrolment program are likely to have a significant amount of
work to
do to

ensure non conformities identified have bee
n effectively
addressed before commissioning the new audit. Due to the nature and
number of non
-
conformities, it is unlikely that these nonconformities can be
addressed and fully effective improvements implemented and established
within a 28 day period; al
though there may be some exceptions. It is
likely;

therefore, that in most cases the re
-
audit will take place after the 28 day
period and typically a 3 month period may be required to fully establish new
systems or patterns of working.

Auditing the Standar
d


Why are the BRC now insisting on more of the audit time being spent in
the factory?


Concerns have been expressed that not enough time is spent in production
and too much time spent reviewing paperwork in the office. Users of the
Standard for supplier a
pproval are rightly concerned to ensure that emphasis
is given to the factory
environment;

product and food safety controls in
production and working practices since these directly affect the safety and
quality of the food being produced. It is expected th
at at least 50% of the audit
is spent in the production and ancillary areas. This should include assessing
the production process, observing activities, interviewing staff in production,
reviewing relevant procedures/work instructions recording forms
withi
n

the
production area. These are all things that good auditors will already have
been doing and need to be adopted by all.


When calculating the audit time in the factory what does this include?


Whilst most of the time allocated to the factory (GMP) audit

is expected to be
spent within the processing areas of the factory the inspection of ancillary
areas including
s
torage facilities, exterior areas,
e
ngineering facilities,
transport, canteen and staff facilities are also included when calculating the
total

time in the factory. The audit report shall show an estimate of the time
spent auditing the factory.


What
is expected by the
BRC
of auditors
when opening equipment to
inspect cleaning?




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To ensure that the standards of cleaning are properly challenged it

is
expected that some equipment should be opened for instance by removing
panels or dismantled to check that cleaning is more than superficial.

Sites need to know in advance e.g. at the opening meeting that this will be
part of the site audit and any nec
essary arrangements
should be made
for
engineers to be present.

It is NOT expected that lines will be stopped for inspection. The audit should
be limited to lines or equipment not in production at the time of the factory tour
or the inspection of equipment

outside of production periods.

Auditors must at all times be aware of and obey health and safety rules at the
sites.


How does the BRC expect the traceability (vertical audit) to be
undertaken?


BRC expect a traceability check (vertical audit) to be
carried out on a product
selected by the auditor
. This is
in addition to the review of
the method of
achieving
traceability which forms part of the GMP audit.


The exercise shall be based on a product selected by the auditor the product
shall have been pro
duced
typically
in a 2
-
5 months period prior to the audit
date. Where a claim is made about a component of the product (as per 5.3)
the test shall include a mass balance of the material subject to the claim. The
mass balance test should be in both directio
ns (finished product to raw
material and vice versa).


BRC suggest the vertical audit (i.e. traceability documentation
plus

all
associated production and raw material documentation) should be carried out
only as part of the trace backwards from finished pr
oduct to raw materials. To
undertake such an exercise in both directions would be too time consuming
unless issues are suspected.


Where the site produces products which make a claim of provenance (5.3) the
product selected for the traceability study shou
ld be a product for which such
a claim is made.


Details should be captured in the auditor’s checklist and summarised in the
final audit report.


What is expected of auditors when carrying out line start up or Pre
operation checks?


Where ever possible aud
itors should arrange to carry out an inspection of
lines before the start of production. Typically this would be accompanied by
the person who normally undertakes this check for the site being inspected.
The objective is both to ensure the standards of cle
aning are good enough
and assess how the site undertakes such a check and the standards the site
its self expects.




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There will be some production processes where such checks are impossible
for instance continuous processes or where timing is such that this

would be
impractical. The auditor’s notes should indicate where a check has been
completed and if not why not.


What are the BRC
’s

expectations when examining records during the
documentation review
?

It is important that when examining records this is a f
air but true test of the
sites records and procedures. It is expected that the auditor shall manage the
select
ion or records

to demonstrate compliance. The factory inspection shall
be used by the auditor to identify actual records to be examined during the

documentation audit. This could include

Employee names for


training record review

Reference numbers of measuring equipment


for review of calibration
records

Examples of glass/plastic items to check against the glass register


Can non
-
conformities

be
issued
against Statements of intent (SOI)?


Yes and these can be minor, major or critical


Statements of intent summarise the overall objectives and the clausal
requirements below show how these can be achieved through policies and
procedures e.g. customer

complaints (3.10)


the intent is that complaints are
reduced. It maybe that the company meets all the individual requirements by
having procedures for recording and investigating but complaints may still be
increasing


therefore the intent is not met. I
n this case a non
-
conformity
could be raised against the statement of intent.


I have had a BRC audit and am not happy with the non
-
conformities
identified or the grade awarded


what can I do?


The company has the right to appeal the certification decisio
n made by the
certification body which should be made in writing to the certification body
within 7 days of the decision. The certification body shall give a full written
response within 30 days following a full and thorough investigation. The
company also

has the option to contact the BRC if resolution cannot be
attained by the two parties.