key changes to the requirements brc issue 7 changes.pdfkey changes to the requirements! in issue 7...

Key Changes to the Requirements!in Issue 7 of the!

BRC Global Standard for Food Safety!

Presented By:!Dr. Claver Bundac!

[email protected]!Managing Director!

BioMedix!Pomona Technology Centre!

California State Polytechnic University!Pomona, California!

BRC Issue 7 Changes!

Audits conducted BEFORE 1 July 2015 shall be certificated against Issue 6!!!

Audits conducted On or AFTER 1 July 2015 shall be certificated against Issue 7!

Issue 7 Implementation Date: 1 July 2015!


Senior Management Commitment!!HACCP Plan!!Quality Management System!!Prerequisite Programmes!

Expectations and structural components remain the same!


Legality!!Safety!!Quality (Wholesomeness)!!Authenticity (new!)!

The articulated objectives have been widened to include:!


Revisions in structural nomenclature:!


Senior Management Commitment and Continual Improvement (1.1)!Food Safety Plan (2.0)!Internal Audit (3.4)!

Management of Suppliers of Raw Materials and Packaging (3.5.1) (New!)!Corrective and Preventive Actions (3.7)!

Traceability (3.9)!Layout, Product Flow and Segregation (4.3)!Housekeeping and Hygiene (4.11)!

Management of Allergens (5.3)!Control of Operation (6.1)!Labeling and Packaging Control (6.2) (New!)!

Training!

Two (2) new Fundamental Requirements have been added:!

New Fundamental Requirement!

Statement of Intent:!a.  Effective supplier approval and monitoring system!b.  Manage risks associated with raw materials and packaging!

•  legality, safety, quality and authenticity!

Key requirements:!a.  Documented risk assessment!b.  Documented supplier approval and monitoring procedures!

•  supplier audit by a competent auditor, or questionnaire!•  certification of supplier (BRC or other GFSI recognized schemes)!

c.  Documented ingredient and material specifications!d.  Documented testing procedures for verification!e.  Documented approved suppliers list!f.  For broker/agent derived ingredients and materials:!

•  identity of the last manufacturer, packer or consolidator of the items!•  information needed for the approval of a supplier, unless the broker/

agent has been certificated on the BRC Global Standard for Agents and Brokers!

3.5.1 Management of suppliers of raw materials and packaging!

New Fundamental Requirement!

Statement of Intent:!a.  Effective management of labeling activities!b.  Accurate labeling and coding of products!!

Key Requirements:!a.  Documented operational procedures that consistently ensure the accurate

printing and accurate staging of labeling/coding materials !b.  Documented procedures to consistently ensure the accuracy of the labels

and codes before the start of production and following changes of products!c.  Documented procedures to consistently ensure that the right product is in

the right package and is accurately labeled/coded!•  checks before the run!•  checks during the run!•  checks in between changes!•  checks at the end of the run!

d.  Documented verification of on-line vision equipment used in ensuring the accuracy of packaging and labeling/coding materials!

6.2 Labeling and Pack Control!


Open Product Areas!a.  high-risk (chilled and frozen)!b.  high-care (chilled and frozen)!c.  ambient high-care (New!)!d.  low-risk!

Enclosed Product Areas!!Non-product Area (New!)!!

Production Risk Zones!


Product Characteristics!a.  Finished products are ready to eat or ready to heat!b.  Raw materials used are prone to pathogen (vegetative form)

contamination!c.  Processing includes a pathogen removal or reduction step!d.  Finished product could support the survival and growth of pathogens

(vegetative form)!e.  Finished products are stored at ambient temperature!

Requirements!a.  Documented microbiological risk assessment!

•  raw materials!•  process flow!•  airflow and utilities (including drain)!•  finished product!

b.  Process-related controls to protect from microbiological contamination!•  process segregation, process management (sanitary operation

procedures)!

NEW Production Risk Zone: Ambient High-care!


a.  Environmental monitoring (sampling/testing) programme to verify the effectiveness of footwear control!

NEW Production Risk Zone Requirement: High-care!

a.  By exception, the use of boot-wash facilities is accepted as long as the process has been proven to be effective in preventing the introduction of pathogens in the high-risk area!

b.  Environmental monitoring (sampling/testing) programme to verify the effectiveness of footwear control!

NEW Production Risk Zone Requirements: High-risk!


Statement of Intent:!a.  Complete understanding of customer specifications!b.  Effective compliance to the specifications!c.  Effective communication of customer specifications to staff and to

suppliers of raw materials, packaging and services that are to be affected by customer specification!

Requirements:!a.  Documented procedures to ensure compliance to customer

specification!b.  Document procedures to effectively communicate the

specifications to the staff and if need be, the suppliers!

New Subsection!!3.12 – Customer Focus and Communications!


Statement of Intent:!a.  Effective processing procedures that ensure the safety of by-products!b.  Effective processing procedures that ensure the legality of by-products!

Requirements:!a.  Surplus customer-branded (co-packed/private-label) products to be

disposed of following customer-approved protocol!b.  The sale and donation of non-conforming (quality factors) customer-

branded products shall follow customer-approved protocol!c.  By-products and downgraded/surplus products intended for animal

feeds shall be handled in a manner that prevents contamination and shall be in compliance with relevant regulations!

New Subsection!!4.13 – Management of Surplus Food and Products!! !for Animal Feeds!


Statement of Intent:!a.  Product labeling shall comply with relevant legal requirements!b.  Label information shall be sufficient to enable the safe handling,

display, storage and preparation of the product through the supply chain up to the point of consumption!

!Requirements:!

a.  Documented procedures that ensure the accuracy and legality of labels!

b.  Documented procedures to verify the label against the ingredients!c.  Documented procedures that effectively manage the process of

changing or updating labels due to changes in process, materials or regulations.!

d.  Documented procedures to validate and verify claims!

New Subsection!!5.2 – Product Labeling!


Statement of Intent:!a.  Procedures to effectively prevent or minimize the likelihood of purchasing

adulterated food raw materials!b.  Procedures that ensure the accuracy and legality of claims!

!Requirements:!

a.  Shall have a procedure to access the latest information on possible threats to the legality, safety, quality and authenticity of raw materials!

b.  Documented risk assessment on all raw materials or groups of raw materials !c.  Documented assurance programmes and/or testing procedures to monitor and

verify!d.  Documented procedures to verify preserved status and provenance claims!

•  verification of purchase records!•  verification of traceability (raw materials and finished products)!•  mass balance tests to be conducted at least every 6 months!

New Subsection!!5.4 – Product Authenticity, Claims, and Chain of Custody!


Structural Comparison!

Issue 6! Issue 7! Number of Sections! 7! 7! Number of Sub-sections! 55! 59! Number of Clauses! 238! 256! Number of Fundamental Req.! 10! 12!

End of Presentation!Thank You!!

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