This is the final part of our 4-part article series on how we at BRC have approached maintaining food safety standard during this pandemic. If you have not read the previous articles, you can find them here:

Part 1 | Part 2 | Part 3.

We will round up our discussion with the challenges of pest control, a word about non-conformities and some notes on training methods.

A challenging lesson we learned during the pandemic was in pest control. We all know that pest control is essential for food safety on site. This message was misunderstood at the beginning of the pandemic which led to some pest control contact contractors not been allowed access to sites initially. However, in the UK after some lobbying by the pest control association they were granted essential worker status and then they were allowed into the sites. Of course, pest control is considered a very hands-on industry and it’s considered that you must be on site to do it. This was challenged during the pandemic and now there are alternatives to some physical visits.


Pest contractors have said that remote pest audits can be done in the interim if a site visit isn’t feasible and things like trend analysis review meetings can certainly be done remotely. This is better than not happening at all, but we have heard of occasions where pest contractors have not been given remote access to on-site pest control management systems and that’s mainly due to security reasons or hurdles. This can be very easily addressed by NDA’s or confidentiality policies. What we do know is that monthly pest control visits have been maintained and we haven’t really heard of many issues with that.

What we have heard is that field biologists weren’t always allowed on site, or their visits were being postponed. We heard some sites could end up not having a field biologist visit for nearly two years by the time the pandemic is over. This does contravene clause 4.14.10 of the food standard. We are not clear why field biologists weren’t being allowed on site, is it cost cutting or is it that sites don’t fully appreciate what the field biologist contributes or was it because the staff were being furloughed and they weren’t there to action the report? We don’t know but certainly what we heard was there was a 35% reduction in food and field biologist visits from one contractor. This of course raises some concerns, not only from a food safety point of view, but also because of all those delayed visits we’re going to have that inevitable backlog of scheduled visits and that now must be managed. So, this begs the question do sites fully appreciate the importance of your field biologist?

Just to add to the concerns from pest control companies, we know that some food sectors saw a huge increase in production demand at the early stages of the pandemic and if this is not managed correctly this can lead to less time to clean and less downtime for maintenance and deep clean. If you add in problems with stockpiling of raw materials and finished products and warehousing this could result in more places for a pest to harbour. If that’s not managed correctly, you’re going to end up with these sudden emergency callouts which are more costly for the site at the end of the day and that’s what we want to avoid.

The other thing that’s important to remember is when the lockdown happened it happened very quickly, and some sites just didn’t have a formal shutdown process. They didn’t have time to implement a thorough shutdown process and that could have led to some food safety prerequisites, such as pest control, not being managed correctly. It’s imperative that everybody has a reopening procedure implemented for when sites or parts of the site are reopened.


Information on pest sightings during the pandemic and whether they increased or decreased. This was a survey conducted by the British pest control association (BPCA) and they found that during the pandemic there was a 78% increase in rat activity and a 63% increase in mice activity. This emphasizes the importance of rigorous compliance especially around proofing and monitoring. It also emphasizes the fact that compliance isn’t just for the audit. Sites must operate in accordance with the BRCGS food standard 365 days of the year if they expect to maintain a rigorous food safety management system. If you have some parts of your site have been closed during the pandemic it might benefit from a field biologist visit to help you out with your reopening. ‘Becoming pest ready’ is another document by the BPCA with some guidance on how to reopen your site. That can be found on the BPCA website.



Moving on to non-conformities, the question is, did the pandemic create new non-conformities or have a notable impact on their prevalence? You can see in this image the percentage of audits that contained certain non-conformances. We just want to put this into context. To understand whether non-conformances differed during the pandemic was quite tricky because there was the added complication of comparing two untypical years. For most sites, 2019 was their first Issue 8 audit which was published in August 2018. Which means their first audit was 2019 and that always affects the pattern of non-conformances at sites because sites have got to get used to the new clauses and take some time to understand how to apply them to their facility. Then of course in 2020 we have had the pandemic, so we have had two consecutive years of potentially untypical data to try and trend.

If you look at the right-hand side of the image, clause 1.1.2 food safety culture was new in 2018 and that immediately was the top of the non-conformances. It’s relatively new for our industry and similarly with clause 2.7.1, the radiological hazard bullet point was new to sites, and this caused some non-conformances. If you look on the right-hand side for the following year those non-conformances moved down to position three and five. What we do see over the years is that the non-conformances have only changed slightly, and the top non-conformances have not had a huge amount of change. Not all the statistics on the remote audits have been done yet because we don’t really have a significant number of audits completed to make the statistics meaningful but what we will do is continue to monitor that as the pandemic progresses.

What we can see is that the overall number of minor non-conformances allocated were slightly down year on year but mostly consistent which suggests that, despite all the challenges, sites are maintaining their food standard clauses reasonably well. Sites must maintain their food safety standards during the pandemic, and they have had to make an awful lot of changes to their sites and operationally to comply to the new Covid rules. We know sites had to focus on these four specific clauses: 2.14.1, 2.2.1, 5.1.2 and clause 4.11.3.

What’s useful here is that the standard gives them flexibility to change systems in a controlled way and therefore maintain food safety and risks. This reinforces how standards are designed to help sites to manage changes such as the pandemic.
Finally, just a word about training. One of the key lessons was that remote working thrust virtual learning into the limelight. This has had a huge impact in breaking down the geographical boundaries that have been traditionally associated with classroom learning. If we look at the importance of having contingencies for training when face-to-face training is not possible. BRCGS has training locations all over the globe. They really took an early commitment that they were going to find ways of adapting to support their certificated sites to continue to develop their teams and to maintain this technical level of competence.

Sites that are more agile and more people-centric will be much better positioned to bounce back stronger once this pandemic is over so by adapting our content and our approach, we have redeveloped our packages to make sure that they’re providing an even better online experience. BRCGS had to reconsider how they did training, they had to adapt and to change. They have reframed the content to make it more online friendly, adapted the training methods so learners are getting a much better experience out of the virtual classroom environment. It’s all now delivered through virtual platforms they have even looked at mobile micro learning. That’s where they’re developing these mobile friendly learning options made as easy as possible for people to learn. There are platforms to allow learners to target specific skill areas that really meet their requirements and their business and professional schedules. Virtual events at BRCGS have switched from traditional learning conferences to virtual conferences and they have been a huge success they are going to continue to support their global network with virtual in-person and hybrids events in 2021 and 2022.

SQF Edition 9 Changes: New Design and Technical Improvements

SQF Edition 9 Changes: New Design and Technical Improvements

SQF Edition 9 Changes: New Design and Technical Improvements

The SQF Code Edition 9 comes with a new layout and design for those technical changes. With the SQF Edition 9 changes here, this image below outlines the different codes that we have implemented now. The primary production code as you can see is now broken up into three different codes. The primary production code was all under one code, it had one system element with various modules behind it but the Edition 9 code now has three different codes. One for animal, one for plant and another one for aquaculture. That means that there’s different system elements for those industry sectors specifically that address those risks for that industry sector and that’s what’s important to recognize.

You can find a summary of changes on the SQFI Site here.

SQF Edition 9 Changes

SQF Edition 9 Changes

If you do livestock you have your own code, if you do plants you have your own code and same thing with aquaculture. The other thing that we want to point out is that primary plant production now includes pack houses. So it’s a more streamlined approach because there are a lot of growers and packers and now it’s under one SQF Code. FSC 4 for pack houses is now under primary plant production, previously under 8.1 it was under manufacturing.

Speaking of manufacturing you can see here that we have now five different codes for manufacturing so while under 8.1 we had all of our manufacturing codes under one system element the opportunity we took with the SQF Edition 9 changes was to break it up into five different codes. We have animal product manufacturing, which includes slaughter and meat processing as well as seafood processing food manufacturing which includes everything from soup to nuts and then dietary supplements with its own system elements. The same for pet food and animal feed.

Each of those food sector categories were pulled out and have their own system elements now and it also allows us to create more guidance documents and tools specific to that industry scope. The changes are really reflective of what we’ve done with food manufacturing but at least now they’re their own codes. Storage and distribution and food packaging continue to stand on their own with FSC 26 and 27.

The quality code is still a separate code and there weren’t a lot of SQF Edition 9 changes in the quality code. It still includes process variation and HACCP for quality but one big change is that the quality code is now applicable to be used with any GFSI recognized standard. It’s not specific to SQF food safety but is specific to any food safety program that’s recognized under GFSI This opens up the door for this code, which we think has a lot of value to it, to be applied to any of those GFSI recognized standards. For more details on the major changes see here.

SQF Code is farm to fork so we have a solution regardless of where you start and what industry scope you’re in. Food retail and food service are under 8.1 and they haven’t changed for Edition 9. That is something we will be looking at in the future as it relates to SQF but those aren’t benchmarked by GFSI so SQF don’t plan on benchmarking them this year. The fundamentals program is the introduction to food safety and there haven’t been any changes in that one either.

SQF Code Edition 9 Layout and Design

SQF Edition 9 Changes to Covers

Here are the new code covers, you might have noticed a little bit of a difference, SQF wanted to give the Code a new look and feel so they went to their marketing team and design team and they came up with a new look and feel to the SQF Code. As you can see we have 11 codes under Edition 9 with the implementation date where audits began being in May 2021. They also gave the insides of the codes a new look and feel, a more formatted look. They were able to increase the white space, build up the font and color code and track specific areas so it’s a nice readable font and it really does make it a difference when you print things out.
There are some changes in Part A of the Code. The formatting has changed as well as some of the numbering. This probably won’t make much of an impact to you or your site but is more relevant for the certification bodies (CB’s).

The other thing we want to emphasize in part A, especially if you’ve never had an opportunity to read part A, is that this is really where all of the methodology is found. It is how your site is scored and what the frequency of audits should be and what to do if the site becomes suspended. As you’re reading it this year though, for this edition, SQF took the opportunity to write it from the site’s perspective. It’s a reminder to say that they wrote the SQF Code for the site, so when a site is looking to implement a food safety program if it follows the SQF Code requirements then that’s what it has to do. It wasn’t written for the auditor, it wasn’t written for the CB. The code was written for the site.

That’s how part A was approached, so some of the changes that would be impactful to you at the site we have listed here.

  1. SQF looked at scoring and if you’re a current user of the SQF Code you’ll know that major non-conformities were scored at 10 points. So, if you received one major you automatically got a score of a 90. If you got two majors that would be a score of 80 etc. Minor non-conformities were scored at one point, and they didn’t change. They did change the scoring of a major from ten points to five points and SQF were looking at this to see how they could better reflect the site. It seems that auditors weren’t scoring majors the way that they should. A major is a system element breakdown and it’s used to indicate that there are breakdowns in one area such as the HACCP program or sanitation or training. When SQF looked at the reports and reviews they noticed many similar non-conformances that the auditor’s would have been better suited grouping as a major non-conformance versus a minor non-conformance. We’re not saying they think the score is going to go up or down but will keep an eye on how the scoring works out. SQF want to make sure that the auditor isn’t using points as a means to determine whether there’s a minor or a major, instead if they lowered the points for a major there would be an opportunity to group more and there wouldn’t be a site that received 30 minor non-conformances but maybe received more appropriately three major non-conformances. That’s a 15-point difference but it means that the site can really evaluate the root cause as it relates to a major as a system element breakdown versus 30 minor non-conformances.
  2. Another change made is in the unannounced audit. SQF was at the forefront of releasing and mandating unannounced audits and now GFSI have included it in their requirements documents. So, all GFSI recognized standards need to have a mandatory unannounced audit now. The way that GFSI phrased it as one unannounced audit every three years means that every three years the site has to undergo an unannounced audit. The way that SQF had it phrased was one in every three certification cycles and that means every three years is one certification cycle and then it reset after that third certification cycle. The way that GFSI phrased it it’s one in every three years so once you have your unannounced audits it’s reset after that unannounced audit, so there’s the little bit of difference in there but bottom line SQF sites are very much prepared for that unannounced audit and it’s just one little hiccup in the system right now.
  3. The requirement for desk audits for initial certification has been removed. If it’s a site that’s undergoing an initial certification with SQF Code, a desk audit is not part of the initial certification so there is no stage one. In stage two it just goes right to the site audit which includes the review of the documentation as well as the implementation of the SQF Code requirements. It was never applicable for any of the other parts of it of the certification research or surveillance.
  4. The audit duration table was removed, and we reference the audit guide provided by GFSI. GFSI states a minimum of two days for manufacturing, one day for storage and distribution, one day for food packaging, and half days for primary plants. That’s reflective within the part A itself under section 8.1 of the SQF Code. The CB’s can still use the audit duration guide that was in the previous editions as their methodology for determining audit duration. Two days is the guide and that can change based off of a number of different factors of the site but they did remove that table and just provide the reference that GFSI has in their requirements document.
  5. SQF Code edition 9 does include the option for remote audit activities and as you know SQF has the option where the certification body and the auditor can conduct part of the audit remotely. It’s so they can do interviews, they can do document reviews and even some record checks remotely based off feasibility assessment determining the site’s capabilities and the auditor’s capabilities.
  6. SQF also clarified the activities when a site is suspended or if the site fails an audit or if the site is withdrawn.
  7. They added an if/then table which is a great reference. Sites that are looking at creating a good instructional tool, the if/then table is actually a pretty nice tool to use. It identifies a scenario and then the actions taken based on that scenario. A lot of times it’s used for crisis management planning, for example, if you have a flood then you do this etc. As a side note, it’s really a good tool that you can use in your own development of your programmes, but SQF applied it to what to do when sites undergo a suspension or when they fail an audit or if the site is withdrawn. They created this if/then table and it has a great explanation as to what the actions are if a site is undergoing suspension or withdrawal or failed an audit.

Maintaining Food Safety Standards During a Pandemic – Part 3

Maintaining Food Safety Standards During a Pandemic – Part 3

This is a continuation of our series of articles on maintaining food safety standards during a pandemic. You can read Part 1 Here. and Part 2 Here.We have compiled the top five remote audit tips for sites and certification bodies. This is direct feedback from some of the auditors.

Auditor Feedback

  1. Preparation is key. With the remote audit approach, preparation by the auditor is much more intensive around the pre-order to review of documentation. It’s important for everyone to understand the pre-audit submissions review, and understand the process so as an auditor you can request the right information beforehand.Although there’s lots of similarities between the on-site and the off-site audit, remote document review generally requires information specified by the auditor to be uploaded onto a document portal. Scanning rather than photographing and uploading documents can take some time so auditors need to make sure that the company is aware before the order date of exactly what information will be required. During the audit itself they’re going to need lots more documentation so to enable that it’s important to have a scanner available if possible.
  2. Test that your site it is compatible with the certification body systems. Compatibility can be an issue so the company needs to make sure the IT team is on hand on the day. It’s very important that we’ve got the right people available on the day to help with any technology troubleshooting. We all know video streaming can be poor when internet bandwidth isn’t at its best and of course with these audits taking place all over the world, some in very remote locations where wi-fi and bandwidth is a problem. If you think this could be a problem, it is probably a good idea to request a wired connection to a LAN or some sort of router ahead of time to ensure there aren’t delays on the day. You also need to check in case the company firewall has any internal controls or restrictions. On-screen sharing may need to be resolved in advance.
  3. Test the technology in advance. It is a good idea to arrange a dry run in advance if it’s at all possible. The audit day time constraints on the auditor are tough enough already without the pressure of IT problems. It also allows the site and the auditor to have a chance to get to know each other before the actual audit day. Another consideration is that many sites experience live streaming problems due to a faraday cage effect that steel framed factories present and just to get around this the company can possibly upload a pre-recorded video requested by the auditor or present them via a shared screen. If live streaming is possible just be aware of the noise in the plant and how this can impact the auditor and of course the auditor doesn’t have control over the camera and where it’s pointing. A solution for this can be a team approach to the filming maybe involving two or more people with a camera operator and a quality manager using separate devices.Another point is with a typical on-site audit day, the team will all sit around a table during the audit which works well, however when you’re doing it remotely placing the laptop in the middle of a large table to allow everyone to join in doesn’t work so well particularly if the microphone isn’t picking up the sound or if the meeting rooms are a bit echoey. Moving the auditors closer to the microphone may cause social distancing issues so it’s probably better to have everyone logged into an audit platform with headphones and individual microphones.
  4. Get familiar with video conferencing. Throughout the pandemic, the use of video conferencing has developed immensely and everyone is now much more familiar with these systems. Certification bodies may have their own platforms whether it’s Microsoft teams or Google, Skype or Zoom. The auditors can be trained in these and get familiar with them. Then they don’t have to deal with resolving any IT issues concerning these platforms, on the day. They’re familiar with the system, they’re not using some alien system on the day. Not knowing how an unfamiliar platform works it’s just extra hassle and extra stress for your auditor and you don’t want to have a stressed auditor!
  5. Put a plan in place for poor wi-fi. We’ve mentioned this already but if you were intending to be live streaming during the factory visit but it’s not possible due to wi-fi you could try pre-recording a video of the production facility. However, before you do this you just also need to consider national privacy laws and you must make sure that the video gives a good representation of the site. It doesn’t have to be cinema quality but try to avoid things like nausea inducing rapid panning from one side of the factory to the other. Just think about what it is exactly that your auditor wants to see and focus on those details. Following up on the HACCP process flow diagram might be a good place to start the video. Try experimenting with different recording technology and avoid using the portrait style videos if possible. A digital camera can sometimes be better than a phone camera as it’s easier to transfer the videos onto a computer and so on.
This brings us nicely on to the next lesson learned from the pandemic. The role of information communication technology. So we all know technology has a vital role to play in our food supply chains. Businesses are increasingly turning to digital tools and platforms to support their challenges using the power of data and automation to problem solve, improve processes and certainly to help decision making. It increases productivity, it enhances transparency and creates added value all the way from operations right through to the customer experience.
Maintaining Food Safety Standards During a Pandemic - Part 3
The pandemic has certainly led to a dramatic increase in the use of some digital tools, information communication technology, or ICT, has been essential to the food industry. We know that remote audits could not have been possible without it and it’s been used to demonstrate food safety compliance to auditors. It has helped maintain certification for hundreds of sites across the globe however as we have said that hasn’t been without its challenges.

To recap, we’ve talked about additional steps such as having confidentiality agreements or NDAs to be signed and just to consider documents such as the IAF ID3 or AFMD4 docs need to be understood and agreed with your certification body and if you’re not sure about these just have a chat with your certification body about it. Sites had to learn where their wi-fi hotspots and black spots were in advance of the audit and that’s not something your typical technical manager knows anything about. We’ve heard of some extremely remote sites having no wi-fi at all and making it impossible to conduct a live remote audit. We do know that sites and auditors have used a huge variety of hardware and software. Everything from smartphones, ipads, laptops, even CCTV. They’ve used Go-Pros, they’ve used Whatsapp, they’ve used Microsoft teams. Some have been more effective than others.

ICT however doesn’t in any way constitute digitalization and this is usually an enterprise-wide project requiring investment and lots of detailed projects. The pandemic has not necessarily accelerated digitalization in that respect and it may in fact have slowed down the process in certain businesses. Companies who had started the roll out of a digitalization product may have delayed it because the pandemic took priority but having said that companies that already had digitalization food safety platforms in place had a three-fold increase in their use because those customers realized they could effectively manage their compliance systems remotely using a full set of features that their digital platforms already offered. In other words the pandemic encouraged digital users to exploit a digital based compliance solution that they already had. This is supported by feedback from those using remote technologies to perform internal audits. They enhanced their control to mitigate food safety risks during the pandemic and reiterate the importance of strong internal audits especially when third party audits weren’t possible.

So those who had digital systems in place were very grateful and it really made it a lot easier for them to share their documents with external auditors, it made the entire audit and remote audit experience much more effective.

An example of a rapidly evolving digital tool used in the food industry is digital pest monitors. These integrated pest management tools are a critical component of any food safety program and tools such as rodent monitoring service sensors can protect operations from pest infestations and the related risks of disease, product loss and recalls. They can help ensure your site is audit ready and compliant with lots of the complex regulations associated with food safety standards

We will talk more about pest management and control in the next article.