Development of the Standard
The BRC began to develop the standard following the horsemeat scandal in the UK, when it identified the weak link in the supply chain as the lack of traceability back to source for food products. The standard was written in consultation with retailers and certification bodies to ensure full transparency throughout the food supply chain.
In order to achieve certification, Agents & Brokers need to demonstrate that they manage product authenticity, quality, legality and safety effectively. The standard is applicable for businesses in the food, packaging and consumer products industries that buy, sell or facilitate the trade of products, but do not process, manufacture or store the traded products in their own facilities or on their own sites.
The BRCGS Global Standard for Agents and Brokers Issue 3 has requirements in 4 main areas:
- Senior Management Commitment and Continual Improvement
Senior Management must demonstrate commitment to supply authentic, legal and safe products of the specified quality initially by issuing a documented policy and supporting that policy with clear documented objectives that are also communicated and monitored.
Senior management are required to ensure adequate resources are available, plan to develop a food safety culture, ensure there is effective communication, review systems and implement actions to improve. Product safety responsibilities are not exclusive to the technical department, all members of staff should be committed to and responsible for product authenticity, quality, legality and safety, including logistics, sales and purchasing personnel.
- Hazard and Risk Assessment
The Standard requires hazard and risk analysis and the development of product safety plans (based on CODEX HACCP principles) covering the services/operations the company manages or specifies.
12 Steps in HACCP Application are as follows:
- Assemble HACCP Team and Identify Scope
- Describe product
- Identify intended use and users
- Construct flow diagram
- On-site confirmation of flow diagram
- List all potential hazards that are likely to occur and associated with each step, conduct a hazard analysis to identify the significant hazards, and consider any measures to control identified hazards (Principle 1)
- Determine the Critical Control Points (Principle 2)
- Establish validated critical limits for each CCP (Principle 3)
- Establish a Monitoring System for Each CCP (Principle 4)
- Establish corrective actions (Principle 5)
- Validation of the HACCP Plan and Verification Procedures (Principle 6)
- Establish Documentation and Record Keeping (Principle 7)
Training of personnel in HACCP principles and applications is also an essential element for the effective implementation of HACCP. As an aid to training to working instructions and procedures should be available that define the tasks of the operating personnel in charge of each Critical Control Point.
- Product Safety and Quality Management System
The standard requires documented Product Safety and Quality Management System procedures which cover key system management elements including:
- Documentation Control
- Control and Maintenance of Records
- Customer Focus and Communication
- Internal Audit
- Specifications for Products
- Complaint Handling
- Corrective Action
- Control of Non-Conforming Product
- Management of Incidents
- Product Withdrawal and Product Recall
- Supplier and Subcontracted Service Management
The standard requires a risk-based approach to the selection and management of product manufacturers, subcontractors and service providers to ensure products and services are only sourced from approved manufacturers and suppliers of services, following agreed specifications, with a traceable and transparent supply chain.
Suppliers of product must be evaluated for their ability to meet specifications for the products they are supplying including product authenticity, legality and safety requirements whilst considering:
- the nature of all the products and their associated risks
- customer-specific requirements
- legislative requirements
- source or country of origin
- the potential for fraudulent activity in the supply chain
Approval of manufacturers of products should be based on risk and can be based on valid certification of the manufacturing or packing site to the applicable BRCGS Standard or a standard benchmarked by the Global Food Safety Initiative (GFSI) or a supplier audit with a scope to include product safety, traceability testing, HACCP or hazard and risk management review, the product security (food defence) plan, the product authenticity plan, and good manufacturing practices.
For products assessed as low-risk only, initial and ongoing approval may be based on a completed manufacturing site questionnaire.
There also needs to be approval and monitoring of service providers (e.g. storage, or transport) whilst considering:
- risk to the safety and quality of products
- compliance with legal requirements
- customer requirements
- potential risks to the security of the product
Changes in Issue 3 include alignment with the GFSI benchmark, a requirement for senior management to plan and develop a food safety culture and a greater emphasis on food authenticity and food defence. There are also updated requirements for product safety activities including internal audits, preventative action, root cause analysis and incident management.