- The Process. This is all about having to engage your staff in the planning of the audit and having the training and practice in advance. Make sure that the right people are available throughout the audits including the leadership team.
- Assess access support information. There’s lots of information out there publicly available to help you with your remote audit so go to your certification body, go through iso or even go to the international accreditation form. Lots of great information available for you to use.
- Planning is absolutely essential. Really identify who’s going to be doing what. Is there a role for audit assistance to help support the smooth running of the audit? Who’s going to hold the camera? Who’s going to gather all the evidence? Also don’t forget to plan some breaks from screen time. You need natural breaks because a remote audit is very different and it can be much more intense in many ways.
- These are IT considerations. Now you do have to test and map out your wi-fi signal throughout your site. It would probably be a great idea to have an IT person available throughout the audit. Plan in advance how to share documents and maybe set up a separate audit room. There’s lots of planning that needs to be done there and having a designated room is a great idea.
- Preparation. So do a mock test of the equipment with internal and external people. Identify your weak wi-fi signal areas. Test that the lighting on site is good enough so that the auditor is going to be able to see everything clearly from their remote screen. You can send them a map of the site so they know in advance the location of everything.
- More planning again is absolutely imperative. This time in conjunction with your auditor in advance of the audit day. Try and identify what documents need to be ready and which can be sent in advance.
- Company policies. It is particularly important to consider site security policies, both the site security policies of the auditor and the certification bodies. Just make sure that all the systems are communicating with each other and can be shared and accessed remotely. Auditors have reported their feedback where they’ve struggled with this consideration.
- Making sure that the outcomes of the audit are followed through as they should be.
- Particularly important is to take any of the experience that you’ve gained from the audits and reuse them the next time. Again that is some feedback that we’ve had from auditors that the more they’ve done these remote audits, the easier it’s become.
The BRC Global Standard for Food and Distribution was first published in 2006, the current version is Issue 4 which was published in November 2020 and effective May 2021. The standard covers activities that can affect the safety, quality, and legality of food, packaging and consumer products during storage and distribution processes. There are eight core sections:
- Senior Management Commitment
- Hazard and Risk Analysis
- Product Safety and Quality Management System
- Site and Building Standards
- Vehicle Operating Standards
- Facility Management
- Good Operating Practices
Primarily the Standard applies to the storage and distribution of packaged products which are already protected. However, there is section 9 Handling of Open Food Products which applies to permitted exceptions which are limited to:
- open boxes and trays of fruit and vegetables
- trays of raw fish/crustaceans/other sea food
- carcasses of meat
For all other open food product handling and processing operations, the Global Standard for Food Safety is applicable.
There are also Additional Voluntary Modules:
- 10 Wholesale Module
- 11 Cross-docking Module – New in Issue 4
- 12 E-commerce Module – New in Issue 4
Contracted services modules:
- 13 Contractual arrangements (all services)
- 14 Product inspection
- 15 Contract packing (repacking, assembly packing)
- 16 Quantity control inspection
- 17 Contract chilling/freezing/ tempering/defrosting and high- pressure process operations
- 18 Contract cleaning of baskets, roll cages and other distribution containers
- 19 Waste recovery and recycling
BRC Global Standard for Food and Distribution Issue 4 is in alignment with GFSI Benchmarking Requirements Version 2020 and is close to completing the GFSI benchmarking process. The Global Food Safety Initiative (GFSI) Benchmarking Requirements are a widely-accepted benchmark for food safety certification programs. GFSI-recognized Certification Program Owners are required to address each key element outlined in GFSI Benchmarking Requirements Version 2020, the main change being the requirement for a food safety culture. Part III of the GFSI Benchmarking Requirements defines the key elements required in a Certification Program in relation to:
- Hazard and Risk Management Systems (Hazard Analysis and Critical Control Points (HACCP) or HACCP based systems)
- Food Safety Management Systems;
- Good Storage and Distribution Practices, Good Manufacturing Practices, Good Agricultural Practices.
Changes in the BRC Global Standard for Storage and Distribution
The main changes in the Global Standard for Storage and Distribution, issue 4 are:
- New clause: 1.1.2 Food Safety Culture – plan for the development and continuing improvement of a product safety and quality culture
- New clause: 1.1. Whistleblowing System – the requirement to have a confidential reporting system to enable staff to report concerns relating to product safety, legality, quality and integrity.
- HACCP – HARA or HACCP study is based on comprehensive information sources, which are referenced and available on request, there is a need to have a process flow diagram and requirement for the review of HARA or HACCP plans of service providers or subcontractors
- Inspections – requirement for documented inspections, no less than every 3 months, to ensure that the site environment and equipment are maintained in a suitable condition.
- Root Cause Analysis – requirement for root cause analysis to determine preventive actions
- Emergency Supplies – requirement for a procedure to handle exceptions to the subcontractor approval process
- Control of Subcontracted distribution – requirement to verify activities critical to product safety for subcontracted distribution of products
- New section: 3.5.3 Product Fraud Risk Management
- Site Plan – Requirement for current map or plan of the whole site
- Control of Auto-Systems – requirement to risk-assess and define procedures for automated systems
- New section: 7.7 Management of Allergens – New requirements for the Management of Allergens including a documented allergen management plan
- New section 9 Handling of Open Food Products – with additional requirements for open products including:
- 9.1 Hazard and risk analysis
- 9.2 Staff facilities
- 9.3 Fabrication
- 9.4 Maintenance
- 9.5 Housekeeping and hygiene
- 9.6 Protective clothing
So this pandemic that started in March 2020 has really disrupted the lives of everyone, but one thing that hasn’t changed is the need for food safety. Food safety is a priority for customers, specifiers, brand owners and ultimately for consumers.
The challenges that the pandemic brought about were immediate. They occurred very rapidly, they were mostly unknown and they are ever changing. The word, unprecedented, was used a lot over the last year and it was no different in food safety. It was new territory for everyone involved in the food safety chain.
So the new challenges faced by food business operations included supply chain disruptions amongst other things, but it was actually people that were most affected and the importance of staff health was upmost. One major problem for businesses was the lack of staff availability due to staff illnesses, staff self-isolating, a lack of appropriate PPE and staff needing to organise child-care and home schooling.
In fact the lack of PPE was a major issue as there simply wasn’t enough to go around, and businesses couldn’t get it ordered and delivered quick enough. These kinds of issues were impacting sites and their food safety during this pandemic. Even problems with staff getting to work with restrictions in local and national travel, and especially international travel.
So there was a lot of uncertainty over how food sites were supposed to maintain standards. How do you deal with restrictions on who is an essential worker and who is not. Especially when these restrictions and changing all the time, and are different in different regions and dependant on what part of the country you are in.
This has lead to much confusion and some delays and disruption but of course the demand from the public was increasingly for safe food, especially in the retail sector. The pandemic also affected the ability of some prerequisite services to operate like pest control, waste disposal and cleaning agencies. They were in huge demand but with staff on furlough and other challenges the supply chains were challenged.
So the pandemic has created a very clear prerequisite for all of us and that is adapt how you operate your business or risk losing your business altogether. With all of that going on how were you expected to ensure effective oversight of your food safety management system when resources were compromised or, another way of looking at it, with less staff on site how do you ensure that your food safety systems are not at risk.
We know thousands of sites demonstrate their commitment to food safety by getting certificated to a GFSI scheme such as the BRC global food standard and maintaining that certification during the pandemic was not without its challenges.
We have observed over the last 12 months how businesses have adapted to ensure they have maintained food safety and maintained their certification during the pandemic. There are many lessons to be learned from this pandemic and there is still more to be encountered as the pandemic continues its course so of course, these lessons cannot all be covered in this article.
Just focussing on five main areas of discussion, the first is talking about how BRCGS adapted their approach to auditing to ensure all sites had options to maintain their certification where possible. Also going to talk about the use of ICT and digital platforms to help make the audit process feasible for both sites and auditors. We will also take one of the prerequisites, Pest Control Management and discuss some feedback that we had from two pest control companies on their lessons learned and then we can mention briefly some of the known conformances raised during the pandemic just to understand if we’re seeing differences across sites as a result of the new audit approach that were taken at BRCGS. Finally we can discuss the importance of having contingencies for training when face-to-face training is not possible.
In the face of all this, BRCGS adapted their approach to auditing to give sites a set of options to maintain their certification. There was also some good feedback received from the auditors and certification bodies which I will talk about too. BRCGS launched a suite of audit options that took in to account a number of issues like the GFSI’s position and requirements, the account brand, the retailer feedback, the ever changing and evolving local restrictions, and auditor availability. The maturity and the history of the site’s certification was also taken into account.
The following image shows the audit options available to businesses during the pandemic.
Announced audits still continue to be used where it is possible for an auditor to conduct an on site audit. One thing that was learned very early on in the pandemic though was that unannounced audits were in fact an unnecessary burden on sites and they actually increased the challenges of both the certification bodies and auditors in arranging the audits. So BRCGS took the decision to temporarily suspend the unannounced audit program until at least the end of 2021. Where this happens the certification body will contact the site to arrange either an announced audit or blended audit. BRCGS will keep this temporary suspension under review and hope to restart unannounced audits as soon as possible. Sites will be given at least 3 months notice before they can be offered this option but if a site really needs an unannounced audit this can be carried out by exception. For example, if a customer requirement insists upon it or if perhaps it is part of a combined audit with another standard.
The blended audit can be carried out where an on-site visit is possible, but only for existing sites. This blended audit approach consists of 2 parts. The online remote assessment of some or all of the documents plus the shorter on site assessment. This requires a reduced amount of time for the auditor to be on site. This works well when an auditor can visit a country or region for a short amount of time before having to quarantine. This blended audit option will remain in the future for announced audits.
Where access to the site is not possible and the audit is due, the certificate extension could apply. There must be an existing valid certificate in place and this can be extended by 6 months based upon a risk assessment and review by the certification body. It is based on the controls that are already shown to be in place on the site.
Next option on the list is the full remote audit, which is not GFSI benchmarked. This is available for sites where the certificate extension has expired but it is still not possible for a visit to take place by an auditor due to Covid restrictions. It could also be used if a site does not need a GFSI recognized certificate. It involves a complete review of internal audit documents and usually a video audit of production and storage facilities.
Finally the BRCGS also offer a Covid-19 additional module and have published a separate assessment standard and may be used to provide assurances around the management of Covid-19 risks. It’s carried out like a remote audit and focuses on the areas of the food safety system which are potentially at a greater risk as a result of the changes forced to address over covert 19.
BRCGS offers plenty of options to allow sites and certification bodies to work together to ensure food safety assurances are still in place during the pandemic. However in order for these options, especially the remote and blended options, to be successful sites had to adapt their approach to the audit.
In the next article in this series we will be talking about some of the obstacles and issues that had to be addressed to carry out the various audit options available, and feedback on these from both the sites and auditors.
A successful food safety culture is the product of individual and group values, attitudes, competencies and patterns of behavior that determine the commitment to, and the style and proficiency of the food safety management system. Senior management should plan for the development and continuing improvement of a food safety culture.
Senior management should be implementing a “It is how we do things here” food safety culture. This can be achieved by:
- Leadership – starting from the top
- Demonstrating visible commitment
- Effective communication of company philosophy and policy
- Ensuring there is accountability from the top of the organization to the bottom
- Developing employee confidence and mutual trust
- Developing reward schemes including ‘Employee of the Month’ award
- Ensuring all employees are accountable, engaged and understand the value of integrity and proactivity
- Developing an action plan for the development and continuing improvement of food safety culture
To ensure success Senior Management should be directly responsible for food safety by ensuring adequate; organization and support, equipment and facilities, training and education of all employees, reviewing and auditing performance, and driving continuous improvement.
All employees should be empowered and individually responsible for the quality of their work, resulting in a continual improvement culture and working environment for all. Employees should be encouraged and required to notify management about actual or potential food safety issues and are empowered to act to resolve food safety issues within their scope of work.
The philosophy of Food Safety should be promoted throughout the organization and in particular the Food Safety Policy.
Communication processes for promoting food safety include:
- Team briefings
- Staff reviews
- Daily Management meetings
- Feedback mechanisms
- Notice boards
Senior management should monitor and measure through reports and trend analysis the degree of development of the food safety culture by analyzing information including KPIs from:
- Hygiene & Housekeeping Audits
- Internal Audits
- External Audits
- Non-conforming products
- Environmental monitoring
- Review of implementation plan and numbers trained
- Employee reviews
- Staff surveys on values and culture
- Customer Complaints
- Staff Turnover
- Staff Exit Interviews
All employees should undergo individual food safety culture development which can include:
- Food Safety Policy
- Food Safety Objectives
- Food Safety Management System Overview
- Job Descriptions
- Job Training
- Employee Briefing
- Individual Objectives
- CCP Controls – Training Procedures & Record Completion
- PRP Controls – Training Procedures & Record Completion
- Employee Review
A training matrix can be used for Food Safety Culture Planning:
Records of all training should be maintained, including those of induction, on-the-job, refresher and external training. Training schedules and records should be managed by Department Managers and where applicable include the following records:
- Training register
- Operator training review
- Training matrix
- Department training matrix
- Individual Training records including:
- Description of training
- Skills description
- Name of trainee
- Confirmation of training
- Date and duration of training
- Trainer details
- Verification that the trainer has assessed the trainee and found them to be competent
- Identifying the competencies needed for specific roles
- Reviewing and auditing the implementation and effectiveness of the training and the competency of the trainer with a view to taking action to improve the training.
All food operations should have a proactive system for the prevention of contamination of products by pests that ensures there are effective controls and processes in place to minimise pest activity and ensure any pest infestation does not present a risk of contamination to products, raw materials or packaging.
Most organizations use Pest Control Association registered pest control contractor to implement a Pest Management programme and maintain the site free from pest contamination unless the organization employs a Pest Management Specialist.
A typical Pest Management contract agreement defines:
- Company and contractor key contact personnel
- Description of contracted services and how they will be completed
- Term of the contract
- Equipment and material storage specifications
- A complete inventory of pesticides (must be approved by the regulatory authority for use in a food facility) detailing the safe use and application of baits and other materials such as insecticide sprays or fumigants
- Emergency call out procedures
- Records to be maintained
- Requirement to notify facility of any changes in service or materials used
- Service personnel including evidence of competency by exam from a recognized organization
The contracted Pest Management service should provide:
- Site visits and inspections (including the periphery and internal and external buildings) based on a documented risk assessment including service records describing current levels of pest activity and recommendations for taking corrective actions.
- The provision of a plan/diagram of the site showing the location of all pest control monitoring and prevention measures
- Flying insect controls including fly killing units
- Emergency 24-hour call-out service
- Quarterly biologist inspection reports, visit and trend reports with recommendations
- A current copy of the certificate of insurance that specifies the liability coverage
- Spill control materials and procedures
- Material safety data sheet information to ensure proper usage of pesticide chemicals.
A nominated manager or responsible employee should have overall responsibility for Pest Management on site so that Pest Management is manged within site control rather than relying on contractors.
Before agreeing to a contract the Pest Management Contractor should be subject to Supplier Approval to ensure that the contractor is qualified and the pest management programmes will comply with applicable legislation.
Copies of the Contract, Service Agreement, Pest Control Reports and Pest Management Contractor training records and qualifications should be held in Pest Control File on site. At the start of the contract a detailed survey of the entire facility should be completed by a qualified Field Biologist and the results documented and used to determine placement of Pest Control devices.
Exterior Bait Stations
Exterior rodent bait stations should be set up to deter rodents from entering the facility. Based on the detailed facility survey, exterior bait stations should be placed along the foundation walls on the exterior of the facility and along the site boundaries. Exterior bait stations containing rodenticides should be tamper resistant, anchored in place, locked, and labelled.
Based on the detailed Field Biologist survey, interior monitoring devices should be placed in strategic sensitive areas specific to the rodent species, and other areas of possible pest activity. Interior rodent monitoring devices identify and capture rodents that gain access to the facility. Interior monitoring devices should be placed in areas where pest ingress is first likely to be identified and secured in position.
Elimination of Pest Habitat
The Field Biologist should identify any possible pest habitat around the site in the quarterly inspections. The nominated manager or responsible employee should take actions to remove or eliminate favourable conditions for pests including eliminating any rodent burrows, rodent runs and areas that provide harbourage or may attract rodents or other pests to the site or outside grounds.
Pest Management Reporting
Records of all Monitoring devices should be maintained, including services performed, to ensure that devices are properly placed and inspected to allow trend analysis of activity.
Pest Management Contractor reports include:
- Signs of pest activity
- Proofing requirements
- Actions required by site
- Type of Pest
- Pesticide or material applied
- Pesticide registration number
- Rate of application or percent of concentration
- Specific location of application
- Method of application
- Amount of pesticide used at the application site
- Next action/follow up date
- Date and time
- Review and investigation of any missing baits
- Signature of pest controller
Temporary placement of any pest monitoring devices for short-term monitoring should be documented in pest management action reports.
All personnel should be trained to identify potential issues caused by pests at induction. A pest reporting procedure should be in place such that any incident or sign of pest activity is immediately reported to the nominated manager or responsible employee and any potential product affected quarantined. The nominated manager or responsible employee maintains a log of pest sightings and the action taken by the pest controller.
The Pest Control Contractor should provide reports for all visits and advise on any trends and corrective actions.
Pests pose a major threat to the safety of food. Pest infestations can occur where there are breeding sites and a supply of food. Good hygiene practices should be employed to avoid creating an environment conducive to pests. Sanitation, inspection of incoming materials and monitoring can minimise the likelihood of infestation.
Buildings should be kept in good repair and condition to prevent pest access and to eliminate potential breeding sites. Holes, drains and other places where pests are likely to gain access should be protected or sealed. Screens for windows, doors and vents should be used to reduce the risk of pest entry.
The availability of food and water encourages pest harbourage and infestation. Potential food sources should be protected and stored above the ground and away from walls. Areas both inside and outside food premises should be kept clean. Waste should be stored in covered, pest-proof containers whenever possible.
Pest infestations should be dealt with immediately and without adversely affecting food safety or suitability. Treatment with chemical, physical or biological agents should be carried out without posing a threat to the safety of food.
Pesticides should not be used in food areas.
As well as carrying bacteria, rodents can gnaw their way into materials and can cause substantial damage to buildings.
It is important to prevent access to pests, all access doors should be adequately proofed and/or screened.
Adequate measures in place to prevent birds from entering buildings or roosting.
Establishments and surrounding areas should be regularly examined by a competent person for evidence of infestation.
I have been involved in many projects to improve product quality and reduce food complaint levels. One of the best tools for indicating where action for improvement needs to be applied is by analyzing your complaint data appropriately.
Whilst you can identify faults in your factory your customers are your 100% inspection service so respect their feedback. Whilst all of your customers will not complain when they find a problem so you will not capture all of your product faults you will however identify trends.
The first step is to collate all of your complaint data. Your data should then be categorized by product type, complaint type and size. Analyzing complaints by numbers alone will not give you a real picture of your performance. What you need to know is the proportion of complaints you are getting for each product. By far the most practical way of doing this is by using the sales volumes to calculate the proportion of complaints you get for each product. Some people use weight or volume such as complaints per ton or 1000 Liters. My preference is to use complaints per million units.
So, you analyze your complaint data product type, complaint type and size per million units. From this data, you can easily spot the worst performing product lines.
You should then analyze the results for the worst performing products:
Are they all the same size?
Are they produced on the same filling machine/production line?
Is it the same type of complaint?
The answers to these questions will generate your corrective action plans. If products with the highest complaint levels are all the same size it could be a particular problem with that size of packaging. If it is all the same type of complaint then why are some product lines worse than others? If product from one particular production line is generating the highest number of complaints per million units then there must be a reason for this, it needs investigating.
You should compare product performance and if there are significant differences you should ask the question why? At this point complaint trends are useful. For example, when I worked with fresh pasteurized milk sour complaints were higher in larger sized containers. The reason for this was not related to the quality of the product but the fact they took longer to consume and spent more time in and out of the fridge. Such products would be targeted for improvement projects as opposed to corrective action to remedy a problem area.
A few words of caution though, your analysis needs to take into consideration the comparative value of the products and the market. People are more likely to complain about higher value products. Also, some retail customers are much better at reporting complaints from customers to the extent that I used to get 10 times the complaint levels from one particular retailer compared to another for exactly the same product.
My last tip the more data you analyze the better. In the past I have analyzed 3 year’s worth of data. Why? It gives a year on year performance so you can see if things have been improving or deteriorating and also it shows any effects of seasonality. For example, it is not reasonable to compare summer levels of “off” complaints on a fresh product with winter levels. This is why in the Northern Hemisphere I would compare August complaint performance with the complaint levels for August in the previous year.
The complaint analyzer that I have developed based on over 30 years’ experience in the food industry is included in our Food Safety Management System Implementation Packages.