BRCGS Global Standard for Food Safety Issue 9

BRCGS Global Standard for Food Safety Issue 9

About the BRCGS Global Standard for Food Safety

First published in 1998, the BRC Global Standard for Food Safety has set the benchmark for food safety certification schemes for over 20 years. In 2000, the BRC Global Standard for Food Safety became the first GFSI recognised standard. In fact, over the years the BRCGS Global Standard for Food Safety has been a leading light in advancing food safety standards in food manufacturing such that the GFSI benchmark requirements themselves have incorporated new elements introduced by BRC such as food fraud prevention and developing a food safety culture.


Now known as BRCGS Global Standard for Food Safety, it is adopted by over 22,000 sites in 130 countries. Issue 9 was published on the 1st August. It requires a Food Safety Management System to be compliant in 4 key areas:

Senior Management Commitment

HACCP/Food Safety Plan

Product Safety and Quality Management System

Prerequisite Programmes


The BRCGS Global Standard for Food Safety Issue 9 requirements are in 9 Sections

1 Senior Management Commitment

2 The Food Safety Plan – HACCP

3 Food Safety and Quality Management System

4 Site Standards

5 Product Control

6 Process Control

7 Personnel

8 High-Risk, High-Care and Ambient High-Care Production Risk Zones

9 Requirements for Traded Products


Sections 1 to 3 are self-explanatory; Sections 4 to 8 cover Prerequisite Programmes and Section 9 is specific to Traded Products and may not be applicable.


The BRCGS Global Standard for Food Safety contains certain requirements that have been designated as ‘fundamental’ that relate to systems that are crucial to the establishment and operation of an effective food operation. The fundamental requirements are:

Senior Management Commitment & Continual Improvement (Section 1.1)

The Food Safety Plan – HACCP (Section 2)

Internal Audits (Section 3.4)

Management of Suppliers of Raw Materials & Packaging (Section 3.5.1)

Corrective & Preventive Actions (Section 3.7)

Traceability (Section 3.9)

Layout, Product Flow & Segregation (Section 4.3)

Housekeeping & Hygiene (Section 4.11)

Management of Allergens (Section 5.3)

Control of Operations (Section 6.1)

Labelling & Pack Control (Section 6.2)

Training (7.1).


The main changes in Issue 9 are summarised below


Product Safety Culture – There are considerable additions to food safety and culture requirements in section 1.1.2, including more specific requirements for the plan for the development and continuing improvement of a food safety and quality culture. These requirements are not rocket science but are clear, the plan must include communication, training, feedback, prescribed behaviours, performance measurement and timescales.


HACCP/Food Safety Plan – The whole of Section 2 has been aligned with the requirements with the 2020 revision of the CODEX General Principles of Food Hygiene. There have been some changes (shown in red) in alignment with CODEX Seven HACCP Principles and 12 Steps in HACCP Application:

3.1 Assemble HACCP Team and Identify Scope (Step 1)

3.2 Describe product (Step 2)

3.3 Identify intended use and users (Step 3)

3.4 Construct flow diagram (Step 4)

3.5 On-site confirmation of flow diagram (Step 5)

3.6 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 (Step 6/ Principle 1)

3.7 Determine the Critical Control Points (Step 7/ Principle 2)

3.8 Establish validated critical limits for each CCP (Step 8/ Principle 3)

3.9 Establish a Monitoring System for Each CCP (Step 9/ Principle 4)

3.10 Establish corrective actions (Step 10/ Principle 5)

3.11 Validation of the HACCP Plan and Verification Procedures (Step 11/ Principle 6)

3.12 Establish Documentation and Record Keeping (Step 12/ Principle 7)

3.13 Training


Outsourced Processing – There has been an update of the definition of outsourced processing added to the Glossary and updates in Section 3.5.4 Management of Outsourced Processing with an emphasis on ensuring that any hazards associated with the outsourced operations are identified and controlled and that a service specification is agreed including any specific handling requirements for the products.


Equipment – There are major revisions of the requirements of Section 4.6 Equipment including requirements for a documented purchase specification for any new equipment, a documented, risk-based commissioning procedure and other food safety requirements for the management of equipment.


Animal Primary Conversion – New Section 5.9 Animal Primary Conversion with the requirements of the Issue 8 position statement incorporated into BRCGS Global Standard for Food Safety Issue 9.


Authenticity – ‘Integrity’ has been replaced by ‘Authenticity’ throughout the standard to ensure consistent terminology throughout the BRCGS Standards.


Other changes in Issue 9 include updated requirements associated with core product safety activities including as internal audits, root cause analysis, preventive actions and incident management.


The following additional voluntary modules have been reviewed and updated for Issue 9:

Module 10 – Global G.A.P. Chain of Custody

Module 11 – Meat Supply Chain Assurance.

Module 13 – Meeting FSMA Requirements for Food (Previously known as Module 13: FSMA Preventive controls preparedness)


For more information on the BRCGS Global Standard for Food Safety go to the BRCGS website here:

About BRCGS Global Standard for Agents and Brokers

About BRCGS Global Standard for Agents and Brokers

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:

  1. 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.

  1. 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:

  1. Assemble HACCP Team and Identify Scope
  2. Describe product
  3. Identify intended use and users
  4. Construct flow diagram
  5. On-site confirmation of flow diagram
  6. 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)
  7. Determine the Critical Control Points (Principle 2)
  8. Establish validated critical limits for each CCP (Principle 3)
  9. Establish a Monitoring System for Each CCP (Principle 4)
  10. Establish corrective actions (Principle 5)
  11. Validation of the HACCP Plan and Verification Procedures (Principle 6)
  12. 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.

  1. 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
  • Traceability
  • Complaint Handling
  • Corrective Action
  • Control of Non-Conforming Product
  • Management of Incidents
  • Product Withdrawal and Product Recall
  1. 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.

Implementing a BRCGS Global Standard for Food Safety Issue 8 Compliant Food Safety Management System

Implementing a BRCGS Global Standard for Food Safety Issue 8 Compliant Food Safety Management System

BRCGS Global Standard Issue 8

The BRCGS Global Standard for Food Safety Issue 8 requires a Food Safety Management System to be compliant in 4 key areas:

  • Senior Management Commitment
  • A HACCP/Food Safety Plan
  • A Quality Management System
  • Prerequisite Programmes

The BRCGS Global Standard for Food Safety Issue 8 requirements are in 9 Sections

  1. Senior Management Commitment
  2. The Food Safety Plan – HACCP
  3. Food Safety and Quality Management System
  4. Site Standards
  5. Product Control
  6. Process Control
  7. Personnel
  8. High-Risk, High-Care and Ambient High-Care Production Risk Zones
  9. Requirements for Traded Products

Sections 1 to 3 are self-explanatory, Sections 4 to 8 cover Prerequisite Programmes and Section 9 is specific to Traded Products and may not be applicable.

The requirements BRCGS Global Standard for Food Safety Issue 8 deemed fundamental are:

  • Senior management commitment and continual improvement (1.1)
  • The food safety plan – HACCP (2)
  • Internal audits (3.4)
  • Management of suppliers of raw materials and packaging (3.5.1)
  • 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 operations (6.1)
  • Labelling and pack control (6.2)
  • Training: raw material handling, preparation, processing, packing and storage areas (7.1)

These requirements are essential to an effective food safety operation, failure to address any of these areas effectively would result in a fail during a certification 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.

Maintaining Food Safety Standards During a Pandemic – Part 2

Maintaining Food Safety Standards During a Pandemic – Part 2

This is a continuation of our series of articles on maintaining food safety standards during a pandemic. You can read part 1 one of our series here.

Preparing for a Remote Audit

The image below shows quite a detailed diagram on preparing for your remote audit to meet the BRC Food Safety Standards. It’s a nine point checklist that BRCGS offered certificated sites just to give you a flavour of what BRC proposed and what you’ll actually read later is that the feedback and the lessons learned pretty much mirrored a lot of these points.

  1. 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.
  2. 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.
  3. 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.
  4. 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.
  5. 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.
  6. 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.
  7. 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.
  8. Making sure that the outcomes of the audit are followed through as they should be.
  9. 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.

We know that approximately 20,000 food safety audits took place in the last 12 months and a small percentage were remote audits and blended audits.

We wanted to share a little bit of how that’s worked regarding maintaining supply chain confidence and fluidity. Remote audits are providing reassurance that suppliers are still operating to high safety and quality levels. This is based on the BRCGS remote audits done globally.

During the pandemic what we can see is that there was an increasing trend of remote audits taking place between September 2020 and December 2020 across the globe. In total there were 662 remote audits and they were conducted in 73 countries. Of these, 46 were remote agents and broker audits, 78 were storage and distribution audits, 145 were remote packaging material audits and 355 remote food safety audits.

We can also see it split up by country and about 50 percent of those audits were conducted in Europe, a total of 338 of them. This shows us that the sites, the certification bodies and auditors all got on board reasonably quickly with the new audit options available to them. Their confidence grew as they got used to this new way of working and we can see that reflected in the number of audits done from September right through to December.

In a typical year, approximately 20,000 or more food audits would be completed to the BRCGS food standard. We did see a slight drop off initially during the pandemic but that picked up as the year went on and by January 2021 the number of audits completed were actually more or less the same year-on-year.

We can assume that there have also been less visits overall to sites by specifiers and customers and the question is, has this led to complacency? We will explore this later on in the article.

There was much feedback from the auditors that conducted these remote audits. For them, it was actually quite a bit of a culture shock as well as the site owners as neither had much experience with these that led to a few issues. Many sites hadn’t thought about investing in much of the necessary equipment so there were complaints of poor quality headphones, poor wi-fi in some or all areas, poor lighting that made it very difficult for the auditor to see the standard of construction, and so on. It made a lot of auditors realize how much they rely on the sense usually while conducting an audit, observing the environment and listening to interactions between employees. These were all challenges to a remote audit.

Another issue was that some companies were nervous about releasing their documentation over email but measure such as non disclosure agreements were used to allay most of those fears.

So auditors were initially quite sceptical about how video observations of facilities would work out, given that auditors would lose most of their senses except sight when viewing remotely and the video presentation indeed does not replace a walkthrough of the facility. You do really need to be present on site to get the full experience of the culture of the company and its staff through its operational practices but video does afford some understanding of the process and the overall standard of construction and equipment.

It gives you a pretty good idea about the housekeeping and the hygiene and the general current operating standards.

Some specifiers did want their usual auditor to do the remote audit instead of a new one because they are already familiar with the site layout and they know where the blind spots are but then we also heard that new auditors were seeing new non-conformances because they were less familiar with the site. So by having a new auditor and also by having the documentation in advance this could actually allowed the auditor time to do a more in-depth risk assessment and therefore some sites saw an increase in documentation for non-conformances

We will continue to discuss further lessons that were learned during the pandemic in our 3rd part of this series of articles.

About the BRC Global Standard for Storage and Distribution ( Issue 4 )

About the BRC Global Standard for Storage and Distribution ( Issue 4 )

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:

  1. Senior Management Commitment
  2. Hazard and Risk Analysis
  3. Product Safety and Quality Management System
  4. Site and Building Standards
  5. Vehicle Operating Standards
  6. Facility Management
  7. Good Operating Practices
  8. Personnel

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
Maintaining Food Safety Standards During a Pandemic

Maintaining Food Safety Standards During a Pandemic

Food Safety Challenges

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.

How to Develop a Food Safety Culture

How to Develop a Food Safety Culture

Food Safety Culture

A successful food safety culture is the product of individual and group values, attitudes, competencies and patterns of behaviour 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
  • Newsletters
  • 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.


Pest Management in the Food Operations

Pest Management in the Food Operations

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.

Interior Monitoring

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.

Site Standards

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.

Bird prevention measures

Establishments and surrounding areas should be regularly examined by a competent person for evidence of infestation.

Pest Management Report
How to Reduce Your Complaint levels

How to Reduce Your Complaint levels

Food Complaint Levels

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.