Brc Issue 7

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1.1.1

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The site shall have a documented policy which states the site’s intention to meet its obligation to produce safe and legal products to the specified quality and its responsibility to its customers. This shall be:

· signed by the person with overall responsibility for the site

· communicated to all staff .

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1.1.2

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The site’s senior management shall ensure that clear objectives are defined to maintain and improve the safety, legality and quality of products manufactured, in accordance with the food safety and quality policy and this Standard. These objectives shall be:

· documented and include targets or clear measures of success

· clearly communicated to relevant staff

· monitored and results reported at leastquarterly to site senior management.

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1.1.3

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Management review meetings attended by the site’s senior management shall be undertaken at appropriate planned intervals, annually as a minimum, to review the site performance against the Standard and objectives set in clause 1.1.2. The review process shall include the evaluation of:

· previous management review action plans and timeframes

· results of internal, second-party and/or third-party audits

· customer complaints and results of any customer feedback · incidents, corrective actions, out-of-specification results and non-conforming materials

· review of the management of the systems for HACCP, food defence and authenticity

· resource requirements.

Records of the meeting shall be documented andused to revise the objectives. The decisions and actions agreed within thereview process shall beeffectively communicated to appropriate staff, and actions implemented withinagreed timescales.

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1.1.4

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Thesite shall have a demonstrable meeting programme which enables food safety,legality and quality issues to be brought to the attention of senior managementat least monthly and allows for the resolution of issues requiring immediateaction.

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1.1.5

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The company’s senior management shall provide the human and financial resources required to produce food safely and in compliance with the requirements of this Standard.

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1.1.6

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The company’s senior management shall have a system in place to ensure that the site is kept informed of and reviews:

· scientific and technical developments · industry codes of practice

· new risks to authenticity of raw materials

· all relevant legislation applicable in thecountry of raw material supply, production and, where known, the country wherethe product will be sold.

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1.1.7

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Thesite shall have a genuine, original hard copy or electronic version of thecurrent Standard available and be aware of any changes to the Standard orprotocol that are published on the BRC website.

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1.1.8

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Where the site is certificated to the Standard it shall ensure that announced recertification audits occur on or before the audit due date indicated on the certificate.

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1.1.9

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The most senior production or operations manager on site shall participate in the opening and closing meetings of the audit for Global Standard for Food Safety certification. Relevant departmental managers or their deputies shall be available as required during the audit.

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1.1.10

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The site’s senior management shall ensure that the root causes of non-conformities identified at the previous audit against the Standard have been effectively addressed to prevent recurrence.

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1.2.1

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The company shall have an organisation chart demonstrating the management structure of the company. The responsibilities for the management of activities which ensure food safety, legality and quality shall be clearly allocated and understood by the managers responsible. It shall be clearly documented who deputises in the absence of the responsible person.

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1.2.2

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The site’s senior management shall ensure that all employees are aware of their responsibilities. Where documented work instructions exist for activities undertaken, the relevant employees shall have access to these and be able to demonstrate that work is carried out in accordance with the instructions.

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2.1.1

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The HACCP plan shall be developed and managed by a multi-disciplinary food safety team that includes those responsible for quality/technical, production operations, engineering and other relevant functions. The team leader shall have an in-depth knowledge of HACCP and be able to demonstrate competence and experience. The team members shall have specific knowledge of HACCP and relevant knowledge of product, process and associated hazards. In the event of the site not having appropriate in-house knowledge, external expertise may be used, but day-to-day management of the food safety system shall remain the responsibility of the company.

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2.1.2

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The scope of each HACCP plan, including the products and processes covered, shall be defined.

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2.2.1

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The site shall establish and maintain environmental andoperational programmes necessary to create an environment suitable to producesafe and legal food products (prerequisite programmes). As a guide these mayinclude the following, although this is not an exhaustive list:

· cleaning and sanitising

· pest control

· maintenance programmes for equipmentand buildings

· personal hygiene requirements

· staff training

· purchasing

· transportation arrangements

· processes to preventcross-contamination

· allergen controls

The control measures and monitoring proceduresfor the prerequisite programmes must be clearly documented and shall beincluded within the development and reviews of the HACCP.

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2.3.1

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A full description for each product orgroup of products shall be developed, which includes all relevant informationon food safety. As a guide, this may include the following, although this isnot an exhaustive list:

· composition (e.g. raw materials, ingredients,allergens, recipe)

· origin of ingredients

· physical or chemical properties that impactfood safety (e.g. pH, aw)

· treatment and processing (e.g. cooking,cooling)

· packaging system (e.g. modifi edatmosphere, vacuum)

· storage and distribution conditions(e.g. chilled, ambient)target safe shelf life under prescribed storageand usage conditions.

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2.3.2

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All relevantinformation needed to conduct the hazard analysis shall be collected,maintained, documented and updated. The company will ensure that the HACCP planis based on comprehensive information sources, which are referenced andavailable on request. As a guide, this may include the following,although this is not an exhaustive list:

· the latestscientific literature

· historicaland known hazards associated with specific food products

· relevantcodes of practice

· recognisedguidelines

· food safetylegislation relevant for the production and sale of productscustomer requirements.

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2.4.1

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The intended use of the product by the customer, and any known alternative use, shall be described, defining the consumer target groups, including the suitability of the product for vulnerable groups of the population (e.g. infants, elderly, and allergy sufferers).

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2.5.1

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A flowdiagram shall be prepared to cover each product, product category or process.This shall set out all aspects of the food process operation within the HACCPscope, from raw material receipt through to processing, storage anddistribution. As a guide, this should include the following, although this isnot an exhaustive list:

· plan ofpremises and equipment layout · rawmaterials including introduction of utilities and other contact materials (e.g.water, packaging)

· sequence andinteraction of all process steps

· outsourcedprocesses and subcontracted work

· potentialfor process delay

· rework andrecycling

· low-risk/high-risk/high-carearea segregationfinished products, intermediate/semi-processedproducts, by-products and waste.

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2.6.1

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The HACCPfood safety team shall verify the accuracy of the flow diagrams by on-siteaudit and challenge at least annually. Daily and seasonal variations shall beconsidered and evaluated. Records of verified flow diagrams shall bemaintained.

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2.7.1

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The HACCP food safety team shall identify and record all the potential hazards that are reasonably expected to occur at each step in relation to product, process and facilities. This shall include hazards present in raw materials, those introduced during the process or surviving the process steps, and allergen risks (refer to clause 5.3). It shall also take account of the preceding and following steps in the process chain.

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2.7.2

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The HACCP food safety team shall conduct a hazard analysis to identify hazards which need to be prevented, eliminated or reduced to acceptable levels. Consideration shall be given to the following:

· likely occurrence of hazard

· severity of the effects on consumer safety

· vulnerability of those exposed

· survival and multiplication of micro-organisms of specific concern to the product · presence or production of toxins, chemicals or foreign bodies

· contamination of raw materials, intermediate/semi-processed product, or finished product.

Where elimination of the hazard is not practical, justification for acceptable levels of the hazard in the finished product shall be determined and documented.

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2.7.3

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The HACCP food safety team shall consider the control measures necessary to prevent or eliminate a food safety hazard or reduce it to an acceptable level. Where the control is achieved through existing prerequisite programmes, this shall be stated and the adequacy of the programme to control the specific hazard validated. Consideration may be given to using more than one control measure.

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2.8.1

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For each hazard that requires control, control points shall be reviewed to identify those that are critical. This requires a logical approach and may be facilitated by use of a decision tree. Critical control points (CCPs) shall be those control points which are required in order to prevent or eliminate a food safety hazard or reduce it to an acceptable level. If a hazard is identified at a step where control is necessary for safety but the control does not exist, the product or process shall be modified at that step, or at an earlier step, to provide a control measure.

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2.9.1

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For eachCCP, the appropriate critical limits shall be defined in order to identifyclearly whether the process is in or out of control. Critical limits shall be:

· measurablewherever possible (e.g. time, temperature, pH)

· Supported by clear guidance or examples wheremeasures are subjective (e.g. photographs).

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2.9.2

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The HACCP food safety team shall validate each CCP. Documented evidence shall show that the control measures selected and critical limits identified are capable of consistently controlling the hazard to the specified acceptable level.

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2.10.1

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A monitoringprocedure shall be established for each CCP to ensure compliance with criticallimits. The monitoring system shall be able to detect loss of control of CCPsand wherever possible provide information in time for corrective action to betaken. As a guide, consideration may be given to the following,although this is not an exhaustive list:

· on-linemeasurement

· off-linemeasurement

· continuousmeasurement (e.g. thermographs, pH meters etc.).

Where discontinuous measurement is used, thesystem shall ensure that the sample taken is representative of the batch ofproduct.

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2.10.2

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Records associated with the monitoring of each CCP shall include the date, time and result of measurement and shall be signed by the person responsible for the monitoring and verified, when appropriate, by an authorised person. Where records are in electronic form there shall be evidence that records have been checked and verified.

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2.11.1

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The HACCP food safety team shall specify and document the corrective action to be taken when monitored results indicate a failure to meet a control limit, or when monitored results indicate a trend towards loss of control. This shall include the action to be taken by nominated personnel with regard to any products that have been manufactured during the period when the process was out of control.

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2.12.1

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Proceduresof verification shall be established to confirm that the HACCP plan, includingcontrols managed by prerequisite programmes, continues to be effective.Examples of verification activities include:· internalaudits

· review ofrecords where acceptable limits have been exceeded

· review ofcomplaints by enforcement authorities or customers

· review ofincidents of product withdrawal or recall.

Results of verification shall be recorded andcommunicated to the HACCP food safety team.

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2.13.1

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Documentation and record keeping shall be sufficient to enable the site to verify that the HACCP controls, including controls managed by prerequisite programmes, are in place and maintained.

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2.14.1

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The HACCPfood safety team shall review the HACCP plan and prerequisite programmes atleast annually and prior to any changes which may affect product safety. As aguide, these may include the following,although this is not an exhaustive list:

· change inraw materials or supplier of raw materials

· change iningredients/recipe

· change in processingconditions, process flow or equipment

· change inpackaging, storage or distribution conditions

· change inconsumer use

· emergence ofa new risk (e.g. known adulteration of an ingredient)

· following arecall

· newdevelopments in scientific information associated with ingredients, process orproduct.

Appropriate changes resulting from the reviewshall be incorporated into the HACCP plan and/or prerequisiteprogrammes, fully documented and validation recorded.

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3.1

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The company’s processes and procedures to meet the requirements of this Standard shall be documented to allow consistent application, facilitate training, and support due diligence in the production of a safe product.

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3.1.1

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The site’s documented procedures, working methods and practices shall be collated in the form of a printed or electronic quality manual.

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3.1.2

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The food safety and quality manual shall be fully implemented and the manual or relevant components shall be readily available to relevant staff.

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3.1.3

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All procedures and work instructions shall be clearly legible, unambiguous, in appropriate languages and sufficiently detailed to enable their correct application by appropriate staff. This shall include the use of photographs, diagrams or other pictorial instructions where written communication alone is not sufficient (e.g. there are issues of literacy or foreign language).

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3.2

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The company shall operate an effective document control system to ensure that only the correct versions of documents, including recording forms, are available and in use.

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3.2.1

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The company shall have a procedure to managedocuments which form part of the food safety and quality system. This shallinclude:

· a list of all controlled documents indicating thelatest version number

· the method for the identification and authorisationof controlled documents

· a record of the reason for any changes oramendments to documents

· the system for the replacement of existingdocuments when these are updated.

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3.3

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The site shall maintain genuine records to demonstrate the effective control of product safety, legality and quality.

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3.3.1

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Records shall be legible, maintained in good condition and retrievable. Any alterations to records shall be authorised and justification for alteration shall be recorded. Where records are in electronic form these shall be suitably backed up to prevent loss.

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3.3.2

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Records shall be retained for a defined period withconsideration given to:

· any legal or customer requirements· the shelf life of the product.

This shall take into account, where it is specifiedon the label, the possibility that shelf life may be extended by the consumer(e.g. by freezing).As a minimum, records shall be retained for theshelf life of the product plus 12 months.

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3.4

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The company shall be able to demonstrate it verifies the effective application of the food safety plan and the implementation of the requirements of the Global Standard for Food Safety.

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3.4.1

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There shall be a scheduled programme of internal audits throughout the year with a scope which covers the implementation of the HACCP programme, prerequisite programmes and procedures implemented to achieve this Standard. The scope and frequency of the audits shall be established in relation to the risks associated with the activity and previous audit performance; all activities shall be covered at least annually.

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3.4.2

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Internal audits shall be carried out by appropriately trained, competent auditors. Auditors shall be independent (i.e. not audit their own work).

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3.4.3

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The internal audit programme shall be fully implemented. Internal audit reports shall identify conformity as well as non-conformity and the results shall be reported to the personnel responsible for the activity audited. Corrective actions and timescales for their implementation shall be agreed and completion of the actions verified.

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3.4.4

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In addition to the internal audit programme thereshall be a programme of documented inspections to ensure that the factoryenvironment and processing equipment is maintained in a suitable condition for foodproduction. These inspections shall include: · hygiene inspections to assess cleaning andhousekeeping performance

· fabrication inspections to identify risks to theproduct from the building or equipment.

The frequency of these inspections shall bebased on risk but will be no less than once per month in open product areas.

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3.5.1

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The company shall have an effective supplier approval and monitoring system to ensure that any potential risks from raw materials (including packaging) to the safety, authenticity, legality and quality of the final product are understood and managed.

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3.5.1.1

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The company shall undertake a documented riskassessment of each raw material or group of raw materials including packagingto identify potential risks to product safety, legality and quality. This shalltake into account the potential for:

· allergen contamination

· foreign-body risks

· microbiological contamination

· chemical contamination

· substitution or fraud (see clause 5.4.2).

Consideration shall also be given to the significanceof a raw material to the quality of the final product.The risk assessment shall form the basis for theraw material acceptance and testing procedure and for the processes adopted forsupplier approval and monitoring. The risk assessments shall be reviewed atleast annually.

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3.5.1.2

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The company shall have a documented supplierapproval and on going monitoring procedure to ensure that all suppliers of rawmaterials, including packaging, effectively manage risks to raw material qualityand safety and are operating effective traceability processes. The approval andmonitoring procedure shall be based on risk and include one ora combination of:

· certification (e.g. to BRC Global Standards orother GFSI-recognised scheme)· supplier audits, with a scope to include productsafety, traceability, HACCP review and good manufacturing practices, undertaken by anexperienced and demonstrably competent product safety auditoror, for suppliers assessed as low risk only,supplier questionnaires.

Where approval is based on questionnaires, theseshall be reissued at least every 3 years and suppliers will be required tonotify the site of any significant changes in the interim.

The site shall have an up-to-date list of approved suppliers.

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3.5.1.3

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Where raw materials are purchased from agents or brokers,the site shall know the identity of the last manufacturer or packer or for bulkcommodity products the consolidation place of the raw material.

Informationto enable the approval of the manufacturer, packer or consolidator, as inclause 3.5.1.2, shall be obtained from the agent/broker or directly from thesupplier, unless the agent/broker is themselves certificated to the BRC GlobalStandard for Agents and Brokers.

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3.5.1.4

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The procedures shall define how exceptions to thesupplier approval processes in clause 3.5.1.2 are handled (e.g. where rawmaterial suppliers are prescribed by a customer) or where information for effectivesupplier approval is not available (e.g. bulk agricultural commodity products)and instead product testing is used to verify product quality and safety.

When a site produces customer-branded productthe relevant exceptions shall be identified to the customer.

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3.5.2

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Controls on the acceptance of raw materials including packaging shall ensure that these do not compromise the safety, legality or quality of products and where appropriate any claims of authenticity.

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3.5.2.1

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The company shall have a documented procedure forthe acceptance of raw materials and packaging on receipt based upon the riskassessment (clause 3.5.1.1). Raw material including packaging acceptance andits release for use shall be based on one or a combination of:

· product sampling and testing

· visual inspection on receipt

· certificates of analysis – specific to theconsignment

· certificates of conformance.

A list of raw materials including packaging andthe requirements to be met for acceptance shall be available. The parametersfor acceptance and frequency of testing shall be clearly defined, implementedand reviewed.