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The British Retail Consortium (BRC) Global Standard for Food Safety (version 6) was published on July 31st 2011 and will succeed version five of the Standard in all audits conducted from January 1st 2012. The primary changes in the versions of the standard are rooted in the focus of the requirements, and hence the audit protocol and scope, in that the primary focus is to be the condition of the factory rather than the condition of the paperwork.
To this end, the focus of the new version will be on Good Manufacturing Practices (GMP) which is achieved by shifting the balance of the audit away from the paperwork onto the requirements that favour GMP and the actual hygienic condition of the factory. So whilst there has been an overall reduction in the number of requirements (criteria) those concerning hygiene & housekeeping, foreign body control and allergens have been increased by 25 – 30%.
In this document we will focus only on those areas where Holchem services, systems or products have an impact (either direct or in-direct) and customers are advised to review the new standard as this list will not be exhaustive.
Chemical Control (4.9.1)
This section is little changed from version five, however one wording change is from “where appropriate confirmed suitable for food use” to “confirmation of suitability for use in a food processing environment”. Whilst all of Holchem’s products are suitable for use in a food processing environment (when used in accordance with our product information, safety data sheets and Cleaning Instruction Cards) they are clearly not suitable for food use – indeed the primary function of most detergents and disinfectants is to degrade or denature biological systems in order to achieve their intention.
Hygiene and Housekeeping (4.11)
This section has been re-written and expanded although the intent remains the same as version five – the key difference will be in the interpretation and focus on this section during an audit. The BRC Technical Director (Kevin Brackston) has publically stated that the following will be included in audits from January 2012: -
• An increased proportion of the audit time will be spent in the plant – guidelines suggest up to 60% of the total time on site.
• Assessment of line changeover procedures and the standards achieved (this will also link to the demonstrable competency of those undertaking the cleaning tasks).
• The potential for the auditor to request the dismantling of equipment not in production use to assess the efficacy of any clean and the standards achieved.
• The clear definition of the standard of clean required (allergen, microbiological, visual or chemical) as well as an increased emphasis on both the validation and on-going verification of the cleaning process.
• The results, and corrective actions, of any GMP (or cleaning) audits undertaken by site hygiene / technical management (1st party audits).
• A system to check that equipment has achieved the required standard of cleanliness prior to release back to production (this links to the on-going verification of cleaning). These checks must be recorded and used to identify trends in cleaning performance.
• The resources to undertake the clean must be available, including cleaning activities undertaken outside of normal production hours.
Arguably, one of the most significant changes is the greatly increased requirements with regard to Clean In Place (CIP) systems (4.11.6) to include the provision of schematics, revalidation of systems, monitoring and maintenance, key requirements relating to the operation of the system: -
• Process parameters (time, detergent concentrations, flow rates and temperatures) shall be defined to ensure removal …… This shall be validated and records maintained.
• Detergent concentrations shall be taken routinely.
• Process verification through the sampling of rinse waters for the presence of cleaning fluids, allergens or microorganisms as appropriate.
• Detergent tanks shall be kept stocked and records kept of both filling and emptying dates. Recovered pre-rinse solutions must be monitored for the build-up of carryover from the detergent tanks.
Holchem would advise customers to choose their terminology very carefully as in our experience many of the systems we are introduced to as “CIP” cleans are, in fact, recirculation or flush-through cleans utilising the product pump and are not actually CIP in the sense intended by the BRC standard. However, if introduced as a CIP system then they will most likely be judged against the set of requirements and criteria contained in version 6 – in Holchem’s experience the majority of these would be highly unlikely to meet the requirements and attract a number of minors.
Management of Allergens (5.2)
This section has most definitely been totally re-written from version 5 based on new developments, recalls and issues experienced by food manufacturers in the past three years – once again the BRC Technical Director has stated that this is a key area for the new standard with the requirements being extended accordingly: -
• There is more specific guidance on measures to avoid cross contamination (including the scheduling of product runs) and these requirements will no doubt form the back-bone of the audit against this section.
• Assessment (both during the audit and be review of verification procedures) of line start up and changeover procedures.
• Allergen awareness training for all staff (including agency)
• Inclusion of New Product Development – the procedures and controls in place to ensure that inappropriate ingredients are not included, or if they are that they are controlled.
• The equipment or area cleaning procedures shall be designed to remove or reduce to an acceptable level any potential cross-contamination. Methods must be validated to ensure they are effective and the effectiveness of the procedure routinely verified.
The requirement remains that staff are trained “commensurate with their duties and responsibilities” and that where their activities are related to critical control points (such as any cleaning duties) that they are demonstrably competent.
A new requirement, however, is that the company must be able to retrieve training records relating to agency or temporary staff.
Personal Hygiene (7.2)
This section has mainly been reworded to simplify the requirements and to take into account personal privacy laws that may exist in countries outside of the UK. In particular, the requirements relating to jewellery.
As stated previously, this summary is not an exhaustive analysis of the new BRC version 6, but rather a summary of the main areas in which Holchem may have a direct or indirect impact. Other areas of interaction not covered in this briefing note are Layout, Product Flow and Segregation (4.3); Building Fabric (4.4); Equipment (4.6); Maintenance (4.7); Staff Facilities (4.8); Dispatch and Transport (4.15).