After 25 years of existence, the British Retail Consortium (BRC) still retains a dominant role in U.K. and Europe having 65 percent of the registered sites with 11 percent in North America, according to BRC Global Standards Compliance Program 2016. Although the BRC food safety standard began in the U.K., it is now recognized as a global standard. This standard is recognized as a Global Food Safety Initiative (GFSI) benchmarked food safety scheme.
The current version of BRC is Issue 7, which began officially in July 2015. There are several key modifications/changes for BRC Issue 7 versus Issue 6. Audit protocol’s scopes and exclusions have been tightened to reduce exclusions to an audit. However, excluded products must be manufactured in a segregated area of the facility. Supplier approval is another addition to create a convergence with the U.S. FDA Food Safety Modernization Act requirements under its Foreign Supplier Verification Program.
Also in Issue 7, high-risk suppliers’ food safety programs must have more stringent verification than simply using questionnaires or certificates of analysis. The objective is to have the supplier adhere to a certification in a recognized GFSI scheme, plus take part in first- or third-party audits.
Labeling and packaging control have been tightened also in Issue 7 with a required formalized process in label changes and verification of those changes by the certified site. Another key change is that a BRC certified site must have a documented system to authenticate a facility’s supply chain. A risk assessment program must be performed on all raw material types to assess adulteration of each specific raw material. This needs to be kept updated and current to show dynamic market changes.
BRC has conducted unannounced audits as part of its scheme for some time. If you decide to opt for the unannounced audit scheme, you have to notify your certification body within three months of your last audit date. You then have to decide which option to pursue: Option 1 (full unannounced) versus Option 2 (two-part unannounced audit). Option 2 breaks it down focusing on Good Manufacturing Practices (GMPs) in Part 1. Once corrective actions are completed and verified within a 28-day period, then Part 2 is undertaken, which focuses on systems and documentation. Part 2 can transpire within a 28-day window. My perspective as a former QA manager is that I would opt for Option 1 to get the process done in one full chunk of time. However, I can understand why certain plant operations would opt to truncate the process using Option 2.
The following are several fundamental requirements that involve actual food safety plant issues that I have directly dealt with in my career. However, please keep in mind that all fundamental requirements in BRC are critical to your program’s success and your plant’s certification/recertification.
Senior management commitment and continual improvement. Reviewing programs of my GFSI customers, I find the most disconcerting aspect is the “Groundhog Day” syndrome, namely the same issues or problems are not resolved and are continually reoccurring.
The utilization of Band-Aid remedies are criticized by GFSI and BRC. If non-conformities are repetitive or are resolved without ascertaining “root cause analyses” of non-conformities, the Band-Aid corrective actions do not comply with the ethos of BRC. Specifically, Part 1 Clause 1.1.10 states clearly that senior management “shall ensure that the root causes…have been effectively addressed to prevent reoccurrence.” So, if an auditor finds the same issues being quickly remedied to pass an audit, that in itself is a significant red flag.
Food safety plan review and reassessment. Both the Hazard Analysis and Critical Control Point (HACCP) plans and prerequisite programs (PRPs) must be reviewed, adjusted, and updated prior to the announced or unannounced audit. HACCP plans and PRPs both ought to be living, dynamic documents that are continually reviewed, fine-tuned/tweaked, or overhauled depending upon changes in personnel, operations, product portfolio, regulations, and equipment, to name a few.
Review and reassessment CPs and CCPs must be done on a consistent basis by the entire HACCP team, and not just the quality team.
Internal audits and corrective and preventive actions. Audit teams should include cross functional groups and no audit team members should audit their own work. The internal audit teams must have consistent ongoing refresher training since BRC is a living, dynamic program.
All listed non-conformities should be resolved through corrective actions via root cause analysis to truly attain continuous improvement. The need to assess and correct food safety failures is critical. Remember no Band-Aids here. By documenting the non-conformities, establishing clear reasonable timescales for correction, and using root cause analysis to prevent recurrence, you can create bonafide continual improvement in your food safety program.
Besides the internal audits, documented hygiene and equipment inspections are imperative to benchmark sanitation performance via the documented sanitation standard operating procedures (SSOP).
Layout, product flow, and segregation. In most instances for new state-of-the-art facilities, proper product flow and segregation in the facility design are done well. But in many older plants, this fundamental requirement is a major concern that requires significant capital improvements and creativity to achieve proper plant design and prevent cross-contamination due to flawed product flow and poor segregation of the raw to finished side of plant operations.
Any plant manufacturing RTE or RTU products must be diligent in mapping low- and high-risk zones with high-care and high-risk areas being the critical focus. The site maps have to clearly outline doors for forklifts, pallet trucks, and people while mapping typical traffic routes as well. This includes traffic flow of finished product, in-process products, and waste products.
Be sure to properly plan the mapping before the capital expenditures and construction are undertaken to eliminate the root cause of cross-contamination due to poor layout design and segregation. Issue 7’s Appendix 2: Guideline on Defining Production Risk Zones is a “must” read and should be reviewed annually roughly six months prior to BRC certification/recertification.
Training and allergens. For the permanent employee, continual cross-training is mandatory. An employee performing a critical operation must understand the whole production process and appreciate the HACCP plan and PRPs for their current and former or future job functions. The re-training must challenge the employee and re-address in a new perspective key precepts of the plant’s operation, basics of food safety, PRPs, and cGMPs. Plant personnel must understand and be able to explain the “why” as well as the “how to.”
By having food safety cross-training, it enables the plant team member in question to be more valuable to the organization and provide the operation with a degree of flexibility. This includes the sanitation team, a key cog to the performance of a plant’s BRC Standard and HACCP program. An ideal training tool for production personnel and sanitation staff is to have a hands-on class reviewing a SSOP with either a problematic piece of equipment or environmental sanitation niche (i.e. drains).
And lastly, don’t forget that many BRC certification sites generate non-conformities due to allergen mislabeling, allergen raw material storage, and allergen changeovers on production lines. Equipment and environmental sanitation procedures must be continually reviewed to ensure safety when a production line goes from one type of allergen to another or to a non-allergen product.
Giambrone is vice president of technical services for the food safety division at Rochester Midland Corp. Reach him at cgiambrone@RochesterMidland.com.