This document provides information about an upcoming webinar on the changes to the BRC Global Standard for Food Safety Issue 8. The webinar will cover the key changes to the requirements and audit protocol in Issue 8, including a focus on developing a product safety culture, expanding environmental monitoring requirements, and providing greater clarity for high risk production areas and pet food manufacturing. The webinar presenters will provide background on the changes, discuss their implications, and outline next steps.

1. WEBINAR
Deep-dive - BRC Global Standard for Food Safety Issue 8
Tuesday, September 25th, 2018 | 2 pm

2. • Master of Science Degree in Food Science & Technology
• 20 years experience in food industry prior to becoming an auditor in
2002
• Audits in three of the four GFSI-recognized schemes/certification
systems including BRC GSFS
• 2016 Auditor of the Year – SQFI
• 2017 Auditor of the Year – BRC
Welcome!
Yuksel Eyyuboglu, Technical Manager, SAI Global

3. • Background and timeline
• Changes to the requirements
• Changes to the audit protocol
• Next steps
Agenda

4. BRC Food Safety
Key Aims
• Improve food safety
• Facilitate improvements and efficiencies in
the manufacture of products
• Enable manufacturers to meet the demands
of their customers – reducing multiple
audits

5. Scope of BRC’s Food Safety Standard
• Processed foods
both own brand and customer branded
• Raw materials
or ingredients for use by food service
and food manufacturers
• Primary products
such as fruit and vegetables
• Pet foods
for domestic animals

6. Key Changes
• Development of a product safety culture
• Expansion of requirements for environmental monitoring
• Encouraging sites to further develop systems for security and food defense
• Adding clarity to the requirements for high risk, high care and ambient
high care production risk zones
• Providing greater clarity for sites manufacturing pet food
• Ensuring global applicability and GFSI benchmarking
The focus for this Issue has been on:

7. Key Changes
Timescales
August
2018
Standard
Published
September
2018
ATP Training
October
2018
Auditor & Site
Training
Begins
February
2019
V8 food
safety audits
start

8. Key Changes
Food Safety Culture
Food safety culture – A fundamental factor in the
management of product safety. Challenging to
audit, however it is important that food safety
culture is considered within the requirements of
the Standard
Background and Objective
Requirement
Sites shall plan to maintain and develop product
safety and quality culture within the business

9. Key Changes
Section 1.0
The site’s senior management shall define and
maintain a clear plan for the development and
continuing improvement of food safety and quality
culture. This shall include:
• Defined activities involving all sections of the site
that have an impact on product safety
• An action plan indicating how the activities will
be undertaken, measured and intended
timescales
• Review of the effectiveness of completed
activities
Change 1.1.2 added
NB: Auditors will NOT be attempting to audit the culture of
the site but will be looking at how sites have implemented
the bullet points above. Effectiveness will be assessed
only on the site’s 2nd Issue 8 audit

10. Key Changes
Section 1.0
Changes – 1.14 amended
Management review meetings attended by the site’s
senior management shall be undertaken at appropriate
planned intervals …………. to review the site performance
against the Standard and objectives set in clause 1.1.3
…………..
 any objectives that have not been met, to understand
the underlying reasons. This information shall be used
when setting future objectives and to facilitate
continual improvement
 the effectiveness of the systems for HACCP, food
defence and authenticity

11. Key Changes
Section 1.0
The site shall have a demonstrable meeting programme
which enables food safety, legality, integrity and quality
issues to be brought to the attention of senior
management. These meetings shall occur at least monthly.
Change - 1.1.5 amended
Product safety is the responsibility of all staff – not just a
select few, therefore all staff need to know how to report
concerns and incidents.
The objective of this clause is to ensure that there is a
mechanism for food safety and quality issues to be raised and
discussed at a senior management level within the site.
Most sites have weekly or monthly management meetings and
the inclusion of safety, legality and quality as an agenda item
within this meeting is one way to meet the requirements of this
clause.

12. Key Changes
Section 1.0
Change - 1.1.6 added
The company shall have a confidential reporting system to
enable staff to report concerns relating to product safety,
integrity, quality and legality.
The mechanism (e.g. the relevant telephone number) for
reporting concerns must be clearly communicated to staff.
The company’s senior management shall have a process
for assessing any concerns raised. Records of the
assessment and, where appropriate, actions taken, shall
be documented.
Change - 1.1.8 amended
The company’s senior management shall have a system in
place to ensure that the site is kept informed of and
reviews:
All relevant legislation in the country where the
product will be sold (where known).

13. Key Changes
Section 1.0
Change - 1.1.13 added
The BRC Global Standards logo and references to
certification status shall only be used in accordance with
the conditions of use detailed in the ‘General Audit
Protocol’ (Part III, section 5.6) of the Standard.

14. Key Changes
Section 2.0
• Some countries (eg the USA) have regulatory
requirements that incorporate all HACCP processes
outlined by Codex Alimentarius but use different
terminology.
• The specific terminology within the Standard, such
as HACCP, prerequisites or critical control points,
are intended to utilize the most commonly used
global terminology to describe expectations. Sites
are not required to use the specific terminology of
the Standard, but are expected to fully meet the
requirements.
• Thus, reviewed wording for section 2 of the
Standard on the HACCP Food Safety Plan to
ensure compatible in all countries and geographies.
HACCP/ Food Safety Plan

15. Key Changes
HACCP/ Food Safety Plan
Examples of reviewed wording for section 2 of the Standard to
ensure compatible in all countries and geographies:
2.1.1: The team leader shall have an in-depth knowledge of Codex HACCP principles
(or equivalent) and be able to demonstrate competence, experience and training.
Where there is a legal requirement for specific training, this shall be in place.
2.7.1: 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 consideration of the following types of
hazard:
• microbiological
• physical contamination
• chemical and radiological contamination
• fraud (e.g. substitution or deliberate/intentional adulteration)
• malicious contamination of products
• allergen risks (see clause 5.3).
2.14.1: …..• emergence of a new risk (e.g. known adulteration of an ingredient or
other relevant, published information, such as the recall of a similar product)
• new developments in scientific information associated with ingredients, process
or product. Appropriate changes resulting from the review shall be incorporated
into the HACCP or food safety plan and/or prerequisite programmes, fully
documented and the validation recorded. Where appropriate, the changes shall
also be reflected in the company’s product safety policy and food safety
objectives.

16. Key Changes
Section 3
3.2.1: Where documents are stored in electronic form
these shall also be:
• stored securely (e.g. with authorised access, control of
amendments, or password protected)
• backed up to prevent
3.3.1: Where records are in electronic form these
shall also be:
• stored securely (e.g. with authorised access, control of
amendments, or password protected)
Document Control - Records

17. Key Changes
Section 3.0
• Many sites are still not effectively scheduling
their internal audits throughout the year -
where audits are only completed once or
twice a year the system is more likely to lead
to a fall in standards between audits
• 3.4.1 amended to make sure that the safety
management systems are being assessed in
depth at regular intervals – at least 4 audit
dates per year
3.4: Internal Audits

18. Key Changes
Section 3.4 – Internal Audits
3.4.1: There shall be a scheduled programme of internal
audits.
At a minimum, the programme shall include at least four
different audit dates spread throughout the year. The
frequency at which each activity is audited shall be
established in relation to the risks associated with the activity
and previous audit performance. All activities shall be covered
at least once each year.
At a minimum, the scope of the internal audit programme shall
include the:
• HACCP or food safety plan, including the activities to
implement it (e.g. supplier approval, corrective actions and
verification)
• prerequisite programmes (e.g. hygiene, pest control)
• food defence and food fraud prevention plans
• procedures implemented to achieve the Standard.
Each internal audit within the programme shall have a defined
scope and consider a specific activity or section of the HACCP
or food safety plan.

19. Key Changes
Section 3.5 – Supplier Approval
• Safety, integrity, legality and quality of raw
materials are fundamental to the site’s operations
• GFSI benchmarking
Background & objective
Requirement
• All of the requirements reviewed and updated to
ensure rigorous control controls of raw materials
whilst maintaining practical application

20. Key Changes
Section 3.5 – Supplier Approval
The risk assessment for a raw material shall be updated:
• when there is a change in a raw material, the processing of a raw
material, or the supplier of a raw material
• if a new risk emerges
• following a product recall or withdrawal, where a specific raw material has been
implicated
• at least every 3 years.
Changes – 3.5.1.1 - Amended
Changes – 3.5.1.2 - Amended
The approval procedure shall be based on risk and include either one or a
combination of:
• a valid certification to the applicable BRC Global Standard or GFSI-
benchmarked standard. The scope of the certification shall include the raw
materials purchased
• supplier audits, with a scope to include product safety, traceability, HACCP
review and good manufacturing practices, undertaken by an experienced and
Demonstrably competent product safety auditor. Where the supplier audit is
completed by a second or third party, the company shall be able to:

21. Key Changes
Section 3.5 – Supplier Approval
Changes – 3.5.1.2 – Amended (cont…)
–– demonstrate the competency of the auditor
–– confirm that the scope of the audit includes product safety, traceability,
HACCP review and good manufacturing practices
–– obtain and review a copy of the full audit report
or
• where a valid risk-based justification is provided and the supplier is
assessed as low risk only, a completed supplier questionnaire may be used
for initial approval. The questionnaire shall have a scope that includes
product safety, traceability, HACCP review and good manufacturing
practices, and it shall have been reviewed and verified by a demonstrably
competent person.

22. Key Changes
Section 3.5 – Supplier Approval
Changes – 3.5.1.3 – Changed
There shall be a documented process for ongoing supplier performance review,
based on risk and defined performance criteria.
The process shall be fully implemented.
Where approval is based on questionnaires, these shall be reissued at least every
3 years and suppliers shall be required to notify the site of any significant changes
in the interim, including any change in certification status.
Records of the review shall be kept.
The site shall have an up-to-date list or database of approved suppliers.
This may be on paper (hard copy) or it may be controlled on an electronic
system.
The list or relevant components of the database shall be readily available
to the relevant staff (e.g. at goods receipt).
Changes – 3.5.1.4 – Changed

23. Key Changes
Section 3.5.2 Raw Material and Packaging Acceptance
Changes – 3.5.2.2 – Added
Procedures shall be in place to ensure that approved changes to raw materials
(including primary packaging) are communicated to goods receipt personnel and
that only the correct version of the raw material is accepted.
For example,
when labels or printed packaging have been amended, only the correct version
should be accepted and released into production.
Where the site is in receipt of live animals, there shall be an inspection by a
suitably competent individual at lairage (holding pens) and post mortem to
ensure that the animals are fit for human consumption.
Changes – 3.5.2.3 – Added

24. Key Changes
Section 3.5.4 Management of Outsourced Processing
Defining outsourced processing
Outsourced processing
(Sub-contracted processing)
Outsourced processing is where an
intermediate production process or step in
the manufacture of a product, is completed
at another company or site.
Complete production offsite
(contract manufacture)
Offsite packing (contract
packing)
Product not returned to site
≠ Outsourced processing

25. Key Changes
Section 3.7 Corrective and Preventive Actions
Changes – 3.7.3 – Added
The site shall have a procedure for the completion of root
cause analysis.
At a minimum root cause analysis shall be used to
implement ongoing improvements and to prevent
recurrence of non-conformities when:
• analysis of nonconformities for trends shows there
has been a significant increase in a type of non-
conformity
• a non-conformity places the safety, legality or quality
of a product at risk.

26. Key Changes
Section 4.2 Site Security and Food Defence
• Rigorous food defence systems have gained
renewed understanding and should form an
integral part of factory protocols
• Procedures adopted to assure the safety of raw
materials and products from malicious
contamination or theft
Background and Objective
• Threat (risk) assessment with actions (a plan)
based on risk
• Scope of the risk (threat) assessment the same
as the process flow diagram (clause 2.5) i.e. all
stages when product is under the management
control of the site
Changes – Section 4.2.1 Amended

27. Key Changes
Product Security and Food Defense
4.2.1 The company shall undertake a documented risk assessment (threat assessment) of the potential risks to
products from any deliberate attempt to inflict contamination or damage. This threat assessment shall include
both internal and external threats.
The output from this assessment shall be a documented threat assessment plan. This plan shall be kept under
review to reflect changing circumstances and market intelligence. It shall be formally reviewed at least annually
and whenever:
• a new risk emerges (e.g. a new threat is publicised or identified)
• an incident occurs, where product security or food defence is implicated.
4.2.2 Where raw materials or products are identified as being at particular risk, the threat assessment plan shall
include controls to mitigate these risks. Where prevention is not sufficient or possible, systems shall be in place
to identify any tampering.
These controls shall be monitored, the results documented, and be subject to review at least annually.
4.2.3 Areas where a significant risk is identified shall be defined, monitored and controlled. These shall include external
storage and intake points for products and raw materials (including packaging).
Policies and systems shall be in place to ensure that only authorised personnel have access to production and
storage areas, and that access to the site by employees, contractors and visitors is controlled. A visitor recording
system shall be in place.
Staff shall be trained in site security procedures and food defence.
4.2.4 Where required by legislation, the site shall maintain appropriate registrations with the relevant authorities.

28. Key Changes
Section 4.9 Chemical and Physical Contaminants Control
4.9.6.1 - Added
Procedures shall be in place to prevent physical
contamination of raw materials by raw material
packaging (e.g. during debagging and deboxing
procedures to remove the packaging).
4.9.6.2 – Added:
Pens used in open product areas shall be
controlled to minimise the risk of physical
contamination (e.g. designed without small parts
and detectable by foreign-body detection
equipment).
4.9.6 Other Physical Contaminants

29. Key Changes
Environmental Monitoring
• Measures the overall effectiveness of hygienic
design, personnel practices, and operational
methods
• Provides information about indicator organisms,
spoilage organisms, pathogens of concern in a
timely manner, so that appropriate corrective
actions can be initiated to prevent potential
microbial outbreaks
• Acts as an early warning system for microbiological
hazards in both the production and post-production
environment when effectively implemented as an
integral part of prerequisite programs
• Helps detect hot spots in a plant that may act as a
source of contamination
• Validates the hygiene program and helps in
determining the frequency for cleaning & Hygiene

30. Key Changes
Environmental Monitoring
4.11.8.1 - Added
• The design of the environmental monitoring
programme shall be based on risk, and at a minimum
include:
• sampling protocol
• identification of sample locations
• frequency of tests
• target organism(s) (e.g. pathogens, spoilage
organisms and/or indicator organisms)
• test methods (e.g. settle plates, rapid testing and
swabs)
• recording and evaluation of results.
The programme and its associated procedures shall be
documented.

31. Key Changes
Section 8.0 High Risk, High Care Areas
Issue 8 will add greater clarity to the
requirements for high risk, high care and
ambient high care production risk zones
Where a site produces products that require
handling in high risk, high care and/or ambient high
care production facilities all the relevant
requirements from sections 1 to 7 of the Standard
must be fulfilled in addition to the requirements in
this section.

32. Key Changes
Pet Food
• Pet food is within the scope of the Standard (animal feed is not)
• GFSI benchmarking introduced 3 new requirements for pet food (not applicable for human
food)
Background and Objective
• Clause 5.8.1 – Formulated for intended use (complete diet
or complementary)
• Cause 5.8.2 – Management of ingredients harmful to
untended recipients
• Clause 5.8.3 – Management of medicinal products
• Review of the effectiveness of completed activities
Changes – Section 5.8

33. Key Changes
Audit Protocol
• Announced Audit – where the site and the certification
body agree the date of the date of the audit, in advance.
• Unannounced Audit – where the audit date is not
communicated to the site in advance of the audit.
• The unannounced audit programme remains voluntary
and sites can still continue to opt for an announced or an
unannounced audit.
• Option 2 unannounced audits have been removed,
simplifying the options to just announced or
unannounced.
Issue 8 provides sites with 2 audit options

34. Key Changes
Interim Reporting
A consistent concern raised by key stakeholders
is the time gap between audit and confirmation of
Certification.
• Following each audit an ‘interim’ report shall be
available on the BRC Directory within 10 calendar
days.
• Contents strictly limited to date of audit, details of the
audit scope and the non- conformities found.
• Final audit report will still be available after 42 days –
currently being designed

35. Key Changes
Section 9.0 - Traded Goods
• Issue 7 introduced a traded goods module for products
that are stored onsite but not manufactured, processed
or packed onsite
• Now forms Section 9 of the Standard
• Section 9 is voluntary but opting out is considered an
exclusion from scope
Requirements are substantively unchanged
• Three clauses (9.1.2, 9.1.4 & 9.2.4) updated to reflect
wording in main Standard.
• Section 9 will form part of the Standard non-conformities

36. In summary
The new BRC Standard focusses in part on areas of perceived weakness in Issue
7.The GFSI Benchmarking process has also helped determine what additional
requirements are required.
There is a lot of guidance in the coming months:
• The Issue 8 Standard was published alongside Interpretation guidelines and a key
changes document explaining differences between 7 – 8. These are free
• BRC Participate is now available to all BRC certificated sites and registration
details will soon be available
• A Q& A Document (FAQ) will also be published from October to December,
alongside a gap audit checklist and New guidelines to provide clarification on some
of the new areas such as the Food safety Culture
• Training against Issue 8 will also commence in October
.

37. Road Ahead – How we can help you on your journey to Issue 8
Attend training:
• BRC Global Standard for Food Safety Issue 8 – Issue 7 to 8
Conversion for Sites
• BRC Global Standard for Food Safety Issue 8 – Issue 7 to 8
Conversion for Auditors
• BRC Issue 8 Audits from Feb 2019
• Conduct a GAP Analysis
• Get the standard from https://www.brcbookshop.com
For more details email information@saiglobal.com

38. www.saiglobal.com