BRCGS ISSUE 9 CHANGES - REQUIREMENT 1
ASC Public Health and Food Safety Consultants South Africa
Food Safety and Public Health training, auditing and systems implementation, update & FSMS maintenance experts.
In this series of blogs, we will look at the changes between BRCGS Issue 8 and BRCGS Issue 9. The starting point is Requirement 1, which deals with senior management commitment. For any food safety management system to be effectively implemented, Senior Management must be committed to it.
The BRCGS standard places a high priority on clear evidence of senior management commitment. Therefore, it is no surprise that Clause 1.1, which is about Senior Management and Continual Improvement, is a fundamental requirement.
Clause 1.1 – Senior Management Commitment and Continual Improvement
Clause 1.1, senior management commitment and continual improvement, has a minor change.
It is important to note that Clause 1.1 is a fundamental requirement, meaning that the site must ensure that it is fully implemented. So, in terms of Issue 9, there has just been an addition where food safety and quality culture are now part of the commitment and continual improvement.
The new statement of intent now reads as follows:
“The site’s senior management shall demonstrate that they are fully committed to the implementation of the requirements of the global standard for food safety and to processes which facilitate continual improvement of food safety, quality management and the site’s food safety and quality culture.”
Clause 1.1.1 Changes
Under Clause 1.1.1, there has been an addition. The documented policy of this site should also now include a commitment to continuously improving the site’s food safety and quality culture.
Clause 1.1.2 Changes
Clause 1.1.2 deals with food safety culture. There have been a few additions under this clause, and one of them is that there must be a clear plan for developing and continually improving food safety and quality culture.
This must include measures needed to achieve a positive culture change.
This shall include, at a minimum, activities that are designed around the following:
This plan shall be reviewed and updated at least annually at a minimum.
Clause 1.1.3 Changes
The word “AUTHENTICITY” has been added to the following requirement:
“The site’s senior management shall ensure that clear objectives are defined to maintain and improve the safety, authenticity, legality and quality of products manufactured, in accordance with the food safety and quality policy and this Standard”.
Furthermore, the monitoring and reporting of food safety objectives now involve the Senior Management and all staff.
Communication changed from “RELEVANT” to “ALL” staff.
Clause 1.1.4 Changes
Under Clause 1.1.4, there has been an addition where the management review must now include the EVALUATION of the food safety and quality culture plan.
The meeting records shall be documented and used to revise the objectives, encouraging continual improvements, so the addition of “continual improvement” is also new in the Issue 9 version.
Clause 1.1.5 Changes
Under Clause 1.1.5, not much has changed except for the inclusion of the term “AUTHENTICITY”, where now the requirement reads as follows:
“The site shall have a demonstratable meeting programme which enables food safety, authenticity, legality and quality issues to be brought to the attention of senior management”
Please note that the following section in Clause 1.1.5 of Issue 8 moved to Clause 1.2.3. in Issue 9:
“Employees shall be aware of the need to report any evidence of unsafe or out-of-specification product or raw materials, to a designated manager to enable the resolution of issues requiring immediate action”
Clause 1.1.6 Changes
Under Clause 1.1.6, the term “AUTHENTICITY” is added in the following requirement:
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“The company shall have a confidential reporting system to enable staff to report concerns relating to product safety, AUTHENTICITY, legality and quality.”
There is also a change where the word “MUST” changed to “SHALL” in the following requirement:
“The mechanism, for example, a telephone number for reporting concerns, SHALL be clearly communicated to staff.”
Clause 1.1.7 Changes
Under Clause 1.1.7, there has been a change. The word “FOOD SAFETY” has been replaced by “safe, authentic, legal products to the specified quality.”
The new requirement now reads as follows:
“The company’s senior management shall provide the human and financial resources required to produce safe, authentic, legal products to the specified quality and in compliance with the requirements of this Standard.”
Clause 1.1.10 Changes
Clause 1.1.10 includes a new addition. It now comprises BLENDED, announced recertification audits.
Clause 1.1.11 Changes
Under Clause 1.1.11, the following was added:
“A member of the senior management team on site shall be available during the audit for a discussion on effective implementation of the food safety and quality culture plan”
Clause 1.1.14 Added
Clause 1.1.14 is new.
“Where required by legislation, the site shall maintain appropriate registrations with the relevant authorities.”
The relevant authorities could be government departments, for example, the Department of Agriculture, the Department of Health or any other department the site must maintain registrations with.
Organisational Structure, Responsibilities and Management Authority (C1.2)
Clause 1.2.1 Changes
In Clause 1.2.1, the word “INTEGRITY” changed to “AUTHENTICITY”.
The requirement now reads as follows:
“The responsibilities for the management of activities which ensure food safety, authenticity, legality and quality shall be clearly allocated and understood by the managers responsible.”
Clause 1.2.2 Changes
There has been a change in wording in Clause 1.2.2, which include the need to ensure employees are aware of their responsibilities and that the work performed must be by documented policies, procedures, work instructions, and the company’s existing practices.
Furthermore, all staff shall have access to relevant documentation.
Clause 1.2.3 Added
Clause 1.2.3. is a new clause added under Clause 1.2? (Please note that the last section of Clause 1.1.5 in Issue 8 moved here, and the wording changed.)
The requirement now reads as follows:
“Staff shall be aware of the need to report any risk or any evidence of unsafe or out of specification products, equipment, packaging, or raw materials to a designated manager to enable the resolution of issues requiring immediate action.”
Clause 1.2.4 Added
Clause 1.2.4 is a new requirement under Clause 1.2. It recognises that the site may need to use external assistance to ensure full conformity to the standard, but at the same time, the running of the Food Safety Management System remains the responsibility of the site.
Summary