The new, eighth version of the BRC FOOD standard is effective from 1 February 2019.
Dear Ms. Maria Kosik, you are experienced auditor of food safety systems including BRC, IFS, Global Gap, ISO 22000 in Poland. The eighth version of the BRC FOOD standard has brought a lot of changes. What areas of certified organizations have required the largest amount of work?
I have been working as an auditor for 15 years and it is no surprise to me that with each new version of the standard there are a number of doubts related to the interpretation or approach to the assessment and implementation of the new requirements. Issue 8 pays particular attention to the need for the prevention of food fraud. This applies both to purchased raw materials, additives, materials and to products manufactured in the audited plant. This is a difficult topic and not all companies have dealt with it. A reliable risk assessment for raw materials requires detailed knowledge of products, market knowledge, traceability of the supply chain and historical data on fraudulent and adulterated activities. Implementation of the requirements of food fraud allows us to control the authenticity of food products systemically, starting from risk assessment for purchased raw materials, risk assessment and qualification of suppliers, verification of the supply chain in the case of purchases from intermediaries and moving on to the control of labels and information communicated to consumers.
Food defence (i.e. the need for rigorous product security and food defence systems to prevent malicious contamination of products) was one of the biggest challenges for companies in the previous version of the standard. Has anything changed in this area? Perhaps problems with obtaining full compliance in many cases has caused the owners of standards to ease the requirements?
The requirements are adequate to the threats. The company decides what supervisory measures will be applied on the basis of the assessment of potential risk (threat assessment) for malicious contamination or damage to products. The company undertakes a documented risk assessment plan. Where the raw materials or products are identified as being particularly vulnerable, the risk assessment plan must include control measures to minimize the risk. If preventive actions are not sufficient or possible, systems should be put in place to identify any interference. The areas in which a significant risk has been identified should be identified, monitored and controlled.
As in the case of adulterations, this forms the basis for reliable and detailed risk assessment. I encourage you to use the practical and easy to use guide, which is PAS 96.
The qualification of traded products and their exclusion is also important from the point of view of the scope of certification.
The audited companies often offer their clients traded products that are not produced in their factory. The new version of BRC allows you to include traded products in the scope of certification. Until now, certification was possible with the use of an additional voluntary module. Currently, the requirements for traded products included in Chapter 9 are an integral part of the eighth version of the standard. The decision about their certification is taken by the company.
Have new requirements for high-risk, high care and ambient high care production zones forced a change in the plant's approach to the organization of this area? Was it necessary to make new investments or only minor adjustments in the processes?
For products requiring treatment in high risk, high care and ambient high care zones requiring high caution, the requirements were defined in the previous version of the BRC standard. We could find them in individual chapters, e.g. social rooms, work clothes, hygiene maintenance, product flow, air flow, air quality and utilities (including sewage). This scattering was often a reason to overlook details and resulted in inconsistencies during the audit. Version 8 reordered the requirements for these areas and placed them in one chapter.
And what is the level of food safety culture in companies? How should we assess "soft" elements of systems?
This is a new topic for both companies and auditors. You can take a certain key to assess this area. Companies introduce activities that aim to motivate employees to report incidents that may affect food safety. It is very important to involve the highest management in creating this culture, to set a good example, to inspire a "cultural" approach to food production. The topic is noteworthy, which is why we will discuss it in more detail during the annual Experience Exchange of Quality Managers in Krakow, where I will conduct workshops for quality advisers dealing with the most common discrepancies in audits.
Thank you, Ms. Kosik, for the interview.