BRC GLOBAL STANDARD FOR FOOD SAFETY ISSUE 7 BRIEFING DOCUMENT

Overview of the key changes between Issue 6 and Issue 7

Introduction
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The BRC published Issue 7 of the Global Standard for Food Safety in January 2015, and this new standard will be used for all audits from 1 July
2015. Certificates against Issue 6 will remain valid for the duration indicated on the certificate. The intention of this document is to inform
you of some of the key changes between issue 6 and issue 7. It is not possible in a document such as this to provide a comprehensive list of
every change. In order to prepare fully for an audit it will be necessary to obtain a copy of the standard directly from the BRC.
The scope of the Standard remains the same however, there is greater focus on transparency and traceability through extended supply chains,
and systems to identify and assess vulnerability to food fraud. In addition to this, the protocol and grading systems have been reviewed and
the need for additional modules has also been considered. The proportion of the audit duration which is spent assessing the factory
processing areas, holding discussions with production staff, following audit trails and observing product changeover procedures etc, which was
extended moving into issue 6, has been maintained with issue 7.

Protocol Changes:
Unannounced Audits:
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The protocol for unannounced audits remains the same.

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If you have elected to enter the unannounced audit scheme, if your re-audit due date is 1 July 2015 or later, it is possible that your
audit could be against either issue 6 or issue 7 of the standard. Within the scheme rules we are not permitted to notify you which
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this will be. If your audit starts on or before 30 June 2015 it will be issue 6, if it starts on or after 1 July 2015 it will be issue 7.
Unannounced audits are now available to all sites although sites which are not currently certificated need to recognises that the
audit may not take place for up to 1 year from the date of application.

Exclusions From Scope:

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Exclusions must be agreed by the Certification Body prior to the audit these must be clearly written on your audit application form.
Exclusions will be limited to the following conditions:
o The excluded products can be clearly differentiated from products within scope
AND
o The products are produced in a physically segregated area of the factory
Use of the BRC logo is not permitted where exclusions are present

Voluntary Modules:
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With the intention of reducing the need for multiple audits, the BRC will be issuing voluntary modules. These will include: Traded
Goods, Food for Animal Feed, Chain of Custody, Food Defence.

Grading:
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Grading system reviewed. New AA top grade for 5 or less minors only.
A grade remains unchanged at 10 or less minors only
B, C and D grades are now also possible

Enrolment Program:
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Broken into 2 tier audit aligned with GFSI Global Markets Programme at basic and intermediate level

Audit Duration:
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A typical audit duration is 2 3 days and the approximate duration will be confirmed prior to the audit
Approximately 50% of the audit will be spent auditing the production and site facilities. This includes interviewing staff, reviewing
production documentation and observing processes.

Head Office audits:

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The audit of the central system against issue 7 of the Standard must be completed before undertaking any manufacturing site audits
against issue 7 of the standard.

BRC GLOBAL STANDARD FOR FOOD SAFETY ISSUE 7 BRIEFING DOCUMENT

Overview of the key changes between Issue 6 and Issue 7
The Audit Requirements:
New Fundamental Requirements:
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2 new fundamental requirements (resulting in 12 fundamental requirements in total) reflecting the importance of supplier
management and the packing and labelling operations:
o Management of Suppliers of Raw Materials and Packaging (3.5)

Updated requirements to cover agents and brokers

Updated requirements for the management of raw material and packaging material suppliers in view of the
number of issues related to raw materials

Includes consideration of the potential for substitution or fraud, and annual review of risk assessments

Requirement relating to exceptions and customer nominated suppliers

o Labelling and Pack Control (6.2)

Detailed requirements to manage product changeover and issue of packaging materials to packing lines, and
auditor observation of a product changeover

Considers on line vision equipment where used

Sample label verification with vertical traceability audit

Introducing a focus on prevention of incorrect labelling

Highlights changes which should trigger a review of label information and requires the site to have processes in
place to manage these changes

Considers label information where it is the responsibility of a customer or nominated third party

Internal Audit (3.4)

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Reworded clauses explaining that internal audits should be scheduled throughout the year

Traceability (3.9)
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2 new clauses to provide greater assurance of supplier traceability, and accountability of agents and brokers
New requirement that when purchasing from agents or brokers the site shall know and approve the identity of the last manufacturer
or packer. For bulk commodities the consolidation place of the raw material.

Authenticity, Claims and Chain of Custody (5.4)

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New section with 3 new clauses access to information to inform risk assessments, vulnerability assessment of raw materials and
introduction of risk based testing or assurance to mitigate risk.
Vulnerability assessment to take into account historical evidence of substitution or adulteration, economic factors, ease of access
to materials, sophistication of testing available, nature of material etc. Intention to then implement strategies to respond to higher
risk factors.
Added clarity to what is included. Halal, Organic etc are not covered by BRC audit but the auditor will ask for evidence that the site
has appropriate certification.
Claims covered include specific origin or provenance, breed / varietal claims / assured status (eg GlobablGAP, Red Tractor /
sustainable palm oil), GMO / Identity preserved status, named specific trademarked ingredients.
Does not include nutrition or allergens.

High Risk / High Care

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Revised high risk and high care guideline document

Definitions of high risk and high care very similar to issue 6. However Issue 6 states vulnerable to the growth of pathogens, whereas
Issue 7 states vulnerable to growth or survival of pathogens such that they may subsequently grow and therefore cause food
poisoning to survive due to the food matrix eg fatty food, such that a lot effective dose can cause food poisoning.
Previous position statement regarding footwear has been included in the requirements 4.8.4 and 4.8.5 (including the need for
environmental monitoring to ensure the effectiveness of footwear controls)
Decision trees and detailed guidance to assist definition of risk areas are included in the standard

BRC GLOBAL STANDARD FOR FOOD SAFETY ISSUE 7 BRIEFING DOCUMENT

Overview of the key changes between Issue 6 and Issue 7
Ambient High Care (4.3.7)
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Particularly to consider risks associated with pathogens that can be present on the raw material and then re-contaminate the final
product if good controls are not in place for example chocolate, milk powder, peanut butter, dried fruit
Environment designed to minimise product contamination, production process includes a process step which removes or reduces
pathogens. Finished products are ambient stable and ready to eat or heat.
Finished products could allow vegetative pathogens to survive and grow in normal use, subsequently causing food poisoning, or are
of a nature that enables food poisoning to result from a very low level of contamination
Requires risk assessment and where risks are identified, controls such as segregation or suitable process flow
Decision trees and detailed guidance to assist definition of risk areas are included in the standard

Customer Focus and Communication (3.12)

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New section with 2 new requirements

Implementation of customer specific policies and codes of practice
Ensuring sub-contractors and / or suppliers are aware of or adhere to customer policies where applicable.

Managing Surplus Food and Products for Animal Feed (4.13)

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New requirements ensuring brand owners prior consent for disposal of labelled product. Ensuring products are fit for consumption
and controls are in place for food going to animal feed.

Housekeeping and Hygiene (4.11)

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One new clause and one updated

Premises and equipment to be maintained in a clean and hygienic condition
Limits of acceptable and unacceptable cleaning performance to be implemented and consideration of cleaning chemical residues

Pest Control (4.14)

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2 new clauses recording and managing pest activity, and employees responsibility to report any pest activity seen
Non conformities will be raised where the presence of pest activity presents a risk of product contamination or where pest activity is
identifies which does not represent a risk of contamination but has not been identified in the pest control records or being treated

Clarification on purpose and frequency of in-depth survey minimum annually. In-depth review for activity, review of existing pest
control measures

Further Information:
The standard is FREE to download and print from the BRC website. A subscription service is available BRC Participate enabling access to all
standards and supporting documents online at a cost of 95

Training:
Training Courses Available from your NSF Certification UK Ltd audit provider:
Introduction to the Standard 1 day
Implementing the Standard 2 days
Conversion for Manufacturers (Issue 6 to Issue 7) 1 day
Understanding the Requirements 2 days
Auditor Skills 1 day
Third Party Auditor 5 days