Well, I did a quick boil-down... I may have missed some things but here is the suggested/proposed changes in the DRAFT version (without public comment input) to BRC Issue 8.
Comment input deadline 31 December 2017: http://ow.ly/ekYY30gM7kB
1.1 SENIOR MANAGEMENT COMMITMENT AND CONTINUAL IMPROVEMENT
"add site’s senior management requirement to provide a documented strategic plan for the development and continuing improvement of food safety culture with prescriptions to include:
• defined activities involving all sections of the company
• an action plan indicating how the activities will be undertaken and intended timescales
• review of the effectiveness of completed activities"
add required involvement of SM with MR process to understand the underlying reasons for the failure and setting future objectives to facilitate continual improvement.
add requirement for employee awareness/involvement to meeting programs.
add requirement for protected feedback for employees (eg a whistleblower system) to SM and a process to assess/document any concerns raised.
add required responsibility of the company to comply with the relevant sections of the Standard protocol.
add BRC Logo use prescriptions.
1.2 ORGANISATIONAL STRUCTURE, RESPONSIBILITIES AND MANAGEMENT AUTHORITY
2 THE FOOD SAFETY PLAN – HACCP
2.1 THE HACCP FOOD SAFETY TEAM – CODEX ALIMENTARIUS STEP 1
remove Codex Alimentarius References
add requirement for "legal requirement for specific training"
2.2 PREREQUISITE PROGRAMMES
2.3 DESCRIBE THE PRODUCT – CODEX ALIMENTARIUS STEP 2
2.4 IDENTIFY INTENDED USE – CODEX ALIMENTARIUS STEP 3
2.5 CONSTRUCT A PROCESS FLOW DIAGRAM – CODEX ALIMENTARIUS STEP 4
2.6 VERIFY FLOW DIAGRAM – CODEX ALIMENTARIUS STEP 5
2.7 LIST ALL POTENTIAL HAZARDS ASSOCIATED WITH EACH PROCESS STEP, CONDUCT A HAZARD ANALYSIS – CODEX ALIMENTARIUS STEP 6, PRINCIPLE 1
2.8 DETERMINE THE CRITICAL CONTROL POINTS (CCPs) – CODEX ALIMENTARIUS STEP 7, PRINCIPLE 2
2.9 ESTABLISH CRITICAL LIMITS FOR EACH CCP – CODEX ALIMENTARIUS STEP 8, PRINCIPLE 3
2.10 ESTABLISH A MONITORING SYSTEM FOR EACH CCP – CODEX ALIMENTARIUS STEP 9, PRINCIPLE 4
2.11 ESTABLISH A CORRECTIVE ACTION PLAN – CODEX ALIMENTARIUS STEP 10, PRINCIPLE 5
2.12 ESTABLISH VERIFICATION PROCEDURES – CODEX ALIMENTARIUS STEP 11, PRINCIPLE 6
2.13 HACCP DOCUMENTATION AND RECORD KEEPING – CODEXALIMENTARIUS STEP 12, PRINCIPLE 7
2.14 REVIEW THE HACCP PLAN
add HACCP review requirement to include "other relevant, published information (i.e. - a recall of a similar product)" to prompt review.
3 FOOD SAFETY AND QUALITY MANAGEMENT SYSTEM
3.1 FOOD SAFETY AND QUALITY MANUAL
3.2 DOCUMENTATION CONTROL
include digital document system security.
3.3 RECORD COMPLETION AND MAINTENANCE
include digital document system security.
3.4 INTERNAL AUDITS (Change section title from "Internal Audits" TO "Food safety and quality management audits")
add minimum requirements for audit programme to include at least 4 different audit dates spread throughout the year with scopes defined with all sections covered in its entirety annually.
add requirement for Internal Audits to "include objective evidence of the findings."
3.5 SUPPLIER AND RAW MATERIAL APPROVAL AND PERFORMANCE MONITORING
3.5.1 MANAGEMENT OF SUPPLIERS OF RAW MATERIALS AND PACKAGING
add raw material review requirement for "variety or species cross-contamination" as part of RA.
add required drill down/focus for RA on prohibited substances with raw materials review.
add requirement to review raw material every 3 years with HACCP style review prompting.
"add GFSI Benchmark standards (not just BRC) for approval process.
Streamlining 2nd or 3rd party audits: add requirement for auditor credentials/competency, scope in product safety, traceability, HACCP review and GMPs, full report."
add requirement for Low Risk Suppliers on questionnaire: prescriptive scope (product safety, traceability, HACCP review and GMPs) with evidence of review.
Supplier Approval Crunch: add requirement to have (and fully implemented) a documented Process for ongoing review and monitoring for suppliers based on risk and using defined performance criteria.
add required list of approved Suppliers readily available to relevant staff (eg at goods receipt)
add prescription to verify Supplier Traceability
3.5.2 RAW MATERIAL AND PACKAGING ACCEPTANCE AND MONITORING PROCEDURES
add "approved changes to raw materials" be communicated to goods receipt personnel.
add prescriptive live Animal Receipt inspection.
3.5.3 MANAGEMENT OF SUPPLIERS OF SERVICES
Expand "Services" definition to "off-site packing of products" & " food safety consultants"
"add prescriptive RA for additional Services of off-site packing of products & food safety consultants.
add Services RA prescriptions to be based on:
• risk to the safety and quality of products
• compliance with any specific legal requirements
• potential risks to the security of the product (ie risks identified in the vulnerability and food defense assessments)."
3.5.4 MANAGEMENT OF OUTSOURCED PROCESSING AND PACKING (expand to Subcontractors)
add a requirement for GFSI benchmark standards in approval process for subcontractors or outsourcing.
add "frequency and methods of inspection or testing" from subcontractors or outsourcing be dependent on risk assessment .
3.6 SPECIFICATIONS
for "accurate, up-to-date finished product specifications", add aknolement of electronic systems management.
removed 3 year Spec review requirements, to "sufficiently frequent to ensure data is current".
3.7 CORRECTIVE AND PREVENTIVE ACTIONS
3.8 CONTROL OF NON-CONFORMING PRODUCT
add prescriptive "root cause analysis and implementing ongoing improvements, to avoid recurrence" to documented procedures.
3.9 TRACEABILITY
add Traceability procedure prescriptions: how the traceability system works & the labelling and records required.
add requirement for Trace document linkage explanation for withdrawal and recall procedure.
3.11 MANAGEMENT OF INCIDENTS, PRODUCT WITHDRAWAL AND PRODUCT RECALL
add Digital/Data security
add planning prescriptions for withdrawal and recall procedure
3.12 CUSTOMER FOCUS AND COMMUNICATION
added customer "communication" sub-section in Issue7, suggested removal for Issue 8
4 SITE STANDARDS
4.1 EXTERNAL STANDARDS
4.2 SECURITY (add "food defense")
add internal and external threats to Food Defense RA
add requirement for a Raw Material "Food Defense" RA
General "authorized personnel" area control assessment/measures to be changed to a required "Food Defense" RA to "defined, monitored and control" those risks & change visitor "reporting" to visitor "monitoring" system.
add requirement for "secured to prevent unauthorized access" to external storage tanks, silos and any intake pipes with an external opening" security.
4.3 LAYOUT, PRODUCT FLOW AND SEGREGATION
move Hight Risk/Care fabrication requirements to new section 8
4.4 BUILDING FABRIC, RAW MATERIAL HANDLING, PREPARATION, PROCESSING, PACKING AND STORAGE AREAS
add elevated walkway design prescriptions
add requirement for "internal and external" and "shall" to door maintenance.
4.5 UTILITIES – WATER, ICE, AIR AND OTHER GASES
4.6 EQUIPMENT
4.7 MAINTENANCE
add requirement authorized personnel confirmation for acceptance of Equipment and machinery back into operation to a documented hygiene clearance procedure.
add requirement of "appropriate grade or quality" to equipment materials and parts composition.
4.8 STAFF FACILITIES
add requirement for vending machines to "suitably controlled to prevent contamination of products"
4.9 CHEMICAL AND PHYSICAL PRODUCT CONTAMINATION CONTROL RAW MATERIAL HANDLING, PREPARATION, PROCESSING, PACKING AND STORAGE AREAS
4.9.1 CHEMICAL CONTROL
4.9.2 METAL CONTROL
4.9.3 GLASS, BRITTLE PLASTIC, CERAMICS AND SIMILAR MATERIALS
add requirement staff training & mechanisms for the safe disposal of contaminated product with glass/brittle items breakage procedures.
4.9.4 PRODUCTS PACKED INTO GLASS OR OTHER BRITTLE CONTAINERS
4.9.5 WOOD
"add new sub-section ""Other physical contaminants""
add requirement for documented procedures to be in place for the removal of packaging from raw materials (eg debagging or deboxing procedures) to prevent contamination of the raw material during these processes.
add requirements for pens used in open product areas being controlled to minimize risk of physical contamination."
4.10 FOREIGN-BODY DETECTION AND REMOVAL EQUIPMENT
4.10.1 FOREIGN-BODY DETECTION AND REMOVAL EQUIPMENT
4.10.2 FILTERS AND SIEVES
Remove requirement to "examined and recorded to identify contamination risks" of filter/sieve controls.
4.10.3 METAL DETECTORS AND X-RAY EQUIPMENT
add requirement FB testing of in-line metal detectors to be completed during line start up and at the end of the production period.
4.10.4 MAGNETS
4.10.5 OPTICAL SORTING EQUIPMENT
4.10.6 CONTAINER CLEANLINESS – GLASS JARS, CANS AND OTHER RIGID CONTAINERS
4.11 HOUSEKEEPING AND HYGIENE
add requirement for a defined corrective action to be taken when monitored results are outside of cleaning performance acceptable limits.
4.11.7 CLEANING IN PLACE (CIP)
"remove more granular prescriptive CIP requirements and consolidate CIP section clauses.
add required CIP design and construction validation, schematic diagram, cross-contamination RA for recovered rinse solutions, authorized approval and record before changes are made, and revalidated at a frequency based on risk, and following any alteration or addition."
for CIP system critical limit & validation: add requirement for documented times, detergent concentrations, flow rate/pressure and temperatures parameters for target hazards removal.
add required CIP equipment maintenance staff training
add requirement for CIP facilities to monitor at a defined and documented frequency based on risk.
add required procedures defining action to be taken if monitoring indicates that processing is outside defined limits.
4.12 WASTE/WASTE DISPOSAL (add Environmental monitoring sub-section)
include "Internal" external waste collection containers requirements.
"add requirement for a documented environmental monitoring programme based on prescriptive risk criteria:
• sampling protocol
• identification of sample locations
• frequency of tests
• target organism(s)
• test methods (eg settle plates, rapid testing, swabs)
• recording and evaluation of results"
add requirement for appropriate & defined control limits with document the corrective actions there is a failure to meet a control limit, or they indicate a trend of increasing positive environmental results.
add requirement for the company to review environmental monitoring programme at least annually and with prescriptive review requirements
4.13 MANAGEMENT OF SURPLUS FOOD AND PRODUCTS FOR ANIMAL FEED
4.14 PEST CONTROL
add requirement for pest control risk assessment to be reviewed whenever there are changes to the building or production processes.
remove required numbering for pest control devices .
add requirement for adequate measures to prevent birds from entering buildings or roosting above loading or unloading areas.
4.15 STORAGE FACILITIES
4.16 DISPATCH AND TRANSPORT
5 PRODUCT CONTROL
5.1 PRODUCT DESIGN/DEVELOPMENT
add refined criteria for Shelf Life testing.
add requirement to ensure pet food is formulated/designed for the intended use
add requirement for pet food products for multiple, different animal species to have specific procedures for the management of any ingredient, raw material, product or rework that can be harmful to unintended recipients.
"add requirement for pet food that contain medicinal substances to include:
• identification of medication-containing materials handled on site.
• mechanisms to ensure correct concentrations of medicinal substances in finished products
• procedures to prevent cross-contamination with materials containing medicinal substances
• specific procedures to ensure the correct labelling of medicated pet food"
5.2 PRODUCT LABELLING
add requirement to provided fully validated cooking instructions.
5.3 MANAGEMENT OF ALLERGENS
add allergen risk-based assessment requirement to justify were allergen cannot be prevented and to include an allergen warning on the product label.
5.4 PRODUCT AUTHENTICITY, CLAIMS AND CHAIN OF CUSTODY
5.5 PRODUCT PACKAGING
"add required prescription to manage obsolete packaging (including labels):
• mechanisms to prevent accidental use of obsolete packaging
• timely disposal of obsolete packaging
• appropriate procedures for the disposal of obsolete printed materials"
5.6 PRODUCT INSPECTION AND LABORATORY TESTING
5.6.1 PRODUCT INSPECTION AND TESTING
add the requirement for ongoing validation of the product shelf-life
5.6.2 LABORATORY TESTING
add requirement for the significance of laboratory results be understood and acted upon accordingly & trended.
add requirement for legal limits to be understood/appropriate action implemented to address any exceedance of these limits.
5.7 PRODUCT RELEASE
6 PROCESS CONTROL
6.1 CONTROL OF OPERATIONS
6.2 LABELLING AND PACK CONTROL
add requirement for off-line coding or printing of packaging materials setting/amendments to the printer parameters be set only by an authorized person.
"add requirement for on-line verification equipment to have a documented procedures for the operation and testing of the equipment with prescriptive testing criteria:
• at the start of the packing run
• during the packing run
• when changing batches of packaging materials
• at the end of each production run. "
6.3 QUANTITY – WEIGHT, VOLUME AND NUMBER CONTROL
"add requirement for documented procedures for the operation and testing of online check weighers with prescriptive testing criteria:
• consideration of any legal requirements
• responsibilities for testing the equipment
• operating effectiveness and any variation to this for particular products
• the methods and frequency of testing the check weigher
• recording of the results of tests"
6.4 CALIBRATION AND CONTROL OF MEASURING AND MONITORING DEVICES
7 PERSONNEL
7.1 TRAINING: RAW MATERIAL HANDLING, PREPARATION, PROCESSING, PACKING AND STORAGE AREAS
add requirement for an additional training record requirement of the material, work instruction or procedure that is used in the training.
7.2 PERSONAL HYGIENE: RAW MATERIAL HANDLING, PREPARATION, PROCESSING, PACKING AND STORAGE AREAS
7.3 MEDICAL SCREENING
7.4 PROTECTIVE CLOTHING: EMPLOYEES OR VISITORS TO PRODUCTION AREAS
New section for consolidated High Risk, High Care and Ambient High Care Requirements
"8 High Risk, High Care and Ambient High Care Production Risk Zones
(New section for consolidated High Risk, High Care and Ambient High Care Requirements)"
8.1 Layout, Product Flow and Segregation in High Risk, High Care & Ambient High Care
8.1.1 (formerly 4.3.1)
8.1.2 (formerly 4.3.5)
8.1.3 (formerly 4.3.6)
8.1.4 (formerly 4.3.7)
8.2 Building Fabric in High Risk, High Care & Ambient High Care
8.2.1 (formerly 4.4.4)
8.2.2 (formerly 4.4.13)
8.3 Maintenance in High Risk, High Care & Ambient High Care
8.3.1 (formerly 4.7.5)
8.3.2 add maintenance requirement for when equipment is removed from the area, a documented procedure to ensure the cleanliness and removal of contamination hazards, before being accepted back into the area.
"8.3.3 add maintenance requirement for when portable equipment (eg handheld devices) is used in high risk or high care:
• items shall be visually distinctive and dedicated for use in that area
OR
• there shall be specific procedures (eg a full clean) to ensure this does not result in contamination."
8.4 Staff Facilities for High Rick, High Care & Ambient High Care
8.4.1 (formerly 4.8.4 and 4.8.5)
8.5 Housekeeping and hygiene in high risk, high care & ambient high care
8.5.1 (formerly 4.11.2)
8.5.2 (formerly 4.11.3)
8.5.3 (formerly 4.11.6)
8.5.4 add housekeeping requirement for CIP systems used for cleaning high risk or high care areas be dedicated for use in that area and separate from those used in low risk areas.
8.6 Waste/Waste Disposal in High Risk, High Care & Ambient High Care
8.6.1 add Waste Disposal requirement for waste disposal systems ensuring the risk of contamination to products is minimized through the control of potential cross-contamination & risk assessment be consider the movement and flow of waste and waste containers.
8.7 Protective Clothing in High Risk, High Care & Ambient High Care
8.7.1 (formerly 7.4.3)
8.7.2 (formerly 7.4.4)
8.7.3 (formerly 7.4.5)
"9 Requirements of the traded goods
Where a site purchases and sells food products, that are stored in the site’s facilities, that would normally fall within the scope of the Standard, but which are not manufactured, further processed or repacked at the site being audited, the site’s management of these products may be incorporated into the audit scope using the section 9 (Traded Goods).
Where the company applies for certification of the management of traded goods, all relevant requirements from the core Standard (sections 1 to 8) must also be fulfilled in addition to the requirements outlined in this section."
9.1 Approval and performance monitoring of manufacturers/packers of traded food products
9.1.1
9.1.2
9.1.3
9.1.4
9.2 Specifications
9.2.1
9.2.2
9.2.3
9.2.4
9.3 Product inspection and laboratory testing
9.3.1
9.3.2
9.3.3
9.3.4
9.3.5
9.4 Product legality
9.4.1
9.5 Traceability
9.5.1
9.5.2
9.5.3