BRCGS V8 expects you to risk-assess products and processes at the NPD stage, with a tie-in with the HACCP plan…
Clause 5.1.1 states:
“The company shall provide clear guidelines on any restrictions to the scope of new product developments to control the introduction of hazards which would be unacceptable to the site or customers (e.g. the introduction of allergens, glass packaging or microbiological risks).”
Clause 5.1.2 states:
“All new products and changes to product formulation, packaging or methods of processing shall be formally approved by the HACCP team leader or authorised HACCP committee member. This shall ensure that hazards have been assessed and suitable controls, identified through the HACCP system, are implemented. This approval shall be granted before products are introduced into the factory environment.”
By the time you get to section 5.6, the standard simply requires that you apply the outcomes from those original risk assessments to your product inspection and testing programme.
Clause 5.6.1.1 states:
“There shall be a scheduled programme of product testing which may include microbiological, chemical, physical and organoleptic testing according to risk. The methods, frequency and specified limits shall be documented.”
Clause 5.6.1.3 states:
“The site shall ensure that a system of validation and ongoing verification of the shelf life is in place. This shall be based on risk and shall include sensory analysis and, as applicable, microbiological testing and relevant chemical factors such as pH and aw. Records and results from shelf-life tests shall verify the shelf-life period indicated on the product.”
So for finished product testing, you need to address food safety hazards such as pathogens as well as spoilage and quality factors. The upshot of all this is that if your HACCP identifies a food safety risk from pathogen viability/proliferation then you’re likely to need to use positive release as a control for every batch. Conversely, if your HACCP determines that there is no risk to consumers from pathogens, scheduled surveillance testing will be sufficient.
The rationale is majorly routed in the outcomes from your HACCP assessment. High risk products such as RTE salad or cooked meat will be subject to food safety risks in the form of pathogens, whereas a product like a plain biscuit is unlikely to need to be subject to positive release. In either case, your NPD process and HACCP assessment will determine testing requirements including microbiological species and testing frequency.