BRCGS Food Safety: Issue 9 through the eyes of an auditor

In May 2021, consultation and research started for Issue 9 of the BRCGS global Food Safety standard. By August 2022, the standard was published with audits starting February 2023. In a recent survey, 61% of organizations reported that they were not fully prepared for the new issue and would benefit from some extra training. 21% of organizations admitted that they were not prepared at all and needed some guidance.

The main changes at a glance

According to the BRCGS, 80% of organizations with the standard claim certification improved the production and distribution of safe food. BSI is here to help make sure that you are familiar with the new clauses in Issue 9 to best prepare you for audits, ensuring your organization produces and distributes safe food.

Read on to familiarize yourself with the 8 main changes between Issue 8 and Issue 9 of the Food Safety Standard.

Blended audit and unannounced audit

A blended audit has to be announced. It consists of a remote/paper-based audit and an on-site verification. Unannounced audits will occur once in a three-year cycle for those who selected the 'Announced' options – They will have 10 black-out days option and usually will be four months before the audit window.

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Emphasis on Food safety culture - Clause 1

This clause dives deep into the food safety culture of the organization - how are staff trained on Food safety? Are they aware of the objectives? The senior leadership team of an organization needs to provide evidence of their; policy, plans, objectives, and legal and regulatory requirements around their iterative process of embedding a food safety culture. The auditor will check the food safety culture's strengths and weaknesses and verify the actions as well to ensure effectiveness.

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Updates on HACCP validation - Clause 2

The latest publication of the Codex Alimentarius HACCP principles influenced the update of several clauses including the validation of the HACCP or Food Safety Plan. Cosmetic changes have also been introduced, such as 'authenticity' to replace 'integrity', 'disinfection' to replace 'sanitation', and 'shall' to replace must'. Specific food safety hazards must be validated.

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Supplier approval for outsourced processes - Clause 3

As food fraud and food defence are improving, the criminal mind is changing its ways to infiltrate the food industry. Because of this, clause three places great importance on authenticating suppliers as part of the approval process. Whether your suppliers are GSFI-approved or self-audited, it is important to check and document what authenticity, food defence, and food fraud checks your suppliers have. Clause three also focuses on traceability checks and the monitoring of suppliers and outsourced processes. Specifically, mass balance is to be conducted on printed packaging and labels.

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Internal audit and root cause analysis - Clause 3

Root cause analysis is a strong focus in this updated standard, due to the number of recalls, withdrawals and repeat non-conformances. An internal audit should be used to ensure that those repeats are not happening anymore. Clause three highlights that an internal audit should demonstrate you have food safety, authenticity, and legality and quality audits. In case of an actual recall/ withdrawal – information/investigation is to be sent to the certification body in 21 days.

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Food defence and security - Clauses 4 and 5

The food defence and food fraud, TACCP and VACCP, have aligned very similarly to the same clause, names, and numbers. So that's why different security is very important from the point of view of GFSI, so much so, Interpol has also been involved in food defence and food frauds.

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Equipment - Clause 4.6

Clause 4.6 of Issue 9 of the BRCGS Food Safety Standard places a lot of stress on new and existing machinery including their implementation, factory approval, and acceptance tests. The new clause emphasizes risk-based assessments, documentation and procedure of machinery and equipment.

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Animal Primary Conversion - Clause 5.9

Originally part of a position statement in Issue 8, this clause has now been added in this most recent version of the standard to reflect the new GFSI benchmark and to ensure that food remains safe, authentic and legal during animal primary conversion. Clause 5.8 – Pet Food and animal feed clause is a completely new clause for this standard that ensures that any food waste going out or produced by the organization for consumption to pet or animal feed needs to be completely food safe.

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To deep dive into each of the clauses, and other main changes, in more detail, watch our on-demand webinar where, Anirvan Sen, UKI Food Operations Manager and Auditor, BSI, shares his expertise on the new clauses laid out in Issue 9 from an auditor’s perspective.