AUGUST 2022

YOUR ENTECOM FOOD SAFETY

EBOOK SERIES GUIDE
PART 1: CHAPTER 7
BRCGS Global Standard Food
Safety Issue 9 - what’s changed?
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INTRODUCTION

BRCGS Global Standard

Food Safety Issue 9

what’s
changed?
Standards in our industry are constantly evolving. This is an industry that never sleeps, the desk
lamps are always on as food scientists and other industry experts tirelessly research, analyse, review,
collaborate, assess, and improve the standards we work with every day. For all of us that work so
intimately with food safety standards, we take a deep breath and wonder how much work the new
changes will bring. We can draw comfort that Issue 9 of the BRCGS Global Food Safety Standard will
not require a revamp of our entire food safety system, however, it does ask that we focus our attention
on strengthening the fundamental components of our food safety system to improve food safety
controls.

In this eBook we discuss:

• A summary of the key changes and how these will impact your food safety system
• identifying focus areas for improvement in your food safety system
• How to be prepared for the BRGS Issue 9 audits starting in February 2023

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BRCGS Global Standard Food Safety Issue 9 - what’s changed?

Why did the

BRCGS Global Food Safety
Issue 8 standard change?

Issue 9 continues the emphasis on management commitment, HACCP, and quality

management with a direct focus on the implementation of Good Manufacturing
Practices.

The BRCGS Global Standard Issue 9 Guide to Key Standards describes the reasons for
the changes and provides guidance and clarity on all the changes to the standards. The
main reasons for the changes as described in these guidelines are:
• To provide a better understanding of food safety culture and expand on the
requirements.
• To align with the updated Codex Principles of Food Hygiene and benchmark with
the Global Food Safety Initiative (GFSI) requirements.
• To update the audit options to include the use of Information and Communication
Technology, (ICT).
• To update requirements on fundamental food safety controls such as internal audits,
root cause analysis, preventive actions and incident management.
• To provide clarity for sites completing animal primary conversion and producing
animal feed.

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BRCGS Global Standard Food Safety Issue 9 - what’s changed?

When will companies be

audited against Issue 9 of the
Global Standard for Food
Safety?
Companies will be audited against the new Issue 9 standard from 1 February 2023. Certificates
issued against Issue 8 remain valid for the duration indicated on the certificate.

How much has

changed in Issue 9?
Although a few minor changes to the wording have been made to aid clarity, most of the
clauses have remained unchanged. Sites can focus on the key changes which are easy to
identify in the Key Changes Guidance document and will ensure that you are ready for the
Certification to Issue 9.

The BRCGS Global Standard Food Safety (Issue 9) Guide to Key Changes document has
been used a source of reference for the content of this eBook.

What are the main areas of the

standard that have changed?

The main areas are:

• Product Safety Culture
• HACCP/Food Safety Plan
• Outsourced Processing
• Emphasis on Root Cause Analysis
• Equipment
• Animal Primary Conversion
• Requirements for Traded Products
• Updating and reviewing of additional modules
• Colour-coding of audit requirements
• Changes to audit protocol

Let us discuss these areas in more detail.

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BRCGS Global Standard Food Safety Issue 9 - what’s changed?

1 Product Safety Culture

°° Requirement 1.1.2 has experienced a major revamp with an emphasis on the Food Safety
Culture plan that needs to include measures that have a positive impact on culture change
and should include activities such as:
• Clear and transparent communication on food safety.
• Training
• Employee feedback.
• Identify behaviours that are needed to maintain and improve processes impacting
product safety.
• Performance measurement of activities that impact product safety, quality, legality and
authenticity.
• An action plan as to how the above activities will be implemented and measured with
time frames for completion.
• How the activities will be reviewed at least annually to determine their effectiveness.
• The BRCGS Issue 9 Interpretation Guide describes why and how the important key
areas should be included in the food safety and quality culture plan.

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BRCGS Global Standard Food Safety Issue 9 - what’s changed?

2 HACCP/Food Safety Plan

°° Clause 2.3.2 refers to the sources of information that must be collected, maintained,
documented and updated needed for the hazard analysis and has been amended to
include additional examples of information sources such as:
• A copy of any existing HACCP plans e.g for products already produced on site.
• A map of premises and equipment layout.
• A water distribution diagram for the site.
• High care, high risk or ambient high-care production zones indicated on the map.

°° Clause 2.6 refers to the verification of the process flow diagram:

• The accuracy of the flow diagram needs to be reviewed using an on-site audit
at least annually, and whenever changes to the process occur to ensure that any
changes are incorporated into the HACCP plan promptly to manage potential
hazards effectively.

°° Clause 2.7.2 has been amended to ensure emphasis on the significant hazards (i.e
those that are reasonably expected to occur at unacceptable levels) when conducting
the hazard analysis.

°° Clause 2.7.4 (New Clause). Where specific hazards are controlled via a pre-requisite
programme or a control measure other than a critical control point (CCP), these
controls will need to be documented and their adequacy validated.

°° Clause 2.12.1 (New Clause). This

clause refers to the validation of
the HACCP Plan which reflects
the updated Codex Alimentarius
General Principles of Food
Safety for the validation of food
safety controls. This new clause
requires that any changes to
the HACCP or food safety plans
which may affect product safety
must be validated to ensure
that they effectively control
the identified hazard before
implementation.

°° Clause 2.12.3 (New Clause).

Clause 2.14.1 in Issue 8 has
become 2.12.3. The colour-coding
of the requirement is now a dual
colour-coding which means that
the review of the HACCP Plan
should include an audit of the
production facilities, GMPs on-site
as well as the system (documents
and records).

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BRCGS Global Standard Food Safety Issue 9 - what’s changed?

3 Outsourced Processing

°° Clause 3.5.4.1 Here the definition for Outsourced Processing was clarified as: “Any
intermediate process step (including production, processing or storage) in the manufacture
of a product which is outsourced to a third party or undertaken at another site, and
subsequently returned to the site”.

°° The Outsourced Process needs to be declared to the customer and, approval granted
where required.

°° Clause 3.5.4.2 The approval and monitoring process of outsourced suppliers has been
updated to reflect the GFSI requirements. The audit scope for supplier audits has been
expanded to include product security and food defence plan, and product authenticity plan.

°° Clause 3.5.4.3 The clause has been modified to emphasise the importance of identifying
and controlling any hazards that are associated with the outsourced process and including
these in the site’s HACCP Plan.

°° Clauses 3.5.4.4 (New Clause). This clause requires a formal documented service
specification, that has been agreed to with the service provider. The objective of the
specification is to ensure product safety, legality, quality and authenticity and should include
any specific product handling instructions.

°° Clause 3.5.4.5 (New Clause). The clause requires that the outsourced operation is
conducted as per the documented service specification and that product traceability is
maintained.

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BRCGS Global Standard Food Safety Issue 9 - what’s changed?

4 Corrective and
preventive actions

°° Cause 3.7.1 The clause has been expanded to elaborate on the need for a root cause
analysis with examples for when a root cause analysis is needed. The BRCGS Issue 9
Interpretation Guide provides very useful guidance.

°° Clause 3.7.2 The clause has been expanded to include the requirements for a root
cause analysis to prevent the recurrence of non-conformities and to include ongoing
improvements when trends indicate a significant increase in a type of nonconformity.
The BRCGS Issue 9 Interpretation Guide provides valuable guidance on the need for a
root analysis tool such as the 5 Whys. The BRCGS has further guidance on root cause
analysis techniques which can be found in this guide here.

°° Here the colour coding has been changed to dual colour coding requiring that the
auditor audits the site as well as the system (documents and records).

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BRCGS Global Standard Food Safety Issue 9 - what’s changed?

5 Equipment
°° Clause 4.6. The scope of the description of equipment within the statement of intent has
been clarified as all production and product handling equipment.

°° Clause 4.6.1 The clause has been expanded to include the need for a formal purchase
specification for any new equipment purchased from a manufacturer, refurbished as well
as second-hand equipment. The specification document should specify legal requirements
where relevant, suitability for food contact as well as the intended use of the equipment.

°° Clause 4.6.2. The clause focuses and elaborates on the design aspects of equipment (e.g
use of correct seals, impervious surfaces, smooth welding joins etc) which must be considered
to ensure that equipment must be designed to prevent product contamination.

°° Clause 4.6.3 (new clause). This clause requires the following:

• a documented commissioning procedure based on risk when installing new equipment on
site.
• a document hygiene clearance procedure after installation.
• an inspection of the equipment by an authorised staff member before its operation.
• That other site procedures such as training, equipment operation work instructions, master
cleaning schedules, cleaning work instructions and inspection checklists, environmental
monitoring programmes, preventive maintenance schedules etc) affected by the new
equipment are updated.

°° Clause 4.6.4 (new clause). This clause requires that

before moving any static equipment, product safety
and equipment integrity should be considered.

°° Clause 4.6.5 (new clause). The clause requires that

where equipment is not used or taken out of service
that it should be cleaned before storage and stored in
a way that does not pose a risk to the product. Where
equipment is stored in the production area is should
be kept clean and cleaned and sanitised (where
necessary) before using it again.

°° Clause 4.6.6 (new clause). This clause was introduced

to ensure that where mobile equipment such as forklifts
and pallet jacks are used in open product areas that they
do not pose a risk to product safety, and where there
is any risk, that the equipment should be cleaned and
disinfected before entering the production areas.

°° Clause 4.6.7 (new clause). This clause refers to

battery-charging equipment and requires that where
they pose a food safety risk to products they should not
be stored in open product areas unless the batteries are
fully sealed and/or maintenance-free.

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BRCGS Global Standard Food Safety Issue 9 - what’s changed?

6 Animal Primary
Conversion
°° Clause 5.9 New statement of intent which is aligned with the GFSI requirements for
animal primary conversion requires that the site operates controlled processes that
ensure that products are safe and fit for the intended use.

°° Clause 5.9.1 (new clause). Requires that sites are required to complete a risk
assessment where the country of sale or intended use has specific legislative
requirements relating to prohibited substances (e.g pharmaceuticals, veterinary
medicines, heavy metals and pesticides) to identify the risks associated with the
potential prohibited substances and that the results of the risk assessment are included
in the supplier approval and monitoring process so that the risks are managed within
the supply chain.

°° Clause 5.9.3 (new clause). This clause requires that traceability procedures are
implemented and maintained for all edible parts of the carcass.

°° Clause 5.9.4 (new clause). This clause requires defined time and temperature
requirements for chilled or frozen edible parts of the carcass for all post-slaughter
processes such as cooling, processing, storage and transport) are implemented.

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BRCGS Global Standard Food Safety Issue 9 - what’s changed?

7 Requirements for
Traded Products
°° Food Safety Plan Clause 9.1 (New
Section) requires that the site has a
HACCP plan for all processes that it is
responsible for to ensure that the hazards
are identified for the products and that the
risks are managed.

°° Clause 9.1.1 (New Clause). The

requirement for a HACCP or food safety
plan specifically for traded products
handled on site. The site can include the
traded products and processes that it
is responsible for, such as good receipt,
storage and dispatch into its existing
HACCP plan.

8 Updating and reviewing of

additional modules
°° The following additional voluntary modules have been reviewed and updated:
• Module 10: GlobalG.A.P Chain of Custody
• Module 11: Meat Supply Chain Assurance
• Module 13: Meeting FSMA requirements for Food

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BRCGS Global Standard Food Safety Issue 9 - what’s changed?

9 Colour coding of
requirements
°° Activities that are audited during the
assessment of the production areas
and facilities are colour-coded to
differentiate from those activities
that are audited as part of systems
(documentation and records).

°° The colour-coding also identifies

which clause requirements may
be audited remotely as part of a
blended audit, and which must be
audited when the auditor is on site.

10 Changes to audit protocol

°° Announced audits to include a mandatory unannounced audit every 3 years
• Updated to align with the GFSI 2020 requirements for certification sites to have one
unannounced audit every 3 years.
• The certification body will notify the site that the unannounced audit will be taking
place in the coming year, however, the actual date of the unannounced audit will not
be communicated to the site.

°° Blended announced audit programme

• This audit allows flexibility to the audit schedule.
• With this option, the audit is split into two parts, a remote audit, followed by an
on-site audit.
• The first part (remote audit) option utilises information, and communication
technology (ICT) to include a remote assessment of the documentation and records.
• The second part (the announced on-site audit part), will focus on production, storage
and other onsite areas and activities.
• More information can be found in Part III, Section 3 of the standard.

°° Unannounced audits
• The audit protocol for unannounced audits has remained largely unchanged with
the Issue 9 revision.

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BRCGS Global Standard Food Safety Issue 9 - what’s changed?

Where can I
purchase
the BRCGS Global Food
Safety Issue 9 Standard?
• Purchase the BRCGS Global Standard for Food Safety Issue 9 Guide to Key Changes
Document here.
• Access the BRCGS Global Standard for Food Safety Issue 9 standard here.
• Purchase the BRCGS Global Standard for Food Safety Issue 9 Interpretation
Guideline here.

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HOW CAN WE HELP YOU

HOW CAN
ENTECOM HELP
YOU?
We have the following training courses
to help your company align with the
BRCGS Global Food Safety Issue 9
requirements:

• BRCGS Global Food Safety Issue 8

to Issue 9 Bridging course.
• BRCGS Global Food Safety Issue 9
Implementation Course.
• Food Safety Culture for
management.
• Root cause analysis workshop.
• Digital Compliance software to
help you manage your BRCGS Food
Safety System with ease.

Contact us on [email protected] or (041) 3661970 for more information.

We love hearing from you and look forward to taking your call.

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