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Achieving FSMA Compliance with BRC Certification

BRC FSMA

To assist all BRC Food certificated sites BRC Global Standards commissioned The Acheson Group (TAG) to assess the BRC Global Standard for Food Safety Issue 7 against the final rule for Preventative Controls for Human Food. The results of the analysis show that certification to the BRC Global Standard for Food Safety Issue 7 is almost in complete alignment with the expectations in FSMA. Source: BRC website.

BRC Food Safety Standard was first published in 1998 and was Food Safety Standard to be benchmarked by the GFSI. The current version of the standard is Issue 7 which was published in January 2015. In Issue 7 the BRC proactively tackled two major issues in the food industry; food fraud/substitution and product labeling.

 

This was reflected in the additions to the fundamental requirements* as additional fundamental requirements in Issue 7 were clause 3.5.1 Management of suppliers of raw materials and packaging and clause 6.2 Labelling and pack control.

 

* Appendix 1 BRC Global Standard for Food Safety Issue 7 Fundamental Requirements

 

The BRC Global Standard for Food Safety is one of the most established and comprehensive food safety standards published. The standard includes requirements in 7 sections (See Appendix 2 for full list of sections/clauses):

 

1. Senior Management Commitment
2. The Food Safety Plan – HACCP
3. Food Safety and Quality Management System
4. Site Standards
5. Product Control
6. Process Control
7. Personnel

 

Due to the comprehensive nature of the BRC Global Standard for Food Safety it is no surprise that a recent study commissioned by the BRC concludes that ‘BRC Global Standard for Food Safety Issue 7 is almost in complete alignment with the expectations in FSMA’.

 

The FDA Food Safety Modernization Act (FSMA) is the most exhaustive reform of food safety laws in the US in more than 70 years. The Act was signed into law by President Obama on January 4, 2011. It primary aim is to ensure the U.S. food supply is safe by shifting the focus from responding to contamination to preventing it.

 

To assist all BRC Food certificated sites BRC Global Standards commissioned The Acheson Group (TAG) to assess the BRC Global Standard for Food Safety Issue 7 against the final rule for Preventative Controls for Human Food. The results of the analysis show that certification to the BRC Global Standard for Food Safety Issue 7 is almost in complete alignment with the expectations in FSMA. Source: BRC website.

 

FSMA BRC/TAG Report Conclusion

 

As a general observation, TAG has concluded that sites certified under the BRC Food Standard are in a very good position to meet and exceed the requirements Preventive Controls. The systems and documentation required in BRC provide a foundation of information that can be used to complete the analysis on the need for “Preventive Controls” in any operation. In some cases there will be additional documentation, verification validation required to the Preventive Control Rule, however, this should not require significant change to existing BRC based food safety programs. Source: BRC website.

 

Also note that the BRC are offering a free webinar The FSMA BRC Connection for BRC Certificated Sites

 

The webinar will define the comparison between the Global Standard for Food 7, FSMA Preventative Controls, and how the addendum for certificated sites will work, including audit timelines, protocol and site guidance in satisfying the FSMA PC requirements.

 

Appendix 1

 

BRC Global Standard for Food Safety Issue 7 fundamental requirements:

 

1.1 Senior management commitment and continual improvement
2 HACCP - Food Safety Plan
3.4 Internal Audits
3.5.1 Management of raw materials and packaging
3.7 Corrective and preventive actions
3.9 Traceability
4.3 Layout, product flow and segregation
4.11 Housekeeping and hygiene
5.3 Management of allergens
6.1 Control of operations
6.2 Labelling and pack control
7.1 Training

 

Appendix 2

 

BRC Global Standard Food Safety Issue 7 Sections/Clauses:

 

1 SENIOR MANAGEMENT COMMITMENT
1.1 Senior management commitment and continual improvement
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
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 fl ow diagram – Codex Alimentarius Step 4
2.6 Verify fl ow diagram – Codex Alimentarius Step 5
2.7 List all potential hazards associated with each process step, conduct a hazard analysis and consider any measures to control identified hazards – 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 – Codex Alimentarius Step 12, Principle 7
2.14 Review the HACCP plan

 

3 FOOD SAFETY AND QUALITY MANAGEMENT SYSTEM
3.1 Food safety and quality manual
3.2 Documentation control
3.3 Record completion and maintenance
3.4 Internal audits
3.5 Supplier and raw material approval and performance monitoring
3.6 Specifications
3.7 Corrective and preventive actions
3.8 Control of non-conforming product
3.9 Traceability
3.10 Complaint handling
3.11 Management of incidents, product withdrawal and product recall
3.12 Customer focus and communication

 

4 SITE STANDARDS
4.1 External standards
4.2 Security
4.3 Layout, product flow and segregation
4.4 Building fabric, raw material handling, preparation, processing, packing and storage areas
4.5 Utilities – water, ice, air and other gases
4.6 Equipment
4.7 Maintenance
4.8 Staff facilities
4.9 Chemical and physical product contamination control Raw material handling, preparation, processing, packing and storage areas
4.10 Foreign-body detection and removal equipment
4.11 Housekeeping and hygiene
4.12 Waste/waste disposal
4.13 Management of surplus food and products for animal feed
4.14 Pest control
4.15 Storage facilities
4.16 Dispatch and transport

 

5 PRODUCT CONTROL
5.1 Product design/development
5.2 Product labelling
5.3 Management of allergens
5.4 Product authenticity, claims and chain of custody
5.5 Product packaging
5.6 Product inspection and laboratory testing
5.7 Product release

 

6 PROCESS CONTROL
6.1 Control of operations
6.2 Labelling and pack control
6.3 Quantity – weight, volume and number control
6.4 Calibration and control of measuring and monitoring devices

 

7 PERSONNEL
7.1 Training: raw material handling, preparation, processing, packing and storage areas
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

 

Author Biography
Tony Connor, Chief Technical Advisor, IFSQN

 

Tony received an honors degree in Molecular Biology and Biochemistry from Durham University before embarking on a successful 20-year career in the UK food industry in a variety of roles including Laboratory Manager, Production Manager, Quality Assurance Manager, Technical Manager, Technical Development Manager and Group Technical Manager. Tony qualified as a Lead Audit Assessor in 1994. Since 2009 Tony has been Chief Technical Advisor to the International Food Safety & Quality Network.

 

BRC Food Safety Issue 7 Implementation Package
IFSQN offer a comprehensive documentation package suitable for Food Manufacturers looking to achieve certification to BRC Food Safety Issue 7. All document templates are fully editable to suit your process and are provided by download in standard Microsoft Office formats. Find Out More >>


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2 Comments

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HITESH KOHLI
Aug 19 2016 11:41 AM

could you please let me know about the disinfectant approved by FDA. 

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This article is a good news to all BRC7 certificated site.

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