I have just started to review it and, well, my 1st impression is that (on this side of the pond) it will be a large blow to food brokers in the Americas if the retail market begins to drive this certification requirement from food brokers (i.e. – clause 2.1 “The person responsible for leading the hazard analysis shall be able to demonstrate competence in the understanding of HACCP principles and their application…”). I do not believe that many food brokers over here know much about HACCP… but I could be wrong...
After reading a bit more, I think this standard is a bit much (from my perhaps limited understanding of what constitutes an “Agent” or “Broker”).
So rewind a bit, Question: Are food Agents and Brokers a vector to food safety risk in the global food supply chain?
In some instances I can see this as they come up as an a bit of a hurdle in a food manufacturer’s Supplier Approval Program (i.e. – trouble getting verification documents from the broker as to the integrity of food they are the middle man for), but in others all food safety requirements are handled by the other parties. I think the former is why this issue has been drafted… as well as a few that occur to me offhand:
- Newer concerns with cold supply chain management (farm/field to fork)
- FDA’s new FSMA food import legislation
- Fraud (i.e. – horse meat scandal in the UK)
- I am sure there are more…
But I would think that BRC’s Storage and Distribution standard sufficiently captures all links from manufacturer to retailer in the supply chain and associated risks…
These next 2 clauses gives you a picture of where BRC is intending to go with this:
2.5 “A process flow diagram shall be prepared to cover each step in the process from the purchase of products to acceptance of the products by the company’s customer. As a guide this should include the following where applicable:
Product and supplier approval
product checks or testing
Sub contracted transport or distribution
Sub contracted storage of products
Processes for damaged or rejected product
Any subcontracted processes undertaken on products e.g., relabeling, further processing”
2.6 “The company shall identify and record all potential hazards associated with each step of the product flow. The company shall include consideration to the following types of hazard:
... microbiological growth resulting from temperature abuse of products that require temperature control
physical contamination (e.g. glass contamination, wood splinters from pallets, dust, pests)
chemical contamination (e.g. pesticide, heavy metals, PCB’s product tainting)
physical damage (e.g. breakage, puncturing of packaging, water damage)
Fraud e.g substitution or deliberate adulteration,
Malicious contamination of products
any other hazards mandated by the customer or relevant regulatory authorities”
The rest of the draft for BRC’s Standard for Agents and Brokers gets much deeper… and I have other issues with it, but here is a start.