Apologies it was a tough night, my son was ill.
Do you mean BRC proposals for v8? I've not seen any yet but I have to admit to frustration on v7 when the BRC had spent years considering horsegate, then came out with something very vague and wishy washy. This ended up with no-one having a clue how to implement it as it was possible to comply in so many ways. As a result, each UK retailer apart from one has now come out with their own ways of doing it. Each business to business customer has now come out with their own ways of doing it. The lack of consistency has created a massive workload in the supply chain with us all trying to do something "standard" that we can send to everyone but then those standard documents being rejected because of the different approaches. There was a chance for BRC to lead in this and they missed it. It's probably too late now.
What I was meaning by my comment is that unlike in other areas, the BRC are massively behind the curve at least with UK retailers and if you don't supply out of the UK you may not realise this. UK retailers (with the exception of one who seem quiet) see this as being a very serious problem which could massively impact their reputation and some are extending the requirements to authenticity to account for accidental substitution.
My point was, there is no way this is going away whatever the BRC does and if it doesn't lead in this area, it's only going to cause more cost and pain in the supply chain. I've also found many of the courses which sprung up to help comply with this requirement have been a waste of time but I've not tried any IFSQN have done. As a result, again, UK retailers have then felt like they need to fill the gap but even then there are weaknesses. I personally feel the M&S course is brilliant from what I've seen but it is weaker on food defence and security but how can you support your claim of being trained in vulnerability, authenticity and threat assessments when you're being audited by Asda if the course was delivered by M&S? The alternative is I go on every retailer course of every customer I supply. So that's about £5k down the drain.
My frustration is the lack of overarching body leading in this area to give everyone a clearer idea and I think BRC has a massive chance to be that body as no-one else is doing it.
Hi GMO,
Sorry about the illness, IMEX such events can be nerve-wracking for all parties, particularly the sufferer of course.
Thanks for yr very informative Post.
Of course, the Horsegate event was a painful demonstration of how (legally?) accurate Traceability could (can?) be circumvented in order to assist Economic Fraud so it certainly makes sense to treat it seriously and implement more rigorous control measures. Nonetheless it is debatable (just like Quantity Control ?) whether (some) specifically non-safety Fraud issues should be included in a self-titled FOOD SAFETY STANDARD (IIRC the GFSI-related literature justifies all-inclusion by virtue of the occurrence of documented cases where safety issues were an additional consequence, even if not initially intentioned, eg Melamine). This scope of inclusion inevitably IMO overlaps the BRC Standard also being driven by the UK’s (legal) support for the concept of Due Diligence, plus GFSI’s recent inclusion of their “Fraud” as (I presume) a benchmarkable characteristic. I am unaware of how common the “Due Diligence” defence is found outside UK but it never seems to be elsewhere mentioned in this Forum (?) (not criticizing, just speculating).
Sadly, I cannot recall ever seeing one of the “Retailer Courses” for VA you mention being exampled/discussed here previously or on the Net so unable to usefully comment. I would much like to see one.
By “proposed on the Forum” I meant the maybe 3-4 BRC-specific templates devised/posted on this forum by members for BRC7. From what I have seen, these range across a spectrum of, conceptually, very simple to the exact opposite. Based on absence of contrary reports on this Forum to any of these methodologies (and others), BRC seem to have so far been OK with all offered responses. This may have been due to the relative newness of the subject from a BRC7 POV plus GFSI (and others) have themselves been discussing as to preferred ways to go forward (apparently now concluded). One obvious current bugbear is the disappearance of, afaik, the most popular database source of historical Fraud data, USP, from the freely accessible scene. IIRC most of the references mentioned in BRC’s own Vulnerability I. Guidelines were of marginal assistance when I last checked.
As a (maybe) interesting difference to BRC7, SQF have apparently excluded NON-safety related Economic Fraud In their Manufacturing 8 FS Standard. I assume that the SQF organization are confident that the Standard remains compliant to GFSI.
