Catch Up Time as GFSI Release GFSI Benchmarking Requirements GFSI Guidance Document Version 7 Updated April 2018
GFSI Version 7
With the recent release of the GFSI Benchmarking Requirements GFSI Guidance Document Version 7 I thought it would be a good time to follow up on one of my previous blogs – GFSI Chicken or BRC Egg…which came first?
So, what are the changes? The previous GFSI Benchmarking Requirements GFSI Guidance Document Sixth Edition Version 6.4 was a single document with 4 parts:
Part I: The Benchmarking Process
Part II: Requirements for the Management of Schemes
Part III: The Technical Equivalence Process for Government Owned Certification Schemes
Part IV: Scheme Scope and Key Elements
Part IV: Glossary of Terms
The GFSI Benchmarking Requirements GFSI Guidance Document Version 7 has been published as a series of documents including:
PART I The Benchmarking Process
PART II Requirements for the Management of Schemes
PART III Scheme Scope and Key Elements*
PART IV Glossary of Terms
Process Manual for the GFSI Benchmarking Process V7
The Technical Equivalence Process for Government Owned Certification Schemes
So, focusing on Part III, for V7 GFSI has published a separate Part III for each GFSI scope of recognition. The third Part of the GFSI Benchmarking Requirements defines the requirements for:
- the food safety management systems to be in place in the scheme’s standard for the relevant GFSI scope of recognition
- the Good Practice requirements to be in place in the scheme’s standard for the relevant GFSI scope of recognition
- the requirements for HACCP or HACCP based requirements to be in place in the scheme’s standard for the relevant GFSI scope of recognition
PART III - AI Farming of Animals
PART III - AII Farming of Fish
PART III - BI Farming of Plants
PART III - BII Farming of Grains and Pulses
PART III - C Animal Conversion
PART III - D Pre-Processing Handling of Plant Products
PART III - EI Processing of Animal Perishable Products
PART III - EII Processing of Plant Perishable Products
PART III - EIII Processing of Animal and Plant Perishable Products (Mixed Products)
PART III - EIV Processing of Ambient Stable Products
PART III - F Production of Feed
PART III - J Provision of Storage and Distribution Services
PART III - L Production of Bio Chemicals
PART III - M Production of Food Packaging
PART III - N Food Broker/Agent
Having a separate Part III for every scope of recognition makes the Guidance Document more straightforward and far less confusing and is a big plus in my opinion.
So, looking at Part III and the food safety management systems, good practices and HACCP or HACCP based requirements to be in place in the scheme’s standard for the relevant GFSI scope of recognition what are the changes from Version 6.4 to Version 7?
Taking PART III - EIII Processing of Animal and Plant Perishable Products (Mixed Products) as an example firstly there has been a reordering of how the requirements are laid out:
SECTION 1: HACCP or Hazard Based Requirements
SECTION 2: Food Safety Management Requirements
SECTION 3: Good Industry Sector Practice Requirements (Good Manufacturing Practice Requirements)
The numbering in each section is similar, here is a summary of the changes for each section for PART III - EIII Processing of Animal and Plant Perishable Products (Mixed Products):
SECTION 1: HACCP or Hazard Based Requirements is now in 4 parts HACCP EIII 1.1 - 1.4
There is similar wording except In all cases, the 7 Codex Alimentarius HACCP principles and the 12 step logic sequence for application of HACCP specified in the document, Recommended International Code of Practice – General Principles of Food Hygiene CAC/ RCP 1-1969, Rev. 4 -2003, shall apply has been removed and or those principles specified by the National Advisory Committee on Microbiological Criteria for Foods (NACMCF) has been removed.
There are still similar requirements that the standard shall require that the HACCP system shall be systematic, comprehensive and thorough and shall be based on the Codex Alimentarius HACCP principles, be capable of accommodating change and that the scope of the HACCP system shall be required to be defined.
SECTION 2: Food Safety Management Requirements here is a summary of my observations:
Food safety management general requirements - Additional requirement f) include a procedure for verification of the food safety management system to confirm that the system continues to be effective.
Food safety policy - Similar/Same
Food safety manual - Similar/Same
Management responsibility - Removed requirement for reporting relationships
Management commitment - Similar/Same
Management review - Split in 2 parts FSM EIII 6.1/6.2 Slight change Similar wording
Resource management - Additional wording the qualified resources (including suitably qualified personnel)
General documentation requirements - Split in 3 parts FSM EIII 8.1/8.2/8.3 Similar wording
Specified requirements - Split in 2 parts FSM EIII 9.1/9.2 Similar wording
Procedures - Added requirement for documented procedures
Internal audit - Reworded: require that the organisation has an internal audit system in place to cover all activities within the scope of the scheme. Removed to cover the scope of the food safety system, including the HACCP Plan or the HACCP based plan.
Corrective action - Similar/Same
Control of non conformity - Split in 2 parts FSM EIII 13.1/13.2 Similar wording
Product release - Similar/Same
Purchasing - Split in 3 parts FSM EIII 15.1/15.2/15.3 Similar wording except:
15.3 Reworded such that the standard shall require that control of such outsourced processes that may have an effect on food safety
Supplier performance - Similar/Same
From V6.4 FSM 17 Outsourcing removed, requirements are in FSM EIII 15.2/15.3
Complaint handling - Renumbered Similar/Same
Serious incident management - Renumbered Similar/Same
Control of measuring and monitoring devices - Renumbered Similar/Same 3 parts
Food defence threat assessment - Renumbered & Reworded FSM EIII 20.1 The standard shall require that the organisation have a documented food defence threat assessment procedure in place to identify potential threats and prioritise food defence measures.
Food defence plan - New Requirement FSM EIII 20.2 The standard shall require that the organisation has a documented plan in place that specifies the measures the organisation has implemented to mitigate the public health risks from any identified food defence threats.
Food defence plan - Reworded FSM EIII 20.3 The standard shall require that the organization's Food defence plan shall be supported by the organisation’s Food Safety Management System.
Food fraud vulnerability assessment - New Requirement FSM EIII 21 The standard shall require that the organisation has a documented food fraud vulnerability assessment procedure in place to identify potential vulnerability and prioritise food fraud mitigation measures.
Food fraud mitigation plan - New Requirement FSM EIII 22.1 The standard shall require that the organisation has a documented plan in place that specifies the measures the organisation has implemented to mitigate the public health risks from the identified food fraud vulnerabilities.
Food fraud mitigation plan - New Requirement FSM EIII 22.2 The standard shall require that the organization's Food fraud mitigation plan shall be supported by the organisation’s Food Safety Management System.
Traceability - In 3 parts 23.1, 23.2 & 23.3 Similar wording
Analysis of Inputs (e.g. water, ice) - Slight Rewording inputs critical to the confirmation of
product food safety
Product Labelling - Renumbered & Reworded FSM EIII 25 The standard shall ensure that finished product is labelled according to the applicable food regulations in the country of intended sale
Allergen Management - New Requirement FSM EIII 26 The standard shall require that an allergen management plan is in place in all food manufacturing facilities. This shall include a risk assessment of allergen cross contact and implemented controls to reduce or eliminate the risk of cross contact.
Allergen Labelling - New Requirement FSM EIII 27 The standard shall require that all finished products intentionally or potentially containing allergenic materials are labelled according to the allergen labelling regulations in the country of manufacture and the country of destination.
Environmental Monitoring - New Requirement FSM EIII 28 The standard shall require that a risk-based environmental monitoring program be in place which includes all high-care and high-risk areas.
SECTION 3: Good Industry Sector Practice Requirements (Good Manufacturing Practice Requirements) observations:
Facility environment- Similar/Same
Local environment - Changed maintained to an appropriate standard to so as to prevent contamination and enable the production of safe products.
Facility design, construction, layout and product flow - Similar/Same
Fabrication - Similar/Same
Equipment - Similar/Same
Maintenance - Similar/Same
Staff facilities - Similar/Same
Physical, chemical and biological product contamination risk - Similar/Same
Segregation and cross-contamination - Removed covering all aspects of food safety
including micro-organisms, chemicals and allergens.
Stock management - Similar/Same
Housekeeping, cleaning and hygiene - Split in 2 parts FSM EIII 11.1/11.2 Similar wording
Water quality and utility management (including Ice) - Reworded
product safety to food safety. Removed Water for post-harvest washing shall be potable. Potable water shall be used and checked for contaminants at an appropriate frequency. Where applicable, storage of water and storage and handling of ice shall occur so as to prevent contamination. Analysis covered by FSM EIII 24 Analysis of Inputs (e.g. water, ice)
Waste management - Similar/Same
Pest control - Similar/Same
Transport - Added all containers and vehicles, including contracted out vehicles, used for the storage and transportation
Personal hygiene, protective clothing and medical screening - Similar/Same but now in 5 parts GMP EIII 16.1 - 16.5. 16.4 additional wording a medical screening procedure shall be in place to identify conditions impacting food safety.
Training – Similar/Same
Packing and storage of product - New requirement GMP EIII 18.1 The standard shall require that packaging materials are obtained with knowledge of origin, be appropriate for use and are used and stored so as not to be a source of contamination to the product.
Packing and storage of product - New requirement GMP EIII 18.2 The standard shall require that the product shall be handled, sorted, graded and packed in a manner that minimises sources of biological, chemical and physical contamination.
Packing and storage of product - New requirement GMP EIII 18.3 The standard shall require that the product shall be held or stored in designated areas and handled under the proper conditions to minimise contamination.
So, the key changes in GFSI Benchmarking Requirements GFSI Guidance Document Version 7 are requirements for:
Packing and storage of product (Control of packaging materials, product handling, sorting, grading and packing and storage)
Food defence plan
Food fraud vulnerability assessment
Food fraud mitigation plan
Clearly food defence and food fraud have been ‘hot topics’ for a while so their inclusion/elaboration of requirements are no surprise. Environmental monitoring is also high profile given the requirements of FSMA PART 117 Current Good Manufacturing Practice, Hazard Analysis, And Risk-Based Preventive Controls for Human Food 117.165 Verification of implementation and effectiveness. (a) Verification activities. (3) Environmental monitoring.
Allergen management and labelling controls are also essential requirements of any food safety scheme given the amount of product recalls there are due to incorrect labelling.
***UPDATE APRIL 2018***
Last month GFSI released new Benchmarking Requirements, Version 7.2, which focusses on improving auditor competency and covering the entire supply chain
Version 7.2 introduces requirements for auditors of GFSI-recognised certification programmes to have passed an exam. The exam is based on the content of the GFSI Benchmarking Requirements and covers Hazard Analysis and Critical Control Points (HACCP), Good Manufacturing Practice (GMP) requirements and standard auditing skills such as sampling and evidence gathering. Certification Programme Owners have nine months to translate into their programme's management processes and three years to assess all auditors.
Two new scopes of recognition for GFSI Benchmarking Requirements have been introduced:
Catering (Scope G)
Retail & Wholesale (Scope H)
There appears to be minor changes to existing benchmarking requirements, as an example here is a summary of the changes from Version 7.1 to Version 7.2 for PART III - EIII Processing of Animal and Plant Perishable Products (Mixed Products)
SECTION 1: HACCP OR HAZARD BASED REQUIREMENTS
Clause Name Requirements
HACCP EIII 1.1 Added ‘including prerequisite programmes', removed '
including allergens, to demonstrate food safety management'
HACCP EIII 1.2 Same/Similar
HACCP EIII 1.3 Same/Similar
HACCP EIII 1.4 Same/Similar
HACCP EIII 1.5 NEW The standard shall require that the HACCP or HACCP-based system shall include documented Standard Operating Practices (SOP’s) and Work Instructions (WI’s) as required and applicable to the organisation’s Scope of Certification
SECTION 2: FOOD SAFETY MANAGEMENT REQUIREMENTS
FSM EIII 1 Food safety management general requirements
'The food safety management system shall: a) identify the processes needed for the food safety management system, b) determine the sequence and interaction of these processes, c) determine the criteria and methods required to ensure the effective operation and control of these processes, d) ensure the availability of resources and information necessary to support the operation and monitoring of these processes, e) measure, monitor and analyse these processes and implement actions necessary to achieve planned results and continuous improvement. f) include a procedure for verification of the food safety management system to confirm that the system continues to be effective.'"
FSM EIII 2 Food safety policy Same/Similar
FSM EIII 3 Food safety manual Same/Similar
FSM EIII 4 Management responsibility Same/Similar
FSM EIII 5 Management commitment Same/Similar
FSM EIII 6.1 Management review Same/Similar
FSM EIII 6.2 Same/Similar
FSM EIII 7 Resource management Same/Similar
FSM EIII 8.1 General documentation requirements Added ‘procedures’
FSM EIII 8.2 Same/Similar
FSM EIII 8.3 Same/Similar
FSM EIII 9.1 Specified requirements Same/Similar
FSM EIII 9.2 Same/Similar
FSM EIII 10 Procedures Same/Similar
FSM EIII 11 Internal audit Changed
'scope of the scheme' to 'the scope of the Food Safety Management System.'
FSM EIII 12 Corrective action Same/Similar
FSM EIII 13 Control of non-conformity Added 'and documented'
13.2 The standard shall require that the processes described under FSM EIII 13.1 shall be defined in a documented procedure that is securely stored and readily accessible when needed.
FSM EIII 14 Product release Same/Similar
FSM EIII 15.1 Purchasing Same/Similar
FSM EIII 15.2 Same/Similar
FSM EIII 15.3 Same/Similar
FSM EIII 15.4 Same/Similar
FSM EIII 16 Supplier performance Same/Similar
FSM EIII 17 Complaint handling Same/Similar
FSM EIII 18 Serious incident management Same/Similar
FSM EIII 19.1 Control of measuring and monitoring devices Change to 'equipment used to measure parameters critical to ensure food safety.' from
'measurement of parameters critical to ensure food safety.'
FSM EIII 19.2 Same/Similar
FSM EIII 19.3 Same/Similar
FSM EIII 20.1 Food defence threat assessment Same/Similar
FSM EIII 20.2 Food defence plan Same/Similar
FSM EIII 20.3 Same/Similar
FSM EIII 21 Food fraud vulnerability assessment Same/Similar
FSM EIII 22.1 Food fraud mitigation plan Same/Similar
FSM EIII 22.2 Same/Similar
FSM EIII 23.1 Traceability Same/Similar
FSM EIII 23.2 Traceability Change to 'enables traceability to the producer.' from
'that includes, as a minimum, the name and address of the producer.'
FSM EIII 23.3 Addition: ‘This refers to one step forward and one step backward as a minimum.’
FSM EIII 24 Analysis of inputs (e.g. water, ice) Change to 'analysis be performed by a competent laboratory when it is critical to the verification of food safety is undertaken' from
'such analyses are performed to ISO 17025 or equivalent standards'
FSM EIII 25 Product labelling Same/Similar
FSM EIII 26 Allergen management Same/Similar
FSM EIII 27 Allergen labelling Removed reference to '
in the country of manufacture'
FSM EIII 28 Environmental monitoring Removed
'which includes all high-care and high-risk areas'
FSM EIII 29 Food safety legislation Same/Similar
SECTION 3: GOOD INDUSTRY SECTOR PRACTICE REQUIREMENTS
GMP EIII 1 Facility environment Same/Similar
GMP EIII 2 Local environment Same/Similar
GMP EIII 3 Facility design, construction, layout and product flow Same/Similar
GMP EIII 4 Fabrication (input and material handling, preparation, product handling, packing and storage areas) Same/Similar
GMP EIII 5 Equipment Same/Similar
GMP EIII 6 Maintenance Same/Similar
GMP EIII 7 Employee facilities Change to 'employee facilities' from
GMP EIII 8 Physical, chemical and biological product contamination risk Same/Similar
GMP EIII 9 Segregation and cross- contamination Same/Similar
GMP EIII 10 Stock management Same/Similar
GMP EIII 11.1 Housekeeping, cleaning and hygiene Same/Similar
GMP EIII 11.2 Same/Similar
GMP EIII 12 Water quality and utility management (including Ice) Same/Similar
GMP EIII 13 Waste management Same/Similar
GMP EIII 14 Pest control Same/Similar
GMP EIII 15 Transport Same/Similar
GMP EIII 16.1 Personal hygiene, protective clothing and medical screening Same/Similar
GMP EIII 16.2 Same/Similar
GMP EIII 16.3 Same/Similar
GMP EIII 16.4 Added: subject to legal restrictions in the country of operation.
GMP EIII 16.5 Same/Similar
GMP EIII 17 Training Same/Similar
GMP EIII 18.1 Packing and storage of product Same/Similar
GMP EIII 18.2 Same/Similar
GMP EIII 18.3 Same/Similar