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BRC Global Standard for Agents and Brokers issue 1 Draft 5

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Posted 30 September 2013 - 03:53 PM

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:

  1. Newer concerns with cold supply chain management (farm/field to fork)
  2. FDA’s new FSMA food import legislation
  3. Fraud (i.e. – horse meat scandal in the UK)
  4. 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

 Importation/export processes

 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

 allergens

 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.


Any thoughts?



><((((º> Salmon of Doubt & NOAA HACCP lover of Bacon


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Posted 02 October 2013 - 04:51 AM


Interesting issue. Well, I don't have a chance to read this standard in detail yet. However, I think this standard for agents and brokers who acts as trader (no warehouse/storage and not involve in transportation/distribution).

Do agree that these agents and brokers almost no affect to food safety risk if raw materials source is certified, manufacturing site is certified, external storage site is certified, and distributor is certified....the final products should be safe if used according to the guide shown on label.

My opinion might change after read more detail of this standard. :)



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Posted 03 October 2013 - 05:39 AM

Well, I've gotta say, I can see your points.  I can agree that a broker, within his own processes, does not directly impact the safety of a food product simply by his buying and selling it.  In fact, in many cases, he may not even handle it directly but may do drop shipping.


The thing is, he's selling a food product.  If he doesn't understand the fundamental aspects of HACCP and general food safety, how can he be sure that the consumer is protected?  Moreover, he's not doing himself any favors and not protecting his own business if he inadvertently sells an inferior product.


I don't think it's a big hurdle to ask these folks to develop an understanding of food safety. Many of them probably don't think about food safety considerations enough, if at all.  Nor do they have an understanding of the unique risks inherent to the products they trade in.  It's not enough, in my opinion, for a broker to ask their supplier for a certificate of any kind.  They need to understand what they're asking for and why, and what the watch-outs are for the items they trade in.


I think these changes are great for the industry.  I hope they take hold and become commonplace.


Anyone disagree?  I love a good discourse and I'm open to an opposing viewpoint.


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Posted 03 October 2013 - 09:40 AM

If this goes some way to protecting the grower/supplier too then I am all for it.

We had a rejection last week of our fruit. The photos sent to us show the pallet had been split and put directly onto the floor ( thats a non-conformance according to BRC)

when the fruit was returned to us we had peppers in the boxes!!! we don't grown peppers! And the boxes were covered in mud.


Once the fruit leaves our farm we have no say in how the customer treats the fruit, yet according to our shelf life samples there should have been no issues with the consignment, the same batch also went to other customers with no issues.


This issue aside if they are treating our product like this what is the end customer buying in the shop?

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Posted 09 October 2013 - 06:20 AM

 Although I have yet to read the draft, I believe this proposal is relevant since "Agents / Distributors" are generally part of the concept of  responsibility and chain of custody deeply rooted within the supply chain. 


Look forward to reading it!

Charles Chew

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Posted 13 November 2013 - 09:07 PM

 products should be safe if used according to the guide shown on label.

and the company not responsible for improper storage and handling


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Posted 15 November 2013 - 07:43 PM

Only 84 total clauses in the following areas:

1.  Senior Management Commitment
1.1      Senior Management Commitment and Continual Improvement
1.2      Organisational Structure, Responsibilities and Management Authority
2. Hazard and Risk Assessment
3. Product Safety and Quality Management System
3.1      Product Safety and Quality Systems Manual
3.2      Documentation Control
3.3      Record Completion and Maintenance
3.4      Internal Audit
3.5      Corrective Action
3.6      Control of Non-conforming Product
3.7      Customer focus and communication
3.8      Complaint Handling
3.9      Management of Incidents, Product Withdrawal and Product Recall
4. Supplier and sub contracted service management
4.1       Approval and performance monitoring of suppliers of products. –
4.2      Management of suppliers of services
4.3      Management of out sourced processing
4.4      Product Security /Food Defense
4.5      Specifications
4.6      Traceability
4.7      Product Inspection and Laboratory Testing
4.8      Product Legality
4.9      Product Design/Development
4.10    Product Release
5. Personnel
5.1      Training and Competency



IFS (International Featured Standards) just come out with a version 2 (version 1 was developed three years ago):



Edited by baron, 15 November 2013 - 07:44 PM.

><((((º> Salmon of Doubt & NOAA HACCP lover of Bacon

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