PRPs For BRC Agents and Brokers

Good day all, 

I am currently in the process of designing a HACCP plan for my company which is a food broker/ food ingredient trading company. This is in compliance with the BRC Standard for Agents and Brokers which we are currently preparing for.

I can't seem to find any prerequisite programs which apply to this standard. Can anyone suggest if there are any?

Just a background, we never physically handle the products, all transport, storage and other operations are subcontracted by third parties on our behalf. 

Secondly, I have been told that it is normal to have no CCPs on these types of HACCP plans. However, I'm wondering if independent laboratory testing on our behalf counts as a CCP or if inspection and customs approval counts as a CCP as it is a necessity in the process which confirms the quality and legality of the product.

Many thanks

Your prerequisite program is largely going to be the other parts of your food safety and quality management system, e.g. approval for suppliers, transport providers etc.

As for the CCPs, we don't have any in our Agents & Brokers HACCP either, and I could see this being common - whilst section 2 of the standard is often referred to as "HACCP", it isn't necessarily quite the same thing.

Customs approval doesn't really count as a control for food safety purposes IMO - you should show you've considered it in your plan, and also the potential implications of it failing or being delayed, but it's more a critical step for physical passage into a new country, rather than for food safety purposes.

Similarly, the lab testing you're arranging is probably more of a monitoring activity?

In general it's worth noting that IME the audit scope for this section is much broader than food safety, so it can be worth including specific detailed consideration of what might go wrong and what you would do about it for things like customs checks and delays.