BRCGS Clause 3.5.1.1 - Variety or Species Cross Contamination

Morning all,

Long time lurker, first time poster.

To give a bit of context; I work in the UK in an egg packing station.

We are currently doing the change over to BRCGS V9 2022

I am aware of the previous posts relating to this question, but feel mine is slightly different due to the number of other legislations we have to adhere to (BEIC, RSPCA, OF&G, Lion Code, SQMS etc, etc)

So one of the points you have to cover in Section 3 Risk Assessments is: Variety or Species Cross Contamination with chickens I am struggling to differentiate between Substitution and Fraud Vs Variety or Species Cross Contamination. 

Say this was in context to a claim (Organic, Free Range etc) we would rely on Supplier audits in person and ensuring all suppliers adhere to relevant legislation, in this case BEIC and RSPCA are mandatory and OF&G would be applicable if it was an Organic claim.

So previous answers to this question relate mainly to substitution or fraud, looking into it I feel it is leaning towards breeds of birds in my case. So we do a premium product which is from Maran breed hens. Control measures include: Passports for the animals, Intake checks to ensure correct pallet labels, Date Of Lay, Certification legislative numbers, etc, etc. I understand this is a pretty specialist area for Food Manufacturing, but would love to hears others' opinions on this subject within my context.

Many thanks in advice for any comments

Hi jst23,

So the BRCGS Global Standard Food Safety Issue 9 Clause 3.5.1.1 states: The company shall undertake a documented risk assessment of each raw material or group of raw materials, including primary packaging, to identify potential risks to product safety, authenticity, legality and quality.

And requires you to take into account the potential for:

….

- Variety or Species Cross Contamination

- Substitution or Fraud *

….

* See Section 5.4 Product authenticity, claims and chain of custody

5.4.4 Where raw materials are identified as being at particular risk of adulteration or substitution, the vulnerability assessment plan shall include appropriate assurance and/or testing processes to mitigate the identified risks.

So, the difference between Variety or Species Cross Contamination and -Substitution or Fraud is that:

Variety or Species Cross Contamination considers potential for inadvertent variety or species cross-contamination

Substitution or Fraud would be considering the risk deliberate substitution for economic gain.

Also note Clause 3.5.1.1 Guidance states:

This raw material risk assessment is not intended to be a duplication of other clauses.

For example, the reference to authenticity is not intended to duplicate the requirements within section 5.4; the processes are intended to operate together. In other words, section 5.4 should highlight any authenticity risks within the supply and identify suitable controls, whereas this clause is intended to bring those identified risks into the supplier approval, raw material management and raw material receipt processes.

So, you will need to have supplier assurance measures and incoming goods controls to prevent inadvertent mixing of ordinary eggs with Maran Chicken Eggs.

You will also need control measures to prevent deliberate substitution which may include supplier assurance and incoming goods control measures as per 3.5.1.1 but more than likely extra assurance the Maran Chicken Eggs are genuine.

Similar requirements may be applicable for other claims such as Organic or from Corn Fed Hens.

Kind regards,

Tony