What’s new in BRCGS Food Safety Standard Issue 9

(Update to Standard Published August 2022 – Certification Commences February 2023)

There is more to the changes in the BRCGS– Food Safety Standard Issue 9 than initially meets the eye.  The prescriptive nature of BRCGS standards is still there however it is quite cleverly insisting on non-technical / quality personnel, namely – engineering, maintenance, senior management supply chain and HR playing their part in the management of the FSMS.

As was to be expected, the Food Safety Culture is being further emphasised via Section 1 Senior Management Commitment.  This combined with the new legal Food Safety Culture requirement as of March of this year (EU Notice 2021/382) makes this a topic that must be fully embraced. 

In HACCP the need to validate PRPs is a new addition which will undoubtedly cause a bit of concern or perhaps confusion.  CCP validation is relatively straight-forward however ‘validating pre-requisite programmes that control food safety hazards’ is challenging, 

Section 3 changes including supplier approval and performance plus CAPA all need careful consideration.  As CAPA is a fundamental clause, the approach an FBO adopts to the new requirements requires consideration.  My advice is that the same CAPA approach cannot be adopted for everything.  A specific approach for issues that arise in 2nd & 3rd party audits, competent authority findings is best separated from the more mundane issues that arise on a day to day basis.

In Section 4 the approach to food defence and authenticity needs careful planning.  There is a greater focus on competency for those who undertake threat assessments.  I believe that an FBO now needs the TACCP / VACCP Team to be as well trained and skilled as their HACCP Team. 

Section 4.6, equipment has got a complete rewrite.  You will need your engineering manager or maintenance manager to really step up here.  If they are familiar with DQ, IQ, OQ and PQ Validation methodology of equipment you will be fine, if not there is work to do.

In clause 5, product authenticity, claims and chain of custody, there is a greater expectation with regards to vulnerability assessment of raw material with the need for the team to have a greater understanding of food fraud risk.  Section 5.9 regarding Animal Primary Conversion is brand new however the majority of slaughter FBOs have little to fear from it as it is relatively straight-forward. 

Changes to Section 6 and 7 are relatively minor in nature.  Section 8, Product Risk Zones as always needs careful reading.  The Map of the site “shall include the location of pathogen control step’ and there are new clauses regarding cross-contamination control during CIP.

If Clause 9, traded product is within your scope there is a new requirement regarding possession of HACCP Plans.

The audit possibilities have been changed with three options :

  1. Option 1, announced on-site audit
  2. Option 2, blended, announced audit
  3. Option 3, unannounced on-site audit

Overall I think the changes to BRCGS Food Safety Standard Issue 9 are very good for the average FBO’s Technical or Quality Manager.  It is driving the Food Safety Culture message and requires other departments and their responsible managers to demonstrate their knowledge, understanding and commitment to the production of safe food.

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