Validation of the elements of a Food Safety Management System

BRCGS Food Safety Standard Issue 9 looks very similar to Issue 8 at a glance however when one probes a little deeper the changes are quite significant. One of these is Validation of a HACCP or Food Safety Plan and/or pre-requisite programmes.

As Validation is not one of the seven HACCP principles and not a legal reference in the EU (it is in the USA), it has always been a challenging concept. We are good with Verification but not with Validation. Validation is proof that something can work and Verification is proof that something is working.

All Food Business Operators with GFSI Certification will have their CCPs and maybe oPRPs validated however what about the PRPs? Clause 2.74 of the BRCGS Food Safety Standard Issue 9 is a new clause “to emphasise that the control of specific hazards needs to be validated where the control is achieved via a pre-requisite or a control measure other than a CCP.” It further states that “it is not a requirement for all PRPs to be validated, only those designed to control a specific hazard.”

The final interpretation can be quite difficult. It is easy to apply to cleaning as it does control a specific hazard however what about the other 14 PRPs?

The most important issue when approaching Validation is that you have a clear methodology that you will follow and a standard reference document. Be it DQ, IQ, OQ, PQ & MQ or perhaps a more basic Part I and Part II approach as advocated by the FSIS.

Food Safety Management Systems have evolved significantly over the past 10 years from a shelf based manual to a comprehensive understanding at factory floor level by production and maintenance personnel. Validation and Risk Based Thinking is now where leadership and understanding is required by Technical and Quality Assurance Managers to lead their food safety teams through these challenging concepts.