(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 2^nd & 3^rd 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.

Learn More

What is the purpose of (EU) 2021/382 and what are the implications?

Food Safety Culture

The newly published commission regulation (EU) 2021/382 amending regulation 852/2004 requires all food business operators to establish, maintain and provide evidence of an appropriate food safety culture.  This legal requirement is a new departure as culture can be quite a subjective matter.  To those of us working in Food Safety we are more accustomed to more measurable criteria such as micro 2073/2005 Chapter 1 & 2 or time x temperature parameters.  Before attempting to address food safety culture one must first understand what culture is.  Why does a group of people form a society with their own culture? Societal culture has five main elements to it.  All cultures have core values, be they music, language, sport, religion etc.  Around these values they perform rituals to help protect, grow and foster these values for themselves and the next generation.  These rituals must be performed by responsible leaders within that society helping to cement and protect the cultural identity.  If you belong to that culture you must then accept the behavioural standards within that society.  The behaviour of the individual within that culture or society is to protect and uphold the core values.  If this behaviour is not within the acceptable norms then the culture can be damaged.

The models above represent the culture model in general society and within a food business operation.

All Food Business Operators must establish and document what their core values are.  Procedures must then be established that protect these values.  These processes are to be implemented under the leadership of a responsible person which all leads to brand protection and potential growth.  The prescribed behaviour is the critical measurement of behaviour as one definition of culture is “what we do when no one is looking.”

To help implement the Food Safety Culture objective, food business operators need to adopt the Plan, Do, Check, Act Risk Management Framework so that the process can be planned, implemented and monitored which will ultimately drive the continuous improvement that is needed.

SQT’s Food Safety Culture One Day Training workshop explores the aforementioned tools to assist Food Business Operators develop a strategic plan to ensure compliance with regulation EU 2021/382.

Next Public Course 24th March 2022 (also available in-house)

Brexit & the Agri-Food Sector – Webinar 09 September 2021 – “Exporting Agri-Food Goods to GB from 1 October 2021”

This “joint webinar with UK Government will provide details on securing health certification and the procedures and systems at borders”

“This webinar will outline the processes for moving agri-food products between EU and GB, including the new GB import requirements to be introduced from 1 October 2021 and 1 January 2022 as outlined in the UK Border Operating Model.

LINK to register for this WEBINAR 09 September

The event will focus on moving agri-food products from EU to GB after 1 October. It will provide practical details about securing export health certification and the procedures and systems at the borders. Following presentations from UK and Irish Government officials there will be an exchange with UK and Irish Trade Associations that covers the main challenges and issues. The event will conclude with a question and answer session with UK and Irish officials.”

INFOSAN Q2 report 2021 – shows Salmonella having highest incident rate
(INFOSAN = global network of national food safety authorities, managed jointly by FAO and WHO with the secretariat in WHO.)

“The International Food Safety Authorities Network (INFOSAN) has been fostering an integrated and cross-sectoral approach to food safety emergency preparedness and response by connecting food safety authorities since 2004”

Food safety incidents – According to Infosan’s Quarter two report 2021 Salmonella having highest incident rate followed by Listeria monocytogenes

“During the second quarter of 2021, the INFOSAN Secretariat was involved in 63 food safety incidents involving 77 WHO Member States. There were 38 incidents involving a biological hazard [Salmonella spp. (19), Listeria monocytogenes (9), Clostridium botulinum (4), Hepatitis A (3), Yersinia enterocolitica (2), Escherichia coli (1)]; 11 involving an undeclared allergen/ingredient [milk (6), cashew (1), eggs (1), gluten (1), shellfish (1), soy (1)]; nine involving a physical hazard [glass (4), plastic (2), metal (1), rubber (1), insects (1)]; and five involving a chemical hazard [histamine (4), methanol (1)].”

Natasha’s Law –
Prepacked for Direct Sale (PPDS) food legislation – comes into effect 01 October 2021
(UK, Wales & Northern Ireland)

“Any food business that produces PPDS food will be required to label it with the name of the food and a full ingredients list. Allergenic ingredients must be emphasised within this list.”

“This can include food that consumers select themselves, for example from a display unit, as well as products kept behind a counter, or some food sold at mobile or temporary outlets.”

Above is relevant to UK, Wales & Northern Ireland.

‘Use by’ or ‘best before’? A topic that can cause confusion…

Follow the links on the extract below for guidance and decision trees released by EFSA in December 2020….

“EFSA has developed a tool to help food business operators decide when to apply the ‘use by’ or ‘best before’ date to their products.

“The ‘use by’ date on food is about safety – foods can be eaten until this date but not after, even if they look and smell fine. ‘Best before’ refers to quality – the food will be safe to eat after this date but may not be at its best. For example, its flavour and texture might not be as good.

The European Commission estimates that up to 10% of the 88 million tonnes of food waste generated annually in the EU is linked to date marking on food products.”

New guidance is available to help food suppliers decide what information to give consumers about storing food and time limits for consumption.

Once food packaging has been opened, bacteria can be transferred to food by contaminated hands, surfaces, or equipment. Setting a time limit for consumption is complex, but the tool developed by EFSA’s experts assists food suppliers in deciding whether it is appropriate to give consumers other instructions in addition to the ‘use by’ or ‘best before’ dates.”

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Did you know there are new rules on Transparency and Sustainability in the EU Food Safety System? [2019/1381]

“REGULATION (EU) 2019/1381 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 20 June 2019 on the transparency and sustainability of the EU risk assessment in the food chain and amending Regulations (EC) No 178/2002, (EC) No 1829/2003, (EC) No 1831/2003, (EC) No 2065/2003, (EC) No 1935/2004, (EC) No 1331/2008, (EC) No 1107/2009, (EU) 2015/2283 and Directive 2001/18/EC”

To view the regulation please click on the link in the paragraph below.

According to EFSA :
A new regulation on the transparency and sustainability of the EU risk assessment in the food chain, which has been in application since 27 March 2021, strengthens the Authority’s ability to carry out its risk assessment functions in accordance with the highest transparency standards.

For the latest on Exporting Minced Meat and Meat Preparations to Great Britain (03/06/21)

“Current UK import requirements will preclude the export of fresh or chilled minced meat or meat preparations from the EU (including Ireland) to Great Britain from 1 October 2021. However, minced meat and meat preparations can be exported to Great Britain if frozen to -18oC and if they meet the other UK import requirements including……:”

Read more here…. UK Import Requirements

Is it time for yet another Food Safety Standard?

BRCGS Food Safety Standard Issue 9 is in the works. No release date as of yet however the consultation period for feedback ended 31st May 2021. 

Unfair Trading Practices & National Food Ombudsman

The UTP Directive (Directive (EU) 2019/633 of the European Parliament and of the Council of 17 April 2019) deals with unfair trading practices in business-to-business relationships in the agricultural and food supply chain.

The Unfair Trading Practices (UTP) Directive must be transposed into Irish law by 1 May 2021 and was subject to a previous public consultation in 2019.

DAFM are holding a Webinar on the Unfair Trading Practices (UTP) Regulations and the National Food Ombudsman/Regulator, where the UK’s first-ever Groceries Code Adjudicator ChristineTacon CBE will be the guest speaker

Taking place this Friday (June 25) at 10:00a.m to 11:30a.m, the UK’s first Groceries Code Adjudicator, Christine Tacon CBE, will address the virtual event.

The webinar will provide information on the Unfair Trading Practices Regulations signed into law in April 2021 by Minister for Agriculture, Food and the Marine.

A short preliminary overview of the submissions received to the recent consultation on the establishment of the office of National Food Ombudsman/Regulator will also be provided.

A key component of the Programme for Government (PFG) commits to:

Ensure fairness, equity, and transparency in the food chain by establishing a new authority called the National Food Ombudsman (NFO) to enforce the Unfair Trading Practices Directive. This new authority will enforce EU-wide rules on prohibited unfair trading practices in the food supply chain and will have powers to enforce this Directive, penalising those who breach regulations. The NFO will have a specific role in analysing and reporting on price and market data in Ireland.

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Food Safety Culture :

There is no doubt that Food Safety Standards have improved significantly over the past twenty years in all sectors of the supply chain driven primarily by major product recalls, GFSI and retailer standards.  Large multinational food manufacturers have also driven improvements through increased expectations of the upstream supply chain.

Figure 1: Elements of Food Supply Chain

As companies’ food safety management systems have matured with 10-15 years of BRC Grade A or FSSC Certification, the expectation now is that Food Businesses have a strong Food Safety Culture.  If most CEOs were asked ”Do you have a strong Food Safety Culture?” they would all say “yes” believing that they do, but do they?

In challenging oneself as to whether your Food Business really has a best practice Food Safety Culture you must first establish what is culture? There are many definitions to be found but the following two are perhaps the more accurate and thought provoking respectively:

“Culture is the system of knowledge shared by a relatively large group of people.”

“Culture is communication, communication is culture”

Figure 1 above simply visualizes the elements of the supply chain.  Food flows one way, money the opposite and expectation always follows the money “he who pays the piper calls the tune.”

What is the tune that your customer expects you to play? They expect you to know their fears, their concerns, their expectations and to understand their Food Safety Culture.  It is then up to your entire organisation from CEO to shop floor operator to “communicate” to them in a manner that assures them that you won’t let them down.

Interested in Finding out More? Check out the Food Safety Culture One Day Training Programme at SQT Training

Preventive Controls Qualified Individual

The Food Safety Modernisation Act (FSMA) is the most significant change to US Food Safety legislation in over 70 years.  The act was signed into law by President Obama in 2011.  FSMA is in response to numerous food poisoning incidents that have occurred in the US over the past ten years.  Figures released by the USDA estimate that each year over 48 million Americans become ill from food poisoning, resulting in 50,000 hospitalisations and over 3,000 deaths.

The FSMA concept is to move away from a reactive approach towards a preventive system.

With FSMA there are seven rules which are specific to different types of foods, elements of the supply chain and stakeholders.  With this level of complexity and change, the challenge for Irish indigenous and Irish based multinational food companies is to understand how these rules will affect their current Food Safety Management Systems.

Under CFR 117 each food manufacturer in the US must have a Preventive Controls Qualified Individual (PCQI).  This individual must have successfully completed training in the development and application of risk base preventive controls using a standardized curriculum recognized by the FDA.  Denis Kiely is a Qualified PCQI  (Cert a1e9e90b) and a Qualified Lead Instructor (Cert 31bf87e2) in Preventive Controls for Human Food.  Delegates who attend this 20 hour programme will become qualified PCQIs.

IMS will be offering Public PCQI Training via SQT Training Ltd., in early 2018…..