FAQs
Answers to general questions regarding how BRC certification works can be found here. Specific questions relating to the clauses and protocol of the Global Standard for Food Safety Issue 5 are detailed below.
1. Non-conformities
Can a minor non-conformity be awarded against the statement of intent?
Yes, an example may be against the statement of intent for clause 4.9 where the standard of hygiene of an area is not maintained to an appropriate level. This will NOT result in a grade D.
When will a major non-conformity be awarded against clause 1.11 – maintenance of certification?
A major non-conformity will be awarded where the company has not undertaken an audit within the audit due date (as indicated on the certificate). It is recognised that there may be specific circumstances where audits cannot occur within the certification cycle for instance packing of seasonal product, or access restrictions to the site and these exceptions are outlined within the Standard protocol Section III paragraph 12. Moving the audit date to a more ‘acceptable’ date for reasons of combining audits, lack of personnel or undertaking building work is not an acceptable reason for missing the due date. It is not a justifiable reason to delay audits where sites are not in full production, since there is a 28 day window in which the audit can occur and it is presumed that there will be occasions within that period where production is planned. Audits must however be undertaken whilst there are products being manufactured. Justified reasons should be agreed with your Certification Body prior to any delay with your audit booking. It is the certificated company’s responsibility to ensure a suitable audit date is agreed within the appropriate timescale. Where the company is not required to have certification by customers and where certificates have lapsed for more than 6 months re-entry to the BRC certification scheme will be considered as a new application and the clause 1.11 will not apply.
At our audit we obtained a major non-conformity against clause 1.11 , as this is a subclause of a Fundamental clause – does this mean we get a grade D?
No – the awarding of a major non-conformity must be against the ‘statement of intent’ of a fundamental clause highlighting that there is a substantial failure against the principles of the clause for a grade D to be awarded. You would however, also get a grade D if you had 3 or more major non-conformities, 2 with > 21 minors or 0-1 with > 31 minors.
I have had a BRC audit and am not happy with the non-conformities identified or the grade awarded – what can I do?
The company has the right to appeal the certification decision made by the certification body which should be made in writing to the certification body within 7 days of the decision. The Certification Body shall give a full written response within 30 days following a full and thorough investigation. The company also has the option to contact the BRC if resolution cannot be attained by the two parties.
2. Clarification of Clauses
What would you expect to see for a risk assessment, since the Standard now bases many of the requirements on this?
Some sort of documentation would be expected to be seen as evidence of the thought process and conclusions made as to the risks to products. However, the principles and objectives behind 'risk assessment' are to ensure that the company has considered the issues pertinent to the requirements and can justify the reasons for their policy or procedures, responding to the challenge by an auditor. In some instances it would be appropriate to have a detailed document (along the principles of a HACCP plan) showing those considerations, an example may be the risk rating for suppliers and the subsequent approval process or the risks to product from physical contamination which would be included within the HACCP plan. However, other requirements such as the policy on where beard snoods shall be worn could be evidenced in other ways such as a documented policy, to the understanding by staff and the reasoning behind this policy. This would include considerations of best practice within the industry and be open to challenged by an auditor. The need for a documented risk assessment would be particularly pertinent where you have decided not to adopt procedures for a particular requirement e.g. not wearing beard snoods in a particular area.
What is defined as ‘a current issue’ of the Standard as required by clause 1.10?
An ‘original’ issue of the Global Standard for Food Safety Issue 5 must be available on site. These are available through the BRC Bookshop in various languages, in print and as a PDF (where usage rules apply). This must not be a photocopy and should be made available to all relevant staff to ensure they understand The Standard’s requirements.
Clause 1.12 - who are defined as the ‘most senior’ production or operations manager on site to attend meetings?
The objective behind this requirement is to ensure that the conclusions of the audit and any actions required to correct non-conformities are effectively understood, agreed and there is the authority to ensure these are carried out. Whilst it may be the case that the most senior personnel may be absent on the day of the audit, there will always be someone on site that will be responsible for the daily running of the site.
How many people should make up the HACCP food safety team and what training do they require?
The number of people on the HACCP food safety team should be pertinent to the size and structure of the company as the team should include representatives of each department with responsibility for operation of The Standard. It should not be too large and note that 1 person does not constitute a ‘team’. It would be expected that participants should have appropriate training, with particular regard to the team leader. This may be achieved through external, industry recognised training specific to HACCP but may equally be achieved by a good quality internal course. At the audit, the competency and understanding of the HACCP team would be assessed as well as the quality of the resultant HACCP plan. Note that if the HACCP plan has been prepared with the help of an external consultant, internal staff must still be fully conversant with the plan, principles and practices associated with it. Records need also to demonstrate the training of the external consultant in HACCP principles.
What documentation do you need to keep for HACCP?
You need to ensure that the information on which the HACCP plan is based is referenced and available on request by the auditor. This may include published literature on known hazards, codes of practice or legislation. You need to keep records of HACCP team meetings and the decisions which were reached. You should have documents to demonstrate how the decisions for establishing CCPs were reached.
We are a small company with many customers – what do we need to do for the requirements on customer focus -clause 3.4?
The review of customer requirements needs to be planned and where appropriate undertaken on a regular pre-determined frequency which will vary according to individual customer requirements. When dealing with large customers such as a retailer, it is likely that they will determine the frequency for a formal contract review meeting or the requirement for generation of monthly reports, details key performance indicators. The level of communication should be based on customer requirements and it is accepted that smaller companies may communicate in a less formal way that is not documented but fulfils the customer requirements by regular telephone contact for example, and links to other procedures such as complaints analysis. Communication evidence maybe provided via email for example.
What training do internal auditors have to have completed and what does ‘independent from audited department’ mean in clause 3.5.2?
Internal auditors should be able to show via training records that they have received formal training either via attendance of an external course or via training within the company. Training should cover the planning and scheduling of internal audits, preparing reports and follow up of audit findings. The objective behind the requirement for auditors to be independent of the area being audited is to ensure that the audit is rigorous and thorough and is not influenced by the work which may need to be carried out to effect corrections and improvements. Auditors should not be biased or influenced. External auditors may need to be used where there are insufficient internal resources.
How accurate does the quantity check / mass balance on traceability need to be as specified in clause 3.9.2?
It is unlikely that the mass balance check will be able to account for all materials to an accuracy of 100%, however, the company needs to justify the discrepancies and demonstrate they understand the nature of the variance through dehydration of fresh ingredients, typical wastage on equipment and portion variances for example. The principle of this requirement is to ensure that the traceability system is effective and mass balance is a key measure of this workability and highlights areas for improvement.
What is the registration that clause 4.2.6 requires?
This clause relates to legal requirements to register premises with enforcement authorities pertinent to food safety and quality and includes as examples the requirement for food businesses to be registered with the local authority in the UK under Regulation (EC) No. 852/2004 on the Hygiene of Foodstuffs, Article 6(2) or that food premises in the USA must be registered with the US treasury under the 'Public Health Security and Bioterrorism Preparedness and Response Act of 2002'. It does NOT include other legal registrations related to personnel health and safety such as fire regulations or employment law as this is outside the scope of the Standard.
Clause 4.5.3 requires equipment to be suitable for food use where appropriate – I can’t obtain a certificate of conformity for machinery we’ve had on site for years, what can I do?
The requirement is designed to ensure that manufacturers are complying with relevant legislation, for example the EU ‘Materials and articles intended to come into contact with food Regulation 1935/2004’ and that such materials do not constitute a hazard to food. General principles should be to use approved suppliers known to supply products designed for food use. All new food contact equipment should be purchased with a certificate of conformity or specification detailing its suitability for food use, this may also be confirmed by a symbol or label on the product. Where this evidence is not available, then a risk assessment should be carried out to justify its use and determine that it is not a food safety risk. The risk assessment should consider factors such as , the nature of the food contact surface material and its known characteristics e.g. stainless steel is known to be a food grade material; length of contact time with the food and the nature of the food and its potential for contamination e.g. fatty foods may be more at risk from migration of contaminants from a plastic container for example. Further clarification should be sought e.g. from equipment manufacturer or testing such as migration tests where required.
To meet the requirements of clause 4.6.6 that contractors shall be under the supervision of a nominated person – does that mean they have to be accompanied at all times on site?
Not necessarily – the objective of this requirement is to ensure that any contractor on site is made aware of relevant site rules such as personnel hygiene and adheres to these rules. That good practice is adhered to that the site contact is aware that they have arrived on site, have completed the job to the company’s satisfaction and that it has been checked and approved before the contractor leaves site.
Clause 4.7.4 and 4.75 dictates the requirements for handwashing in production and in toilets. Does this mean that roller towels can’t now be used?
This requirements clearly specifies what can and can’t be used and includes that roller towels cannot be used at handwashing stations in production areas as they are not ‘single use’; they can however, be used in toilets but only if they are not the only facilities provided before re-entering production.
I handle nuts on my site, but add a statement on my packaging stating ‘it cannot be guaranteed that this product is free of nut traces’ – do I have to comply with any of the requirements of section 5.2?
Yes, you still have to carry out a risk assessment and consider what steps are appropriate for your company to minimise the potential for cross contamination.
I do not handle any allergen containing materials on my site, but I am not making any ‘nut free’ claims, are the clauses of 5.2 applicable?
The following clauses would still be applicable 5.2.1.1, 5.2.1.2, 5.2.1.5 and 5.2.1.7
Is it correct that I have to have a metal detector as specified in clause 5.3?
The Standard requires that a foreign body detector eg x-ray machine or metal detector be in place unless it can be justified as not necessary. This shall identify that procedures are in place that control potential foreign body contamination to the same level as detection facilities and for example may include where finished product liquids are filtered or dry materials are sieved.
What is meant by “shelf life tests shall validate the minimum shelf life period indicated on the product” in clause 5.5.1.4?
This requirement is trying to reflect that a margin of safety is included within any products stated shelf life and that the use by or best before date labelled on the product would never be the ‘maximum’ life. Therefore shelf life trials should extend beyond the stated life.
Clause 7.5 relates to protective clothing - is there justification for not wearing protective clothing?
Protective clothing includes uniforms, overalls, head coverings such as hats and hair nets, shoes and boots, aprons and gloves whether disposable or washable. Protective clothing is that which protects the product from contamination, however, the risk assessment shall consider potential contamination from foreign bodies such as buttons and fibres from clothing as well as hair and therefore protective clothing is likely to be required and it would rarely be expected to see any suitable justification for exception.
Where would home laundering be acceptable as detailed in clause 7.5.4?
Home laundering may be deemed acceptable in low risk operations such as produce packing where there is no microbiological risk. This needs to be controlled by written instructions to staff to include:
- How garments are to be washed (temperature, detergent, avoiding of items to be washed together, drying instructions).
- Employees must be provided with some suitable means to safely transport washed garments from home to the workplace. (ie sealable plastic bags, or similar).
- There must be a defined responsibility within the company for monitoring the effectiveness of the system. This may typically be achieved by visual inspection.
- There must be a procedure and system for effectively dealing with any case where employees are unable to perform self-laundry, either through lack of diligence or facilities. This system must be capable of being brought into immediate effect once a problem has been identified.
3. About the Audit
How often will I need to be audited against the Standard?
The audit frequency depends upon the grade achieved which is a result of the type and number of non-conformities awarded. Grades A and B have an audit frequency of 12 months with a grade C 6 months.
How long will the audit take?
The length of the audit will depend on the modules being included within the audit and size and complexity of your operations. A typical audit would be expected to take 1 to 1.5 days on site with another 0.5 to 1 day to produce the detailed report.
How quickly will I get my Report/Certificate?
At the end of the audit the auditor is expected to provide a summary of any non conformities identified and will usually provide a written report setting these out. Sites are then allowed 28 days to provide the evidence that they have completed any actions identified at the audit. A further 14 days are allowed for the Certification Body to review the information, complete the report and make a certification decision. In all a time of 42 days should be allowed between the audit and issue of a certificate.
I have a grade D – when I can I undertake a new audit?
Where a Grade D has been awarded a full re-audit must then be carried out to gain certification. The company should be made fully aware of the need to ensure that there must be significant, demonstrable evidence that the requirements have met and the underlying causes of previously identified issues have been effectively addressed before commissioning the new audit. Due to the nature and number of non-conformities, it is unlikely that these nonconformities can be addressed and fully effective improvements implemented and established within a 28 day period; although there may be some exceptions. It is likely, therefore, that in most cases the re-audit will take place after the 28 day period and typically a 3 month period may be required to fully establish new systems or patterns of working.
When can we book an audit for our newly built factory?
Manufacturing units that are newly built or ‘commissioned’ must ensure that systems and procedures in place are compliant before an initial BRC audit is undertaken. It is at the discretion of the company when they wish to invite a Certification Body to carry out an audit, however they must be able to demonstrate that systems and processes are well established, compliant and monitored. It is unlikely that full compliance can be satisfactorily demonstrated within a 3 month period from commencement of operation. A company may wish to consider a pre-assessment towards the end of this 3 month period. With respect to a new production site within an established company, the site systems and procedures may reflect that systems already established with other sites within the company, but a full audit must establish compliance against BRC requirements for the new site.
