BRCGS for Food Safety Issue 9 Changes – Part 7: Personnel (R7)

In Part 7 of the BRCGS Issue 9 series, we discuss the major changes under Requirement 7 (Personnel).

The Personnel requirement consists of 4 clauses (sections) and has 1 fundamental requirement.

The following clause is a fundamental requirement:

7.1 Training: raw material-handling, preparation, processing, packing and storage areas

A complete list of the clauses under Requirement 7 (Personnel). The clauses marked with * are discussed in this article:

7.1 Training: raw material handling, preparation, processing, packing and storage areas*

7.2 Personal hygiene: raw material handling, preparation, processing, packing and
storage areas*

7.3 Medical screening*

7.4 Protective clothing: staff or visitors to production areas*

7.1 Training: Raw Material Handling, Preparation, Processing, Packing and Storage Areas

Clause 7.1.1 – The training of ALL personnel

Clause 7.1.1 now requires that ALL personnel be trained and adequately supervised throughout the working period. The requirement now reads as follows:

“All personnel, including agency-supplied staff, temporary staff and contractors shall be appropriately trained prior to commencing work and adequately supervised throughout their working period.”

Clause 7.1.2 – Training relating to CONTROL MEASURES

Clause 7.1.2 requires that employees involved and engaged in activities relating to CCP’s and CONTROL MEASURES (new addition) should receive relevant training and their competency assessment shall also be in place.

Clause 7.1.4 – Allergen awareness and allergen procedures training of ALL personnel

Clause 7.1.4 now requires that ALL staff must receive training in allergen awareness, as well as training in the site’s allergen handling procedures.

This includes engineers, agency-supplied staff, temporary staff and contractors.

Previously it was only required to train “relevant” staff.

7.2 Personal Hygiene: Raw Material Handling, Preparation, Processing, Packing and Storage Areas.

Clause 7.2.1 – Personal hygiene practices – wearing of jewellery

The only change in Clause 7.2 is under Clause 7.2.1.
There are additional requirements under personal hygiene practices.

The first change is the requirement that wearable devices similar to watches shall not be worn.

The second change is the requirement that personnel is only permitted to wear a single, plain wedding ring, wedding wristband, or medical alert jewellery.

7.3 Medical Screening

Clause 7.3 – Medical screening – transmission of infections, diseases or other conditions

Clause 7.3 covers medical screening.

There are changes to the statement of intent and it now reads as follows:

“The company shall have procedures in place to ensure that staff, agency staff, contractors or visitors are not a source of transmission of infections, diseases (including food-borne diseases) or conditions to products.”

Clause 7.3.1 – Contractors and visitors to be included in the medical screening procedure

Under Clause 7.3.1, the term ‘employees’ changed to ‘STAFF’.

There is also an addition where contractors and visitors to the site must be included as part of the procedure which enables them to notify the site if they show any relevant symptoms, infection, disease, or condition which they may have been in contact with or may be suffering from.

Clause 7.3.3 – Addition of “temporary staff” to the clause

Under Clause 7.3.3 the term “employees” has been changed to “STAFF”.

Temporary staff has been added as part of the list. The clause now reads as follows:

“There shall be procedures for staff (including temporary employees), contractors and visitors relating to action to be taken where they may be suffering from or have been in contact with an infectious disease.”

7.4 Protective Clothing: Staff or Visitors to Production Areas

Clause 7.4.3 – Washing of protective clothing by the employee

Clause 7.4.3 provides better clarification when employees are allowed to wash their own PPE.

The first condition is that the PPE is not used for product safety purposes. For example, PPE used for health and safety purposes (to protect the employee).


The second condition is the PPE is worn in enclosed product or low-risk areas only.

Clause 7.4.5 – Use of gloves

There are slight changes under Clause 7.4.5 where there is an addition of the term ‘shall’ and ‘and’ in the following requirement.

“If gloves are used, they shall be replaced regularly. Where appropriate, gloves shall be suitable for food use, of a disposable type, of a distinctive colour (blue where possible) and intact; and shall not shed loose fibers.”

Clause 7.4.6 – Disinfection of protective clothing unsuitable for laundering

Clause 7.4.6 now requires that protective clothing which is not suitable for laundering shall be cleaned and disinfected (new addition) at a frequency based on risk.

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