BRCGS for Food Safety Issue 9 Changes – Part 6: Process Control (R6)

In Part 6 of the BRCGS Issue 9 series, we discuss the major changes under Requirement 6 (Process Control).

The Process Control requirement consists of 4 clauses (sections) and has 2 fundamental requirements.

The following clause is a fundamental requirement:

6.1 Control of operations

6.2 Labelling and pack control

A complete list of the clauses under Requirement 6 (Process Control). The clauses marked with * are discussed in this article:

6.1 Control of operations*

6.2 Labelling and pack control*

6.3 Quantity – weight, volume and number control*

6.4 Calibration and control of measuring and monitoring devices

6.1 Control of Operations

Clause 6.1.1 – Addition of “process specifications”

Clause 6.1 remains a fundamental requirement relating to the CONTROL OF OPERATIONS.

The fundamental statement of intent under Clause 6.1 and the requirements under Clause 6.1.1 now also refer to “process specifications” in addition to procedures and work instructions.

This means process specifications and work instructions should be separate documents or separate processes that should be implemented for all the items listed under Clause 6.1.1.

The second change is the addition of “storage conditions” to the list of things that require process specifications and work instructions or procedures.

The last change is the addition of a requirement to review process specifications, work instructions and procedures prior to changes that may affect food safety, legality and quality.

Clause 6.1.7 – Products or materials outside the scope of the audit

Clause 6.1.7 is a new clause under Clause 6.1 and it reads as follows:

“Where a site handles products or materials (e.g. by-products from production processes) that are outside the scope of the audit, these shall be controlled to ensure that they do not create a product safety, authenticity or legality risk to products within the scope.”

6.2 Labelling and Pack Control

Clause 6.2.1 – Processes for label use

Clause 6.2 remains a fundamental requirement relating to LABELLING AND PACK CONTROL.

There is an addition under Clause 6.2.1 and it reads as follows:

“Processes shall be in place to check label use is reconciled with expected use and the cause of any inconsistencies investigated.”

Clause 6.2.2 – Addition of “printed packaging and labels”

There is an addition of “printed packaging and labels” to Clause 6.2.2. It reads as follows:

“Documented checks shall be carried out at product changes to ensure that all products and printed packaging and labels from the previous production have been removed from the line before changing to the next production.”

Clause 6.2.3 – Clarifying the required checks during packing runs

Clause 6.2.3 now clarifies how the checks during packing runs should be done by providing the following example:

“at predefined intervals and when printed packaging or labels are brought to the line during the production run.”

6.3 Quantity – Weight, Volume and Number Control

Clause 6.3.2 – Where product quantities are not governed by legislation

In Clause 6.3.2 the term “must” have been replaced with “SHALL’. The requirement reads as follows:

“Where the quantity of the product is not governed by legislative requirements, the product shall conform to customer requirements and records shall be maintained.”

Clause 6.3.3 – Processes for handling rejected packs

Under Clause 6.3.3 there is the addition of “processes for handling rejected packs” to the list of minimum requirements for the procedures for the operation and testing of online weighers.

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