BRCGS for Food Safety Issue 9 Changes – Part 5: Product Control (R5)

5.3 Management of allergens

5.1 Product design / development*

5.2 Product labelling*

5.3 Management of allergens*

5.4 Product authenticity, claims and chain of custody*

5.5 Product packaging*

5.6 Product inspection, on-site product testing and laboratory analysis*

5.7 Product release

5.8 Pet food and animal feed*

5.9 Animal primary conversion*

Clause 5.1.1 – New product development / changes to existing products procedure

Clause 5.1 deals with product design or development.

Clause 5.1.1 requires that the company shall have a procedure for new product development and changes to existing product, packaging and manufacturing processes.

The procedure shall include any restrictions to the scope of new product development to control the introduction of hazards which would be unacceptable to the site or customers.

For example, the introduction of allergens, glass packaging, microbiological risk, or the introduction of ingredients that may affect product claims.

Clause 5.2.1 – Procedure for artwork approval and sign-off

Clause 5.2.1 requires that the company shall have a procedure for artwork approval and sign-off.

Clause 5.3 – Management of allergens

Clause 5.3 is a fundamental requirement relating to the management of allergens.

Expansion in terms of how the management of allergens relates to pet food and animal feed. It reads as follows:

“Pet food and animal feed manufacturers certificated to the Standard are required to meet the appropriate allergen management legislation in the country of intended sale of the products. Therefore, if there is no legislation relating to allergens in pet food/animal feed, this section of the Standard may be considered ‘not applicable’ for pet food or animal feed destined for those countries.

In some parts of the world, allergen claims (e g. gluten- or dairy-free) are made on pet food or animal feed products. Therefore, where a site makes an allergen claim on a pet food or animal feed, it is required to meet all of the requirements within section 5.3.”

Clause 5.4.1 – Vulnerability assessments must be performed by knowledgeable personnel

Under Clause 5.4.1, there is an addition that reads as follows:

“Where personnel are engaged in vulnerability assessments, the individual or team responsible shall understand potential food fraud risks. This shall include knowledge of raw materials used by the site and the principles of vulnerability assessment.”

Clause 5.4.2 – Addition to vulnerability assessment activities

Under Clause 5.4.2 there is an addition of the information that could be used to conduct the vulnerability assessment, where the new standard adds that these can include activities completed for Clause 1.1.8.

Clause 5.4.3 – Review of the vulnerability assessm

Under Clause 5.4.3 it is now a requirement to review the vulnerability assessment plan:

• at least annually,
• whenever there is a change of raw materials or supply of raw materials, or
• the emergence of new risk following a significant products food safety incident (for example, a product recall where the authenticity of the site’s product or raw material is implicated.)

Clause 5.4.5 – Review of the mass balance

Clause 5.4.5 places emphasis on the review of the mass balance at least once every six months if no guidance is given by the scheme the site is certificated to.

Clause 5.4.7 – Validation of product formulation and production processes

Clause 5.4.7 explicitly requires the site to ensure that product formulation and the production processes are fully validated to meet the stated claim and any legal requirements in the country of intended sale related to the claim.

Clause 5.5 – Product packaging procedures

Under Clause 5.5, where the standard discusses product packaging, the first change is under the statement of intent, which reads as follows:

“Product packaging and processes for the purchase of product packaging shall be appropriate for the intended use. Packaging shall be stored under conditions to prevent contamination and minimise deterioration.”

Clause 5.5.1 – The use of recyclable or reusable packaging material

Under Clause 5.5.1, there is an insertion of “the use of recyclable or reusable packaging materials”.

Clause 5.6 – Product inspection, on-site product testing and laboratory analysis

Clause 5.6 has been renamed to “Product inspection, on-site product testing and laboratory analysis”.

In the statement of intent, “authenticity” has been added as part of the requirement and now the requirement reads as follows:

“The company shall undertake or subcontract inspection and analyses which are critical to confirm product safety, authenticity, legality and quality, using appropriate procedures, facilities and standards.”

Clause 5.6.1 – Processes for obtaining product samples as part of the documented testing programme

Clause 5.6.1 now also includes the “processes for obtaining product samples (including, where appropriate, their delivery to a laboratory)” as part of the documented testing programme.

Clause 5.6.2 – Understanding the significance of on-site and laboratory results

Under Clause 5.6.2 the following is completely new. It reads as follows:

“The significance of on-site and laboratory results shall be understood and acted upon accordingly. Appropriate actions shall be implemented promptly to address any unsatisfactory results or trends.

Where legal limits apply, these shall be understood and appropriate action is taken promptly to address any exceedance of these limits.

Where applicable, the measurement uncertainty associated with laboratory test results shall be considered.”

Clause 5.6.5 – On-site testing laboratories

Under Clause 5.6.5 the following controls shall be documented and implemented and include the consideration of (highlighted sections are new):

• “Operating procedures to contain laboratory activities, including the design and operation of drainage and ventilation systems.
• Access and security of the facility.
• Movement of laboratory personnel.
• Hygiene and protective clothing arrangements.
• Movement of materials that may pose a risk to products, raw materials or the production area, into and out of the laboratory, including the disposal of laboratory waste.
• The management and monitoring of laboratory equipment.”

“Where testing activities are performed in production or storage areas (e.g., at the line tests or rapid tests), these shall be located, designed and operated to prevent product contamination.”

Clause 5.6.6 – Requirements for testing laboratories

Under Clause 5.6.6 the following was added:

• “authenticity”
• “including proficiency testing where applicable”

It now reads as follows:

“Where the company undertakes or subcontracts analyses which are critical to product safety, authenticity or legality, the laboratory or subcontractors shall have gained recognised laboratory accreditation or operate in accordance with the requirements and principles of ISO/IEC 17025, including proficiency testing where applicable. Documented justification shall be available where accredited methods are not undertaken.”

Clause 5.8 – Pet food and animal feed

Clause 5.8 has been renamed to “pet food and animal feed” with the addition of “animal feed”.

The statement of intent has been revised and reads as follows:

“Where a site produces pet food or animal feed, all the relevant requirements from sections 1–7 of the Standard must be fulfilled in addition to the requirements in this section.”

Clause 5.8.1 – Pet food and animal feed must be formulated or designed for the intended use

Clause 5.8.1 requires that the site shall ensure that pet food and animal feed is formulated or designed for the intended use.

For example, where products are designed for complete diet or as a complementary product.

Clause 5.8.2 & 5.8.3 – Addition of “animal feed” to the requirements

“Animal feed” has been added to the requirements in Clause 5.8.2 and Clause 5.8.3.

Clause 5.8.3 – Pet food or animal feed products that contain medicinal substances

There are other additions to Clause 5.8.3 relating to the procedures for the management of medicated raw materials and finished products. The additions are as follows:

• “Supplier approval equivalent to section 3.5.1 for all medicated raw materials.
• Specific staff training on the correct handling of medicated materials.
• Waste disposal mechanisms (see section 4.12) that include the safe and legal disposal of medicated raw materials and products.”

Clause 5.8.4 – Meeting relevant pet food and animal feed product legislation

Clause 5.8.4 is new and reads as follows:

“Site procedures shall be designed and implemented to meet the relevant pet food and animal feed product safety legislation (both in the country of production and in the country of sale).”

Clause 5.9 – Animal primary conversion

Clause 5.9 is new and focuses specifically on ANIMAL PRIMARY CONVERSION.

Summary of the requirements:

Clause 5.9.1: Risk assessment for potentially prohibited substances.

Clause 5.9.2: Requirements for the receipt of live animals.

Clause 5.9.3: Traceability of all edible parts of the carcass.

Clause 6.9.4: Defined time and temperature requirements for all post-slaughter processes.