BRCGS for Food Safety Issue 9 Changes – Part 9: Requirements for Traded Products (R9)

In Part 9 of the BRCGS Issue 9 series, we discuss the major changes under Requirement 9 (Requirements for Traded Products).

The Requirements for Traded Products consist of 6 clauses (sections).

There are no fundamental requirements under the requirements for traded products.

A complete list of the clauses under Requirement 9 (Requirements for Traded Products). The clauses marked with * are discussed in this article:

9.1 The food safety plan – HACCP*

9.2 Approval and performance monitoring of manufacturers/packers of traded food
products

9.3 Specifications

9.4 Product inspection and laboratory testing

9.5 Product legality

9.6 Traceability*

9.1 The Food Safety Plan – HACCP

Clause 9.1 – Food safety / HACCP plan for traded products

Clause 9.1 is a new requirement where the site is now required to have the Food Safety plan or HACCP plan for traded goods, which could either be a separate document or incorporated into the existing HACCP study or HACCP plan as per Requirement 2.

The scope of trade products’ HACCP for food safety plan shall include the products and the processes for which the site is responsible.

At a minimum, this shall include receipt, storage and dispatch.

9.6 Traceability

Clause 9.6.1 – Traceability requirements for traded products

Clause 9.6 deals with traceability.

The changes are under Clause 9.6.1. The first change relates to the site ensuring that its traceability procedure includes details of the system used for the transferability of traded products. The site can make reference to the traceability of traded products as per Clause 3.9.1.

The second change is to the second paragraph of the requirement under Clause 9.6.1. It now reads as follows:

“The traceability system shall ensure that, for all batches of product, the site can identify the last manufacturer or, in the case of primary agricultural products, the packer or place of last significant change to the product.”

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