In Part 4 of the BRCGS Issue 9 series, we discuss the major changes under Requirement 4 (Site Standards).
The Site Standards requirement consists of 16 clauses (sections) and has 2 fundamental requirements.
The following clauses are fundamental requirements:
4.3 Layout, product flow and segregation
4.11 Housekeeping and hygiene
A complete list of the clauses under Requirement 4 (Site Standards). The clauses marked with * are discussed in this article:
4.1 External standards and site security*
4.2 Food defence*
4.3 Layout, product flow and segregation*
4.4 Building fabric, raw material handling, preparation, processing, packing and storage areas*
4.5 Utilities – water, ice, air and other gases*
4.8 Staff facilities
4.9 Chemical and physical product contamination control*
4.10 Foreign-body detection and removal equipment*
4.11 Housekeeping and hygiene*
4.12 Waste and waste disposal*
4.13 Management of surplus food and products for animal feed*
4.14 Pest management*
4.15 Storage facilities
4.16 Dispatch and transport*
Clause 4.1 – External Standards and Site Security
Clause 4.1.4 – External standards and site security
Clause 4.1 deals with external standards and site security.
The major revision is under Clause 4.1.4 where policies and systems shall be in place to ensure that access to the site by staff, contractors and visitors is controlled.
Contractors and visitors, including drivers, shall be made aware of the procedures for access to the site.
Only authorised personnel shall have access to the production and storage areas, and staff shall be trained in site security procedures.
Clause 4.2 – Food Defence
Clause 4.2 – Emphasis is placed on Food Defence
Under Clause 4.2 in Issue 9, “site security” is now called “FOOD DEFENCE”.
The emphasis is on:
- Complying with the country of sale or intended use’s Food Defence requirements
- Training of staff in Food Defence procedures
The Food Defence team must be adequately informed about all Food Defence risks. The team should have knowledge about the site and Food Defence principles.
Clause 4.3 – Layout, Product Flow and Segregation
Clause 4.3 – Layout, Product Flow and Segregation
Under Clause 4.3, production risk zones shall be included in the site layout diagram.
Clause 4.4. – Building Fabric, Raw Material Handling, Preparation, Processing, Packaging and Storage Areas
Clause 4.4.6 – Access steps and mezzanine floors
There is an addition for requirements of access steps and mezzanine floors under Clause 4.4.6.
Clause 4.4.11 – Maintenance and cleaning of strip curtains
Clause 4.4.11 is a new clause dedicated to the maintenance and cleaning of strip curtains.
Clause 4.5 – Utilities – Water, Ice, Air and Other Gases
Clause 4.5.1 – Management of water stored on site
Clause 4.5.1 requires that water stored on site shall be managed to prevent food safety risks.
Clause 4.5.2 – The water source as part of the water distribution schematic diagram
Clause 4.5.2 requires that the water source be included as part of the water distribution schematic diagram.
Clause 4.6 – Equipment
Clause 4.6 – Requirements for equipment
This clause has been completely revised and now refers to “production and product handling” equipment. Here is a summary of some of the requirements:
- Purchase specifications
- Suitability of the equipment (design, location, easy to clean, etc.)
- Maintaining food safety and integrity during installation and operation
- Inspections prior to operation
- Storage of equipment not in operation or out of service
- Mobile equipment
- Battery charging equipment
Clause 4.9 – Chemical and Physical Product Contamination Control
Clause 126.96.36.199 – Chemical control
Clause 4.9.1 has a change under Clause 188.8.131.52 where it requires that procedures to manage any spills and procedures for the safe, legal disposal or return of obsolete or out-of-date chemicals, and empty chemical containers must be in place.
There is also clarification that chemicals used for raw materials must be stored away from other chemicals.
Clause 184.108.40.206 – The control of portable handheld items
In Clause 4.9.6, there is a change under Clause 220.127.116.11 where it is a requirement to control the use of portable handheld items such as pens, pencils, phones, etc. in open product areas to minimize the risk of contamination.
Clause 18.104.22.168 – Control of other types of foreign materials
Clause 22.214.171.124 requires procedures (based on risk) for the control of other types of foreign materials not explicitly addressed by the standard.
Clause 4.10 – Foreign Body Detection and Removal Equipment
Clause 126.96.36.199 – X-ray equipment testing procedures and the use of test pieces
Under Clause 4.10.3 (metal detectors and x-ray equipment), Clause 188.8.131.52 is specifically dedicated to X-ray equipment testing procedures, including how the test pieces should be used.
Clause 4.10.7 – Other foreign-body detection and removal equipment
Clause 4.10.7 is completely new and focuses on the need to ensure that checks on other foreign-body detection and removal equipment are documented.
Clause 4.11 – Housekeeping and Hygiene
Clause 4.11.2 – Addition of disinfection and records for completion and sign-off
Clause 4.11.2 now refers to documented cleaning and disinfection procedures. “Disinfection” has been added.
Cleaning records should now also include records for completion and sign-off.
Clause 4.11.8 – Relevant pathogens and spoilage organisms
Under Clause 4.11.8 the word “relevant” was added when referring to pathogens and spoilage organisms.
Clause 4.12 – Waste and Waste Disposal
Clause 4.12.3 – Relevant pathogens and spoilage organisms
Waste removal from open product areas:
Clause 4.12.3 (new) requires the following:
“Waste removal from open product areas shall be managed to ensure that it does not compromise product safety.”
Clause 4.13 – Management of Surplus Food and Products for Animal Feed
Clause 4.13.2 – Products given to staff and charities
Clause 4.13.2 requires that products that are given to staff, or charity must maintain traceability and be safe for human consumption.
Clause 4.14 – Pest Management
Clause 4.14.10 – Change of wording from “survey” to “assessment”
Under Clause 4.14.10, the word “survey” is replaced by “assessment”.
Clause 4.16 – Dispatch and Transport
Clause 4.16.6 – Approval of contractors
No major changes except in Clause 4.16.6 where the approval of contractors can be based on two things:
- A valid certification to the applicable BRCGS Standard (e.g., Global Standard for Storage and Distribution), or GFSI-benchmarked standard, or
- a completed contract or terms and conditions.