BRCGS for Food Safety Issue 9 Changes – Part 4: Site Standards (R4)

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*

4.6 Equipment*

4.7 Maintenance

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
  • Authorisation
  • 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
  • Etc.

Clause 4.9 – Chemical and Physical Product Contamination Control

Clause 4.9.1.1 – Chemical control

Clause 4.9.1 has a change under Clause 4.9.1.1 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 4.9.6.2 – The control of portable handheld items

In Clause 4.9.6, there is a change under Clause 4.9.6.2 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 4.9.6.3 – Control of other types of foreign materials

Clause 4.9.6.3 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 4.10.3.5 – X-ray equipment testing procedures and the use of test pieces

Under Clause 4.10.3 (metal detectors and x-ray equipment), Clause 4.10.3.5 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.

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