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BRCGS for Food Safety Issue 9 Changes – Part 2: The Food Safety Plan – HACCP (R2)

In Part 2 of the BRCGS Issue 9 series, we discuss the major changes under Requirement 2 (the Food Safety Plan – HACCP).

The Food Safety Plan – HACCP requirement consists of 13 clauses (sections) and is a fundamental requirement in its entirety.


A complete list of the clauses under Requirement 2 (The Food Safety Plan – HACCP). Changes to the clauses marked with * are discussed in this article:

2.1 The HACCP food safety team

2.2 Prerequisite programmes*

2.3 Describe the product*

2.4 Identify intended use*

2.5 Construct a process flow diagram

2.6 Verify process flow diagram*

2.7 List all potential hazards associated with each, conduct a hazard analysis, and consider any measures to control identified hazards*

2.8 Determine the CCPs

2.9 Establish validated critical limits for each CCP*

2.10 Establish a monitoring system for each CCP*

2.11 Establish a corrective action plan

2.12 Validate the HACCP plan and establish verification procedures*

2.13 HACCP documentation and record-keeping

Clause 2.2 – Prerequisite Programmes

Clause 2.2 – Prerequisite programmes

Clause 2.2 is about prerequisite programmes. There haven’t been any major changes here, except for the addition of sections.

There is also a new statement that has been added that reads as follows:

“The prerequisite programmes for the particular areas of the site shall be taken into account the production risk zones as per clause 4.3.1.”

The word “must” have been replaced by “shall” which reads as follows:

“The control measures and monitoring procedures for the prerequisite programmes shall be clearly documented and shall be included within the development and reviews of the HACCP or food safety plan.”

Clause 2.3 – Describe the Product

Clause 2.3.2 – Collect, maintain, document and update relevant information to conduct a hazard analysis

The only changes for Clause 2.3 are in Clause 2.3.2.

The first change is the addition of the term “shall”, which has been added to make the following statement mandatory:

“The company shall ensure that the HACCP or food safety plan is based on comprehensive information sources which are referenced and available on request.”

There are also additions to the list of reference documents that can be used to conduct hazard analysis:

  • Copy of any existing site HACCP plans (e.g., for products already in production at the site).
  • A map of the premises and equipment layout.
  • A water distribution diagram for the site.
  • Indication of any areas (zones) where high-risk, high-care or ambient high-care production facilities are required.

Clause 2.4 – Identify Intended Use

Clause 2.4 – Identify the intended use of the product

Under Clause 2.4, which is about the identification of intended use. The words “any known” have been replaced by “expected”. The statement now reads as follows:

“The intended use of the product by the customer, and expected alternative uses, shall be described, defining the consumer target groups, including the suitability of the product for vulnerable groups of the population (e.g. infants, elderly, allergy sufferers).”

Clause 2.6 – Verify Flow Diagram

Clause 2.6 – Verify the process flow diagram

Under Clause 2.6, which is about verification of the process flow diagram, the requirement has been slightly changed to read as follows:

“The HACCP food safety team shall verify the accuracy of the flow diagrams by on-site audit at least annually, and whenever there are changes to the process, to ensure any changes have been considered as a part of the HACCP or food safety plan.”

Clause 2.7 – List All Potential Hazards Associated with Each Process Step, Conduct a Hazard Analysis and Measures to Control Identified Hazards

Clause 2.7.2 – Identifying significant hazards

Under Clause 2.7.2 there is now an emphasis on conducting a hazard analysis to identify significant hazards.

Clause 2.7.3 – Using more than one control measure

There is an added statement under Clause 2.7.3. Consideration may be given to using more than one control measure when the HACCP team considers control measures necessary to prevent or eliminate a food safety hazard or reduce it to an acceptable level.

Clause 2.7.4 – Specific food safety hazards

Clause 2.7.4 has been slightly changed to include “of a specific food safety hazard”. It now reads as follows:

“Where the control of a specific food safety hazard is achieved through prerequisite programmes (see section 2.2) or control measures other than critical control points (CCPs; see clause 2.8.1), this shall be stated and the adequacy of the programme to control the specific hazard validated.”

Clause 2.9 – Establish Critical Limits for Each CCP

Clause 2.9.2 – Critical limits

Under Clause 2.9.2 “including critical limits” has been added. It now reads as follows:

“The HACCP food safety team shall validate each CCP, including critical limits.”

Clause 2.10 – Establish a Monitoring System for Each CCP

Clause 2.10.2 – CCP records

Under 2.10, no major changes with the exception of Clause 2.10.2 where “suitably competent” has been added.

“Records associated with the monitoring of each CCP shall include the date, time and result of measurement, and shall be signed by the person responsible for the monitoring and verified, when appropriate, by a suitably competent and authorised person.”

Clause 2.12 – Establish Verification Procedures

Clause 2.12 – Additional clauses

There was only one requirement under Clause 2.12 in Issue 8. In Issue 9 there are now three requirements.

Clause 2.12.1 – Validate the HACCP or food safety plans prior to changes

Clause 2.12.1 in Issue 9 has a new requirement, and it reads as follows:

“HACCP or food safety plans shall be validated prior to any changes which may affect product safety, to ensure that the plan will effectively control the identified hazards before implementation.
For existing HACCP or food safety plans, this may be achieved using the established processes detailed in clauses 2.12.2 and 2.12.3.”

Clause 2.12.2 – Verification of procedures

Clause 2.12.1 in Issue 8 moved to Clause 2.12.2 (new) in Issue 9 with no changes.

Clause 2.12.3 – Review of the HACCP plan and PRPs

Clause 2.14.1 in Issue 8 moved to Clause 2.12.3 (new) in Issue 9 with slight modifications.

The clause now includes the clarification of some of the changes that must be implemented. Any changes you make to your HACCP system must be documented and the validation thereof recorded.

Related BRCGS Issue 9 Changes Topics

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