How do I achieve BRC Issue 8 certification?
BRC Certification is usually considered extremely difficult, but it is not as difficult as most food industry organisations make it. The BRC Global Standard for Food Safety ensures effective management and assurance of product safety, quality, legality, and integrity. It provides guidance on operational and product control measures that ensure the product produced meets defined criteria. Issue 8 of the BRC Standard is divided into nine sections. Many people ask themselves, how can I achieve certification with this Standard? As ASC Consultants, we have drawn up a list of steps that we believe could assist you or your organisation achieve certification.
Step 1: Statutory and legal requirements
The first factor to consider when starting a food manufacturing business is the statutory and legal requirements of the country you intend to sell the product. Many countries have specific and mandatory requirements for food businesses. Investigate your country’s relevant laws and regulations for starting a food business. Ensure you are familiar with specific requirements related to your industry. If there are laws and regulations you need to comply with before starting with your food operations, ensure you are fully compliant.
The statutory and legal requirements may look at the following at minimum:
- Food premises and the correct zoning
- Process flows, including raw materials, work in progress, final product, waste, packaging material, personnel, water distribution, etc.
- Training of the person in charge and food handlers
- Pest control and waste management
- Building structure compliance with relevant regulations, for example, Health and Safety, Building Standards ACT, etc.
- Provision of resources to ensure safe food handling, e.g. refrigeration units, food containers, handwashing facilities, thermometers, personal protective equipment for staff, etc.
Step 2: Product Legality
The food industry has evolved from just manufacturing simple foods to processing various food products across the food supply chain. It has become easier for one to become creative and innovative. Equally, food safety risks have also increased. To avoid food safety-related incidents, one must ensure that the product they intend to manufacture complies with the legal and customer requirements specifications. Consult with relevant industry bodies, independent consultants, and relevant government departments if unsure what to do.
Step 3: GMP practices
Once you have complied with statutory and legal requirements, you must comply with the requirements of interested parties. Interested parties can include customers, consumers, staff, auditing bodies, etc. You can then identify and implement operational standards that will assist in maintaining food safety practices in the business. These standards are known as Good Manufacturing practices (GMP’s). Good Manufacturing practices are put in place to minimise food contamination and sustain food safety in food handling premises and include: Cleaning and sanitising, waste management, pest control, personal hygiene, and cleanliness, to mention a few.
To ensure that your business effectively implements Good Manufacturing Practices, all personnel involved in your business should receive proper training. Training interventions on food safety is done to prevent food from being contaminated by any hazardous factors. Many reputable institutions are providing these various training interventions. You will, however, need to determine which training intervention is most relevant for yourself and your staff.
Step 4: HACCP Compliance
HACCP has to be implemented to further advance food safety in business or food handling premises. HACCP considers risks during food handling that may lead to food contamination. HACCP has 12 stages, with the first five known as preliminary stages of HACCP and the last seven known as the seven principles of HACCP. HACCP is a preventive risk-based approach that ensures that you put control measures for anticipated risks because of the nature of the process, the type of product handled, and the environment where the food is being handled. HACCP is already included under Requirement 2 of the BRC Issue 8 standard (Food Safety Plan / HACCP).
Step 5: Different types of training interventions required
There are different types of training interventions necessary for personnel in the food industry. Below are key food handlers and their training requirements:
HACCP Team should be a multidisciplinary team with members from different departments in the organisation. The HACCP team must have advanced HACPP knowledge and other specific knowledge of products, processes and associated hazards. Other training interventions that the HACCP team should have are a basic understanding of food safety, food defence and fraud, and allergen management.
General Staff should have training on personal hygiene and food hygiene and a basic understanding of food safety, occupational health and safety, fire management.
General Food Handlers must have a basic understanding of food safety, hazard critical control points, food fraud and defence, allergen management, personal hygiene, and good manufacturing practices.
Step 6: BRCGS Issue 8 fundamental requirements
There are 12 fundamental requirements of the BRC Global Standard, which are: Senior management commitment, The food safety / HACCP Plan, Internal Audits, Management of suppliers of raw materials, Corrective and preventative actions, Traceability, Layout, product flow and segregation, Housekeeping, Management of allergens, Control of operation, Labeling and pack control, and Training on raw material handling, preparation, processing, packing and storage areas. Audit findings on fundamental requirements may lead to the facility’s closure or loss of certification.
Step 7: BRC Issue 8 Gap Audit / Pre-audit assessment
Before approaching a certification body, you may choose to conduct a GAP Audit. A Gap Audit will assist you in identifying the loopholes in your current system before the external audit. This will need to be closed off before the certification. During the process of a gap audit, the internal auditor will review the currently employed management system and the activities thereof. The internal auditor will then make the organisation aware of any non-conformances that need to be closed off. The organisation must address all the non-conformities raised before a certification body is invited to audit. The Standard allows external consultants such as ASC Consultants, should you need assistance.
Step 8: How to apply for certification, and what will the Certification Body require?
Once you have determined you are ready, you may contact an accredited Certification Body. Ensure that the Certification Body (CB) is deemed competent by international accreditation bodies and approved to audit the BRC Global Standard. . Certification Bodies use various assessments to evaluate if applicants/ clients are compatible with the Standard they apply for.
Most certification bodies will require the following:
As an applicant, you will need to fill in a provided application form by the CB or a tailored proposal highlighting the needs of an organisation that the certification body may provide. The certification body will also need business information, nature of the process, documentation in place, size of the facility, number of workers, shift patterns, locations, product range, etc., to understand the organisation’s structure.
Step 9: BRC Global Standard Issue 8 Accredited Certification Bodies
In South Africa, the following bodies are accredited for BRC Certification:
- BSI Group South Africa
- DQS South Africa
- SGS South Africa
- Control Union South Africa
Steps 10: What to expect in a BRC Issue 8 audit?
The auditor collects information through visual observations, documentation perusal, interviews and practical testing. The auditor will review the documents, including procedures, policies, records, work instructions, and related information. They will ask you to confirm the information written in these documents and conduct interviews with relevant staff as the auditee. The auditor will spend substantial time in the production facility and conducting traceability exercises, including mass balances. In addition, the auditor will want to see product changeover if you do any and label control.
Once the auditor has gathered substantial evidence from information provided and all observations in the facility, they will decide if the organisations conform to the standard requirements. The organisation must ensure that all relevant personnel responsible for the food safety management system are available during the audit, i.e. Food safety team leader, senior management, translator (where necessary) and guides. All records and documentation of the FSMS must be available and verifiable.
Step 11: The Actual BRC Issue 8 Certification
It is essential to understand the audit process for manufacturing, processing and retail businesses under the scheme or businesses intending to get the certification.
Announced and unannounced audits
The audit can be done either announced or unannounced. Announced audits are done based on an agreement on the date between the site and the certification body. Unannounced audits are where the certification body visits a site without prior notice to the organisation. Organisations have an option to either have announced or unannounced audits. However, sites that have chosen the announced audit option must prepare themselves for at least one unannounced audit per audit cycle – this is not optional. For uncertified organisations, unannounced can only be done a year after applying for the certification.
There are three levels of non-conformity:
- Critical conformity indicates a critical failure to comply with food safety or legal issue or a major finding against a major against a fundamental clause.
- Major non-conformity indicates a substantial failure to meet the requirements of a ‘statement of intent ‘or any clause of the Standard. A situation identified based on available objective evidence raises significant doubt about the conformity of the product being supplied.
- Minor non-conformity indicates a clause has not been fully met, but based on objective evidence, the conformity of the product is not in doubt.
Dependable on the number and types of non-conformities found in an organisation during an audit process. For announced audits, the gradings are AA, A, B, C, D and unannounced: AA+, A+, B+, C+, D+. The grading from A- D ranges from High to low conformity, meaning a site with a certification grade AA+ meets the standard requirements at high conformity and one with a D grade at low conformity.
Step 12: Subsequent Annual BRC Issue 8 Certification audit
Unlike FSSC 22000, BRC is an annual certification. Audit frequencies are determined by the grading an organisation is certified with. The frequencies can be from 12 and 6 months, where sites with high conformity are audited every 12 months and those with low conformity or found with many minor non-conformity findings. At least 2 or 3 significant non-conformities are audited every six months. For example, a company will receive an AA/ AA+ grading (High conformity) when no critical and no major findings with five or fewer minor findings. And with this grading, it will only be audited every 12 months. A company will receive a D+ /D grading (Low conformity) when it has received 0 critical findings with 0 or 1 or 2 major and between 11 -30 minor findings. With this grading, the audit frequency will be every six months.
It is the responsibility of an organisation that auditing takes place at the determined frequency to maintain certification.
Step 13: How to maintain BRC certification?
To maintain the BRC certification, the organisation will first need to be consistent in meeting the standard requirements by ensuring conformity throughout. Also, the organisation will need to ensure that recertification audits take place as scheduled. Audit Findings must be closed off within the given period, and corrective actions must be submitted to the certification body during follow up process. This shows an organisation’s commitment to continually improving the food safety management system sustaining food safety.
Step 14: Which industries is BRC Issue 8 Certification applicable to?
The BRC standard applies to various industries, including food and beverage, feed manufacturing and processing, food packaging and event agents and brokers.
Step 15: Benefits of BRC Issue 8 Certification
Some of the benefits of BRC Certification are:
- International recognition as BRC is GFSI recognised
- Credible, independent assessment of the food safety and quality system
- When certified with the Standard, the organisation publicly appears on the BRC directory, allowing recognition
- Provides report and certification that can be accepted by customers in place of their audits, thus reducing time and costs