When BRC Issue 9 was published on August 1, 2022, there was time to procrastinate. After all, certification against Issue 9 standards only just began on Feb 1, 2023. But now that we’re well into 2023, and with a mandatory, unannounced BRC audit conducted every three years, Issue 9 is a high priority for all manufacturers hoping to pass or keep their BRC certification.
In this blog, we’ll cover the major changes between Issues 8 and 9 of the BRC. But first, let’s provide an overview of the BRC audit and what is BRC certification.
What changed between BRC Issue 8 and Issue 9?
a. Theme 1: Developing Food Safety Culture
b. Theme 2: Building Core Competencies
What is a BRC audit?
This is a surprisingly difficult concept to articulate. Initially created by the British Retail Consortium (BRC) nearly 25 years ago, the BRCGS Global Food Safety Standard is currently owned by the BRCGS, founded in 1996 as part of LGC ASSURE. The exact wording gets a bit debatable from attempts to balance branding changes with 25 years of recognition based on historical vernacular, so for the purposes of this blog, we’ll refer to the BRCGS Global Food Safety Standard as BRC audits and BRC certifications.
No matter what you call it, BRC certifications are a big deal. More than 29,000 sites across over 130 countries recognize BRC certifications, and they are accepted by 70% of the top 10 global retailers, 60% of the top 10 quick-service restaurants, and 50% of the top 25 manufacturers.
Key drivers for BRC certification include ensuring the production of safe food (80%), meeting the needs of existing customers (85%), staying competitive for growth in domestic (50%) and overseas (61%) markets, and responding to competitor certification (40%).
This widescale, international adoption of BRC audits and standards over the past decades has made BRC certifications more important than ever within the food manufacturing industry. With the release of Issue 9 in 2022, it’s essential for those wishing to obtain or keep their BRC certification to understand the changes to the BRC audit process.
What changed between BRC Issue 8 and Issue 9? The core themes have evolved.
There are two core themes in Issue 9: developing a food safety culture and building core competencies. While these have been present themes throughout much of the history of the BRC, Issue 9 scales up their significance to make them the driving forces behind BRC audit requirements.
BRCGS compliance audits are not reaudits. Instead, they focus on areas of concern. The information is then used to design a robust review of the controls, minimizing the potential for issues that damage brands and potentially harm consumers.
Let’s dive into the core themes of Issue 9 in detail.
Theme 1: Developing Food Safety Culture
There’s been a lot of talk about developing a food safety culture, but it’s not just talk anymore: Issue 8 saw the first introduction of Food Safety Culture as a specific requirement for the BRCGS. In Issue 9, BRCGS defines specific activities, timescales, and measurements to implement the requirements and improve food safety culture.
There’s a significant reason for this new, stronger emphasis on food safety culture. In the last three years before the publication of Issue 9, the top 10 of all registered non-conformances (NCs) included concerns related to Food Safety Culture Plans.
Issue 9 dives into the top 20 NCs, which account for nearly 30% of all NCs raised in global audits. In particular, the focus is on management to establish and continuously improve their organization’s food safety culture by significantly improving employee training and employee engagement, breaking down silos using influence, and developing measurable performance goals related to food safety culture.
Part of the inherent difficulty of trying to establish an exemplary approach to product safety is that ‘culture’ isn’t really tangible. It’s something that an organization is, rather than something an organization has. Culture is the ethos of an organization, and the values felt and demonstrated by people at all levels – irrespective of the size and complexity (or simplicity) of its sites worldwide.
When an organization has a strong product safety culture it can be assured that its employees and contractors will always do the right thing — even when they’re under pressure or when no one is actually watching.
So, how does an organization develop a food safety culture? That starts with building core competencies.
Theme 2: Building Core Competencies
When the BRCGS was updating Issue 8 to create what is now Issue 9, it performed an in-depth, industry-wide consultation to review emerging issues in the food industry and understand stakeholder requirements to address concerns regarding supply chains and associated risks to businesses.
The survey found that hygiene standards, allergen controls and contamination, traceability, food fraud, and labelling and claims were the topmost concerns for stakeholders.
BRCGS Issue 9 outlines how to build core competencies to address these concerns and significantly limit NCs — another 30% of which are attributed to a lack of fully developed core competencies. These competencies span from the very basics such as regularly monitoring, continually improving traceability, foreign body controls, and complaint handling, to more complex elements such as risk assessment and internal auditing.
BRCGS considers developing and recognizing core competencies to be the first step in improving an organization’s overall food safety culture on the path to acing your food safety audit.
Food Safety Issue 9 is all about the evolution of food safety best practice and continual improvement. We believe there’s more to be done across the industry to reduce the most common non-conformities.
Some of the areas that see the common re-occurrence of NCs in food safety audits are those related to core competencies and this currently stands at around 30% of all NCs. Our projections suggest there would be a significant reduction in the number of NCs if the fundamentals – the core competencies – were optimized by sites. That’s why we’ve strengthened some of those fundamentals in the new Standard.
BRC Issue 9 also stipulates that learning how to conduct internal quality audits, implement problem-solving methodologies such as root cause analysis, and corrective vs predictive actions are central to building core competencies that lead to a strong work safety culture and fewer NCs.
Cheat Sheet: Nine critical components of Issue 9, straight from the horse’s mouth.
All the requirements listed in Issue 9 for BRC audits take the two themes discussed above — developing a food safety culture and building core competencies — and turn them into actionable, requirements for BRC certification.
In our e-guide, The Ultimate Guide to BRC Audits and Certifications: Issue 9, SafetyChain identifies nine core topics addressed in Issue 9 for BRC certification. Below is a cheat sheet you can use to refer back to the exact wording from BRC Issue 9 when getting your plant ready for a BRC audit.
Senior Management Commitment: “The site’s senior management shall demonstrate that they are fully committed to the implementation of the requirements of the Global Standard Food Safety and to processes which facilitate continual improvement of food safety, quality management, and the site’s food safety and quality culture.”
Food Safety Plan (HACCP): “The company shall have a fully implemented and effective food safety plan incorporating the Codex Alimentarius HACCP principles.”
Food Safety & Quality Management: “The company’s processes and procedures to meet the requirements of this Standard shall be documented to allow effective, consistent application, facilitate training, and support due diligence in the production of a safe product.”
Site Standards: “The production site shall be of suitable size, location and construction, and be maintained to reduce the risk of contamination and facilitate the production of safe and legal finished products.”
Product Control: “Product design and development procedures shall be in place for new products or processes and any changes to product, packaging or manufacturing processes to ensure that safe and legal products are produced.”
Process Control: “The site shall operate to process specifications and work instructions procedures that ensure the production of confidently safe and legal product with the desired quality characteristics, in full compliance with the HACCP or food safety plan.”
Personnel: “The company shall ensure that all personnel performing work that affects product safety, legality, and quality are demonstrably competent to carry out their activity through training, work experience or qualification.”
Production Risk Zones: “The site shall be able to demonstrate that production facilities and controls are suitable to prevent pathogen contamination of products.”
Requirements for Trade Products: “The company shall operate procedures for approval of the last manufacturer or packer of food products to ensure that traded products are safe, legal and manufactured in accordance with any defined product specifications.”
In order to successfully prepare for your BRC audit, you’ll need to have a thorough understanding of these nine topics, what they entail, and best practices for implementation. Our free e-guide provides an in-depth review of these critical components, in addition to telling you what you can expect from the BRC audit and best practices for how to prepare for the BRC audit.