Unpacking the BRCGS Standard for Food Safety Issue 9

Adopted by 30,000 certified food manufacturers and suppliers in over 130 countries around the world, the BRCGS aims to standardise quality, safety, and operational criteria to ensure that manufacturers fulfil their legal obligations and provide protection for the end consumer. It was first published in 1998, as British retailers sought to raise the bar of industry hygiene and compliance standards. While it is not a legal requirement in the UK, most large food retail brands and foodservice companies demand that their suppliers are BRCGS-certified. 

BRCGS Issue 9 was released four years on from its predecessor, BRCGS Issue 8, which was published on August 1st, 2018. The key changes between these two issues are informed by the most frequently occurring non-conformities throughout 2021. 

The below table lists eight non-conformities in order of commonality:

Continue reading for guidance on how food businesses can implement strategies, policies, and procedures to get ahead of the food compliance curve before Issue 9 becomes fully auditable from February 1st, 2023.

BRCGS Issue 9 has placed a strong onus on the role of senior management in committing to continual improvement. As seen in Clause 1.1.2, BRCGS Issue 9 contains a far more tangible focus on the power of top-down company culture in perpetuating food safety standards.  

Clause 1.1.2 

Clause 1.1 (‘Senior Management Commitment and Continual Improvement’) is one of the BRCGS’s twelve ‘fundamental’ requirements to achieve certification against the new issue. Within this, Clause 1.1.2 provides a specific list of activity design features needed to enact this positive culture change.  

These include activities such as open commnication on product safety, training, feedback from employees, required behaviours to sustain and improve product safety processes, a plan indicating how these activities will be carried out, and a review of their effectivness.

Of particular interest are the specification for employee feedback – an invaluable, if sometimes overlooked activity – as well as an action plan involving processes, measurements, and timelines. As Issue 8 made no reference to review, or frequency of review, requiring this plan to be reviewed and updated on a yearly basis is also new to BRCGS Issue 9.  

Given its position as the first and third most common type of non-conformity on the above list, equipment compliance is logically one of the predominant focal points of BRCGS Issue 9. This can be seen across the range of clauses explained below.  

Clause 4.6.1 

In Clause 4.6.1, there is far more detailed guidance on sites’ responsibilities regarding equipment management than in Issue 8. This includes a documented purchase specification, as well as any relevant legislation, food contact approved requirements, and details of intended use of the equipment.

To this end, it will be invaluable to have a reliable place to keep track of production and hygiene utensils used on site, equipment verification schedules, calibration due dates, and warranty lengths. An example is our Calibration, Audit and Product Certificate Portal, which allows users to… 

• View and download compliance certificates 
• Manage technical equipment 
• Track calibration due dates 
• Download calibration certificates 

 …therefore maintaining compliance with the final part of Clause 4.6.1, which states that ‘suppliers should provide evidence that the equipment meets these site requirements prior to supply’.  

Clause 4.6.2 

A common cause of audit non-conformances is contamination – whether it be microbiological, allergenic, or foreign body. Often, these various forms of contamination take hold in the hidden crevices and small parts of food manufacturing or cleaning equipment, hence BRCGS Issue 9’s requirement for ‘the use of correct seals, impervious surfaces, or smooth welds and joints’.  

In light of this, it is strongly recommended that equipment is chosen based on risk minimisation. Shadow boards offer a fitting example. As an increasingly popular hygiene management and storage solution across the food industry, shadow boards can be constructed to minimise cross-contamination – but only when designed with food safety in mind.  

Specifically, this means minimal welds, joints, or hidden crevices behind the board. One solution is a through-board hook system, which keeps shadow boards hygienic, easy to clean, and free of any foreign body risks. Another is a magnetic mounting option, which allows for convenient and regular cleaning behind the board.  

Clause 4.9.6.2 

This particular clause emphasises the pressing need for portable handheld equipment to be designed with a focus on prevention. At factory or production sites, pens are the most commonly found handheld utensil, and are consequently the cause of many foreign body contamination non-conformities due to their clips, springs, and other small, breakable parts.  

Practices a site may consider reviewing include the exclusion of non-approved items and restriction of site-issued equipment. Furthermore, sites should ensure any such portable handheld equipment items are designed without small external parts, as well as being detectable by detection equipment (metal detectors, X-ray etc), or are only used in areas where contamination is specifically prevented.

Organisations with the highest priority on compliance mandate the use of pens which, first and foremost, prevent foreign body contamination (through shatterproof pens made of durable materials, with no metal springs), and – as a last resort – are detectable by x-rays and metal detectors.  

Ensuring a safe, consistent, and contaminant-free product is the backbone of any food business. While product control doesn’t tend to rank high on lists of most frequent non-conformances, when it does appear, it often has disastrous consequences, both to the safety of consumers, and the reputation of brands.   

Clause 5.3.4 

Clause 5.3 (‘Management of Allergens’) is another of the BRCGS’s twelve ‘fundamental’ requirements to achieve certification against the new issue. Within this, Clause 5.3.4 outlines various procedures for carrying out effective management of allergenic materials.  

Broadly, this means minimising the risk of allergen contamination and cross-contact by having a system or process for managing allergenic materials, and which as a baseline meets legal labelling requirements.

To a greater extent, this clause suggests segregating allergen-containing materials during storage, processing, and packing, as well as having on-site a set of separated, identified utensils for dealing with these materials.  

What is the best way of identifying these utensils by allergen?  

A compelling solution is colour-coding. Whether it be production utensils or brushware; squeegees or storage containers, using sharp, vibrant colours to clearly delineate equipment by its purpose is a reliable way of preventing allergenic cross-contamination. With stronger colours, compliance failures can be easily spotted, which makes the management of allergen segregation easier.  

See the below table for how colour-coded equipment might be implemented.   

As another of the BRCGS’s new ‘fundamental’ requirements, process control is essential for ensuring full compliance with a HACCP (Hazard Analysis & Critical Control Points) or food safety plan. For maximum effectiveness, it usually involves documentation and systematisation of production procedures to optimise product quality, safety, and legality.  

Clause 6.1.3  

In Clause 6.1.3, the standard outlines the importance of process monitoring for ensuring products are manufactured within the required process specification. In relation to this, wireless monitoring systems are proven to provide highly accurate, real-time temperature data, support food safety compliance, and cut costs of loading refrigerated food transportation. Clause 6.1.3 includes temperature, time, pressure, and chemical properties as some examples of key parameters to measure. Leading wireless monitoring systems will typically have the capability to also measure:

• Humidity  
• CO2 
• Energy 
• Concentration
• Door contact 
• Data from advanced plant/engineering sensors 

For more information, watch clips from a webinar we hosted recently on the factors to consider when choosing a wireless monitoring system. Drawing on decades of industry experience, our team dissect nine relevant factors – from the system’s hardware to its data storage access.  

Clause 6.1.4 

Clause 6.1.4 directly addresses another of these factors: the type of alarm used by monitoring systems. A good tip is to look out for the systems that issue alarms by the widest range of mediums, so you can adapt the system to best suit your site or team.

Why?  

In the event of an alarm – whether it be a product quality issue or a malfunctioning chiller unit – speedy and decisive action is essential. This cannot happen without being instantly notified about the situation, which highlights the urgent need for alarms to be sent by a variety of methods (e.g. phone call, SMS, email) rather than riskily depending on just one. Clause 6.1.4 also includes a requirement to routinely check that the alarm and alert system is working correctly.

Clause 6.4.2 

Instrumentation devices which measure a specific parameter – the most common being temperature-measuring probe thermometers – must in turn be checked for accuracy and recalibrated.  

BRCGS Issue 9 strongly emphasises the need for this checking process to adhere to a recognised national or international standard. In the UK, the most credible recognised standard is a UKAS calibration certificate, which distinguishes the industry’s leading measuring devices from the satisfactory.  

Consider re-evaluating outdated approaches to accuracy checks of measuring devices. This is particularly relevant to thermometers; many companies still use the traditional ice or boiling water check, without realising that there are far more innovative methods which remove all subjectivity from checks, and save quality assurance teams hours each month.  

This article has deconstructed the BRCCG’s latest standard in food safety into four key areas and nine standout clauses, explaining their ramifications – and providing tangible solutions – for food businesses.  

If you’d like to take a look at the BRCGS Food Safety Issue 9 in full, you can head to this webpage and select ‘Free PDF’ on the right-hand side for a free copy.

References 

BRCGS (2022a) Global Standard Food Safety Issue 9. Available at: https://www.brcgs.com/our-standards/food-safety/issue-9-revision/. 

BRCGS (2022b) Food Safety Issue 9 Interpretation Guideline. Available as purchase.  

High Speed Training (2020) Our Guide to Understanding BRCGS. Available at: https://www.highspeedtraining.co.uk/hub/understanding-brcgs/.  

Techni-K (2022) BRCGS Food Safety Issue 9. Available at: https://techni-k.co.uk/brcgs-food-safety/brcgs-food-safety-issue-9/.