It contracted TAG to do the comparison of BRC Global Standard for Food Safety Issue 7 against the Preventative Controls for Human Food rule of the FDA Food Safety Modernization Act (FSMA).
BRC said sites and specifiers need to know where there are gaps, and how to best approach satisfying additional needs. BRC Version 7 is a Global Food Safety Initiative (GFSI) benchmarked scheme.
BRC work with TAG
John Kukoly, Americas Director of BRC Global Standards, said it chose to work with TAG as they had spoken at past conferences and were the best go to source for interpretation of FSMA.
“The BRC standard is heavily used in the US, specifiers and retail organisations use it for them and their supply chain and it was natural in taking that extra step to provide guidance. Whenever there are significant changes we provide services to meet requirements,” he told FoodQualityNews.
When asked about the non-alignments, Kukoly said: “It comes down to minor things, BRC is more risk-based or allows more flexibility The requirements in the Preventative Controls rule are more prescriptive such as in elements like record retention is two years and for BRC it is shelf life plus one year.”
TAG listed all the clauses of BRC - Version 7 and identified similar ones in the Preventive Controls Rule before doing a comparative analysis rating the BRC clause as “Exceeds”, “Comparable” or non- applicable to the similar Preventive Controls Rule one.
It concluded the systems and documentation required in BRC provide a foundation of information that can be used to complete analysis on the need for “Preventive Controls” in any operation.
“In some cases there will be additional documentation, verification validation required to the Preventive Control Rule, however, this should not require significant change to existing BRC based food safety programs.”
One difference is BRC sites have developed its plan following the CODEX HACCP approach whereas the one under the Preventive Controls Rule apply an approach referred to as HARPC (Hazard Analysis Risked-Based Preventive Controls).
Under a HARPC, Preventive Controls include in-process controls (referred as CCPs under HACCP) and plant environment controls (referred as prerequisite programs under HACCP).
To meet the Preventive Controls Rule, BRC certified sites may have to reassess prerequisite programs (e.g. Cleaning and Sanitation, Allergen Control) and represent them as “Preventive Controls”, said TAG.
To accompany the TAG matrix, BRC will be hosting live webinars, outlining what additional requirements are needed to fulfill the prescriptive elements within preventative controls not covered by BRC certification.
Food safety culture module
Meanwhile, BRC Global Standards will launch a voluntary module assessing food safety culture in June.
The module is being offered in partnership with Taylor Shannon International (TSI).
Using academic research, combined with TSI’s workplace research in food safety management, the module was developed to offer a way for manufacturers to receive a food safety culture assessment at the same time as their annual audit.
It is available to all sites choosing food safety certification with BRC Global Standards.
The Food Safety Culture Module is for manufacturers, specifiers and wider industry.
Culture is often considered a broad or blurry concept, but this assessment provides a way to evaluate it, identify areas for development, and measure the success of changes over time as a company’s culture evolves, said BRC.
It involves two questionnaires, one completed by employees, and the other by the external auditor following the audit. With answers measured across four categories: people, process, purpose and proactivity, the results provide manufacturers and specifiers with a tool to evaluate site culture, and a report with actionable findings.
BRC said food safety culture is a growing focus in the industry, and the module delivers analysis and insight into working culture; complementing existing programmes with understanding of a site’s culture and areas for action.
It is a way of measuring food safety and complements the existing standard, giving a more in-depth understanding of the site and its staff.
This visibility highlights areas for investment and facilitates improvement, providing the potential for a more food safety focused workforce, targeted training programmes, and greater operational insight, added BRC.
David Brackston, BRC Global Standards technical director, said: “We’ve seen considerable interest in the module when presenting it to BRC Global Standards sites, conference delegates, certification bodies, and auditors, and look forward to being the only GFSI-benchmarked scheme to offer this tool to the food safety industry.”