Category: Quality Management

BRC Issue 6 Guidance Part 4

Posted on November 1, 2011 by Richard Mallett

Continuing our guidance for those trying to upgrade their systems to be compliant with the new Issue 6 of the BRC Global Standard for Food Safety

The HACCP Plan

Hazard analysis

There is, on the whole, relatively little change in Issue 6 concerning the way that hazard analysis should be executed. Some of the same rules apply – assess hazard significance – you should use the principle of considering the credible probability of a hazard against the severity of outcome of that hazard to provide for a value for overall risk. The use of a simple mathematical matrix, something that has been seen in health and safety risk analysis for many years, can help. Especially if provided with real guidance as to what you mean by 1, or “Very Low Probability”, or 3 or “high degree of severity”. Don’t just wildly guess at this. Use historical information, industry data or experience of the HACCP Team.

What is different in this section (2.7.3) is that the Standard requires that where the control is achieved through existing pre-requisite programmes that you specifically state the pre-requisite (i.e. proper reference within the plan) and that you validate that pre-requisite. If you can’t validate cleaning and disinfection or control of suppliers of ingredients, materials and services as effective, then they can’t be the only control! It’s that simple. Make it easy – draw up a table of specified pre-requisite controls and add a column to show how you should validate. Depending on the control it could be through analytical data (e.g. swabs or water tests), servicing plans, certification or appropriateness of supplier (and this is not just food suppliers!), visual inspections and audits. There may be many more.

Critical Control Points

CCP’s should be defined, as they always have been, using a mixture of knowledge, common sense and tools such as the Codex Decision Tree. As a general rule of thumb, if a CCP cannot be assigned an reasonably easily measured critical limit or target, then check it again – is it a CCP? Or has a control point or pre-requisite crept in there?

As has always been the case, be specific in defining your monitoring system (who, when, using what and how), and your corrective action plan (how to bring the process under control, what to do with the product, how to stop it happening again). The key change now is the Standard’s requirement to assess any trends towards loss of control – a sensible step which means that action can be taken before you are writing off £100,000 or Euros of product.

Review

Finally section 2.14 forms an easily understood list of when to review the HACCP Plan. But you are falling short of this new Standard if you don’t (re)validate any changes to the plan that you have made as a result of review. There’s that word again – validate.

New – BRC Global Standard for Food Safety Issue 6 Update

Posted on August 15, 2011 by Richard Mallett

We are pleased to announce that we are offering a new course:

The 1 day BRC Global Standard for Food Safety Update course is recommended for those processors who are certificated to Issue 5 and are looking for guidance on how to prepare for Issue 6, against which they will be audited from January 2012. The course examines the change in audit protocol, Issue 6 being geared ever more towards GMP, and the change in clauses compared to Issue 5. The course is practical and includes best practice workshop sessions.

For those looking for more support in upgrading their systems to meet the requirements of the BRC Global Standard for Food Safety Issue 6 just give us a call. We can offer consulting support and training using our qualified and experienced BRC auditors.

China gets tough on food safety

Posted on August 10, 2011 by Richard Mallett

Some may say that, at last, and after the recent incidents that have damaged its food industry’s reputation with food incidents such as the melamine in powdered milk debacle, China is getting tough on food safety! Food Quality News.com reports that the food authorities have been inspecting 5.9 million businesses and that local police departments have been investigating 1200 criminal cases where non edible substances have been added deliberately to foodstuffs. This has been a source of good revenue income for the criminals, since some of the non edible additions in recent incidents have been demonstrated to fool food composition analytical instruments into thinking that foods are of a very high quality and consequently of higher value.

Does this Chinese crackdown have consequences for Western importers of food ingredients? In the long term, and subject to a successful campaign, it can only serve to improve safety of food produced from Chinese sourced ingredients. In the short term however the mere fact that this level of incidents has been seen through this recent investigation by the Chinese Authorities underlines most sincerely the importance of paying heed to the need to assure the quality of supplier and of supplied materials through a risk assessment process. This approach is mandatory in the GFSI Food Standards such as the BRC Global Standard for Food Safety. Ignore this important food safety control at your peril! And remember that, for now at least, the cheapest imports are not always the best in terms of food safety!

BRC Global Standard for Food Safety Issue 6

Posted on August 4, 2011 by Richard Mallett

Issue 6 is now published and audits will commence from January 2012.

The emphasis has shifted somewhat from the emphasis in Issue 5 to audit paperwork (systems and procedures) to more time spent on site assessment of GMP (Good Manufacturing Practice), including assessment of facility and structure, as well as the hygienic behaviour of food handlers. There is a reduction of some 25% of clauses, which have either been rolled together or taken out where they were deemed not to add benefit in terms of food safety and quality management.

We are finding that the approach is meeting with approval – some sites saying that, in many ways, it represents a welcome return to the grass roots level of food safety auditing.

More on the new issue can be found here - http://www.brcglobalstandards.com/standards/food/

Food Standards Agency 2009 Incident Report

Posted on July 2, 2010 by Richard Mallett

FSA Incidents Report 2009

MQM’s Midlands based consultant Paul Newman has looked into the Food Standards Agency ‘annual report of 2009’ – some interesting facts have emerged!

In 2009 the agency issued 91 alerts, of which 49 were allergen alerts.

In total the agency investigated over 1200 incidents including food contact packaging, pesticides and unauthorised ingredients. Download the full report here:-

http://www.food.gov.uk/multimedia/pdfs/incidents09.pdf

It is a key requirement for food safety accreditation such as SALSA  and BRC Global Standards for companies to have procedures in place for the management of incidents, product withdrawal and product recall. The management of allergens must also be addressed through risk assessment, taking into account the possibility of site allergen cross contamination, out of date supplier specifications,  incorrect labelling information and the potential incorrect use of the wrong label.

How do you ensure your food contact packaging is safe?

How do you avoid becoming of the 49 allergen alerts?

How do you find out about food safety issues?

Do you have an effective recall/withdrawal procedure in place and more importantly does it work?

Help is at hand as MQM Consulting have the experience to help you develop a system to help you ensure that if an incident happens you can confidently withdraw/recall the effected product.

MQM have recently opened a Birmingham office to serve the Midlands, North and beyond. This complements our South Eastern head quarters.

We specialise in Food safety systems such as BRC Global Standards & SALSA, Supplier auditing, food hygiene training and Microbiology.

If you are looking for consultancy help, please use the contact form and a consultant will be in touch

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