Global Standard for Food Safety

Issue 5

KLH Page 1 of 4 6.6.08

Frequently Asked Questions

001 Can the certificate be extended beyond the expiry date, for example where an audit has been booked
to take place.
No the certificate is valid for 6 or 12 months as specified and cannot be extended.
Customers of the company should be advised if a company goes out of certification, they may accept
that the company is uncertificated for a designated timeframe due to specified circumstances.

002 I have developed a new product is this covered under my existing certificate?
Certification relates to the audit of the process of a product, if new product development designs a
product which is basically produced in the same manner but uses different ingredients then this is not an
extension to scope. If new processes, equipment or technology are used which are significantly different
and would require a new HACCP plan for example, then this would require another audit visit from the
certification body.

003 At our audit we obtained a major non-conformity against clause 1.11 , as this is a subclause of a
fundamental clause does this mean we get a grade D.
No the awarding of a major non-conformity must be against the statement of intent of a fundamental
clause highlighting that there is a substantial failure against the principles of the clause for a grade D to
be awarded. You would however, also get a grade D if you had 3 or more major non-conformities, 2 with
> 21 minors or 0-1 with > 31 minors.

004 Can a minor non-conformity be awarded against the statement of intent.
Yes, an example may be against the statement of intent for clause 4.9 where the standard of hygiene of
an area is not maintained to an appropriate level.

005 I have had a BRC audit and am not happy with the non-conformities identified or the grade awarded
what can I do?
The company has the right to appeal the certification decision made by the certification body which
should be made in writing to the certification body within 7 days of the decision. The certification body
shall give a full written response within 30 days following a full and thorough investigation.
The company also has the option to contact the BRC if resolution cannot be attained by the two parties.

006 I have audited one of my suppliers who are BRC certificated and found procedures and practices not
to be in line with the BRC audit report, what can I do?
The BRC would like to receive feedback on sites who do not continue to apply the principles and criteria
of the Global Standard to which they are certified. The BRC will require a documented report of the
reasons for the complaint and will require a full investigation of the issues raised by the certification
body.

007 Clause 1.12 Who are defined as the most senior production or operations manager on site to
attend meetings?
The objective behind this requirement is to ensure that the conclusions of the audit and any actions
required to correct non-conformities are effectively understood, agreed and there is the authority to
ensure these are carried out. Whilst it may be the case that the most senior personnel may be absent on
the day of the audit, there will always be someone on site that will be responsible for the daily running of
the site.


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008 What is defined as a current issue of the Standard as required by clause 1.10
An original issue of the Global Standard for Food Safety Issue 5 must be available on site. These are
available from www.brcbookshop.com in English and various other languages, in print and as a pdf
(where usage rules apply). This must not be a photocopy and should be made available to all relevant
staff to ensure they understand The Standards requirements.

009 How many people should make up the HACCP food safety team and what training do they require.
The number of people on the HACCP food safety team should be pertinent to the size and structure of
the company as the team should include representatives of each department with responsibility for
operation of The Standard. It should not be too large and note that 1 person does not constitute a
team.
It would be expected that participants should have appropriate training, with particular regard to the
team leader. This may be achieved through external, industry recognised training specific to HACCP but
may equally be achieved by a good quality internal course. At the audit, the competency and
understanding of the HACCP team would be assessed as well as the quality of the resultant HACCP plan.
Note that if the HACCP plan has been prepared with the help of an external consultant, internal staff
must still be fully conversant with the plan, principles and practices associated with it. Records need also
to demonstrate the training of the external consultant in HACCP principles.

010 What documentation do you need to keep for HACCP
You need to ensure that the information on which the HACCP plan is based is referenced and available
on request by the auditor. This may include published literature on known hazards, codes of practice or
legislation. You need to keep records of HACCP team meetings and the decisions which were reached.
You should have documents to demonstrate how the decisions for establishing CCPs were reached.

011 We are a small company with many customers what do we need to do for the requirements on
customer focus (clause 3.4)?
The review of customer requirements needs to be planned and where appropriate undertaken on a
regular pre-determined frequency which will vary according to individual customer requirements. When
dealing with large customers such as a retailer, it is likely that they will determine the frequency for a
formal contract review meeting or the requirement for generation of monthly reports, details key
performance indicators.
The level of communication should be based on customer requirements and it is accepted that smaller
companies may communicate in a less formal way that is not documented but fulfils the customer
requirements by regular telephone contact for example, and links to other procedures such as
complaints analysis. Communication evidence maybe provided via email for example.

012 What training do internal auditors have to have completed and what does independent from
audited department mean (clause 3.5.2)?
Internal auditors should be able to show via training records that they have received formal training
either via attendance of an external course or via training within the company. Training should cover the
planning and scheduling of internal audits, preparing reports and follow up of audit findings.
The objective behind the requirement for auditors to be independent of the area being audited is to
ensure that the audit is rigorous and thorough and is not influenced by the work which may need to be
carried out to effect corrections and improvements. Auditors should not be biased or influenced.
External auditors may need to be used where there are insufficient internal resources.

013 How accurate does the quantity check / mass balance on traceability need to be (clause 3.9.2)
It is unlikely that the mass balance check will be able to account for all materials to an accuracy of 100%,
however, the company needs to justify the discrepancies and demonstrate they understand the nature
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of the variance through dehydration of fresh ingredients, typical wastage on equipment and portion
variances for example. The principle of this requirement is to ensure that the traceability system is
effective and mass balance is a key measure of this workability and highlights areas for improvement.

014 What is the registration that clause 4.2.6 requires?
This clause relates to legal requirements to register premises with enforcement authorities pertinent to
food safety and quality and includes as examples the requirement for food businesses to be registered
with the local authority in the UK under Regulation (EC) No. 852/2004 on the Hygiene of Foodstuffs,
Article 6(2) or that food premises in the USA must be registered with the US treasury under the 'Public
Health Security and Bioterrorism Preparedness and Response Act of 2002'.
It does NOT include other legal registrations related to personnel health and safety such as fire
regulations or employment law as this is outside the scope of the Standard.

015 Clause 4.5.3 requires equipment to be suitable for food use where appropriate I cant obtain a
certificate of conformity for machinery weve had on site for years, what can I do?
The requirement is designed to ensure that manufacturers are complying with relevant legislation, for
example the EU Materials and articles intended to come into contact with food Regulation 1935/2004
and that such materials do not constitute a hazard to food. General principles should be to use approved
suppliers known to supply products designed for food use. All new food contact equipment should be
purchased with a certificate of conformity or specification detailing its suitability for food use, this may
also be confirmed by a symbol or label on the product. Where this evidence is not available, then a risk
assessment should be carried out to justify its use and determine that it is not a food safety risk. The risk
assessment should consider factors such as , the nature of the food contact surface material and its
known characteristics e.g. stainless steel is known to be a food grade material; length of contact time
with the food and the nature of the food and its potential for contamination e.g. fatty foods may be
more at risk from migration of contaminants from a plastic container for example. Further clarification
should be sought e.g. from equipment manufacturer or testing such as migration tests where required.

016 To meet the requirements of clause 4.6.6 that contractors shall be under the supervision of a
nominated person does that mean they have to be accompanied at all times on site?
Not necessarily the objective of this requirement is to ensure that any contractor on site is made aware
of relevant site rules such as personnel hygiene and adheres to these rules. That good practice is
adhered to that the site contact is aware that they have arrived on site, have completed the job to the
companys satisfaction and that it has been checked and approved before the contractor leaves site.

017 Clause 4.7.4 and 4.75 dictates the requirements for handwashing in production and in toilets.
Does this mean that roller towels cant now be used?
This requirements clearly specifies what can and cant be used and includes that roller towels cannot be
used at handwashing stations in production areas as they are not single use; they can however, be used
in toilets but only if they are not the only facilities provided before re-entering production.

018 I handle nuts on my site, but add a statement on my packaging stating it cannot be guaranteed that
this product is free of nut traces do I have to comply with any of the requirements of section 5.2?
Yes, you still have to carry out a risk assessment and consider what steps are appropriate for your
company to minimise the potential for cross contamination.

019 I do not handle any allergen containing materials on my site, but I am not making any nut free
claims, are the clauses of 5.2 applicable?
The following clauses would still be applicable 5.2.1.1, 5.2.1.2, 5.2.1.5 and 5.2.1.7



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020 Is it correct that I have to have a metal detector?
The Standard requires that a foreign body detector eg x-ray machine or metal detector be in place unless
it can be justified as not necessary. This shall identify that procedures are in place that control potential
foreign body contamination to the same level as detection facilities and for example may include where
finished product liquids are filtered or dry materials are sieved.

021 What is meant by shelf life tests shall validate the minimum shelf life period indicated on the
product in clause 5.5.1.4?
This requirement is trying to reflect that a margin of safety is included within any products stated shelf
life and that the use by or best before date labelled on the product would never be the maximum life.
Therefore shelf life trials should extend beyond the stated life.

022 7.5 Is there justification for not wearing protective clothing
Protective clothing includes uniforms, overalls, head coverings such as hats and hair nets, shoes and
boots, aprons and gloves whether disposable or washable. Protective clothing is that which protects the
product from contamination, however, the risk assessment shall consider potential contamination from
foreign bodies such as buttons and fibres from clothing as well as hair and therefore protective clothing
is likely to be required and it would rarely be expected to see any suitable justification for exception.

023 Where would home laundering be acceptable? Clause 7.5.4
Home laundering may be deemed acceptable in low risk operations such as produce packing where there
is no microbiological risk. This needs to be controlled by written instructions to staff to include:
How garments are to be washed (temperature, detergent, avoiding of items to be washed
together, drying instructions).
Employees must be provided with some suitable means to safely transport washed garments
from home to the workplace. (ie sealable plastic bags, or similar).
There must be a defined responsibility within the company for monitoring the effectiveness of
the system. This may typically be achieved by visual inspection.
There must be a procedure and system for effectively dealing with any case where employees
are unable to perform self-laundry, either through lack of diligence or facilities. This system must
be capable of being brought into immediate effect once a problem has been identified.

024 What would you expect to see for a risk assessment, since the Standard now bases many of the
requirements on this.?
Some sort of documentation would be expected to be seen as evidence of the thought process and
conclusions made as to the risks to products. However, the principles and objectives behind 'risk
assessment' are to ensure that the company has considered the issues pertinent to the requirements
and can justify the reasons for their policy or procedures, responding to the challenge by an auditor. In
some instances it would be appropriate to have a detailed document (along the principles of a HACCP
plan) showing those considerations, an example may be the risk rating for suppliers and the subsequent
approval process or the risks to product from physical contamination which would be included within the
HACCP plan. However, other requirements such as the policy on where beard snoods shall be worn could
be evidenced in other ways such as a documented policy, to the understanding by staff and the
reasoning behind this policy. This would include considerations of best practice within the industry and
be open to challenged by an auditor. The need for a documented risk assessment would be particularly
pertinent where you have decided not to adopt procedures for a particular requirement e.g. not wearing
beard snoods in a particular area.