Position Statements

BRC Global Standards For Food Safety Issue 6

Position Statements
BRC Global Standard for Food Safety Issue 6

Contents
Introduction

Section 1 Senior Management Commitment

1.1.7 Presence of a copy of the Standard at the site

Section 2 Food Safety Plan - HACCP

2.7.3 - Validation of pre-requisites

Section 3 Food Safety and Quality Management System

Section 4 Site Standards

4.3.5 and 4.3.6 - Definition of the term - Physical Segregation

4.3.6 - The use of Single door ovens/smoke houses for the cooking of high risk products

4.8.5 - The use of boot wash facilities as an alternative to changing into captive footwear

4.10.3 - Metal Detection

4.10.3.1 Assessing the need for Metal Detection

4.10.3.3 Acceptability of Metal Detectors fitted with a stop belt rejection system

4.13 Pest control

Section 5 Product Control

Section 6 Process Control

Section 7 Personnel

7.4.1 - Protective clothing requirements for enclosed product areas

Appendix 1 - Decision Tree for Metal Detection

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Introduction
During the lifetime of a published Standard the BRC Technical committee may be asked to either review the wording of a clause in the Standard, provide an interpretation for a requirement or rule on the grading of non-conformity
against a clause. Any such judgements are defined in position statements. Position statements are binding on the
way that the audit and certification process shall be carried out and are an extension to the standard. This document
contains a summary of the position statements for the BRC Global Standard for Food Safety issue 6.

Section 1
Senior Management Commitment
1.1.7 Presence of a copy of the Standard at the site
The grading of non-conformities regarding availability of copies of the Global Standard for Food Safety will be allocated as follows:
Minor
Where a site is using a photocopy of the Standard (the Standard is a copyright protected document).
Major
Where the site cannot show that they have a copy of the Standard at all.
Note that Standards are available in hard copy (printed) or as a downloadable PDF which can be shared across
company intranet or printed once.
Approved carried forward from issue 5

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Section 2
Food Safety Plan HACCP
2.7.3 - Validation of pre-requisites
The standard requires that pre-requisite programmes used to control specific hazards are validated. Pre-requisite
programs typically cover a wide range of general environmental controls often with results which are not quantifiable. Whilst it is expected that the pre-requisite programmes are effective in achieving the level of controls required
to ensure food safety it is not a requirement that a documented validation of w pre-requisite programme is undertaken. The Standard does however require documented validation where the pre-requisite programme has been
designed to control a specific identified risk.
Examples could include
- Control of an allergen by cleaning of a piece of production equipment evidence is required that the cleaning
regime applied can effectively remove the presence of the allergen validation would typically include:
Confirmation that correct methods and cleaning chemicals have been identified (for example, in discussion with cleaning chemical manufacturers)
Visual assessment of the cleaned line (there is little point in proceeding with laboratory tests if the line
is visually not clean)
Swabs of surfaces and equipment
Laboratory testing of final products (for example the worst case scenario is normally to manufacture a
product that deliberately contains the allergen, clean the production line and test the first non-allergen
containing product produced
Control testing (i.e. testing product that deliberately contains the allergen).
Additional testing may be required, for example of cleaning rinse water
- Chilled storage conditions - The defined storage temperature shall be validated by reference to technical literature
confirming the control of growth of potential spoilage or food poisoning organisms identified as a risk with respect to
the product shelf life.

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Section 3
Food Safety and Quality Management System
No position statements

Section 4
Site Standards 4.3.5 and 4.3.6
Definition of the term - Physical Segregation
The purpose of physical segregation is to provide a self-contained area where naked high risk products are handled
after the microbiological kill step (e.g. thermal processing) until fully protected usually by means of packaging
The segregating barrier must be capable of preventing the risk of cross contamination from:
All people moving between the high-risk area and other areas except through designated changing areas (see
clause 4.8.5)
The movement of all equipment, utensils or materials into the high risk area except through designated ports
with sanitising controls in place.
Water or other liquids on the floor washing into the high risk area.
Air borne contaminants e.g. dust particles or water droplets.
The ideal barrier is a full wall separating the high risk area from other areas. Alternative partial walls or screens can
be accepted where the objectives above can be met.
In assessing the suitability of alternatives to a full wall a risk assessment must have been carried out and documented. This shall consider amongst other risks the potential risk created during cleaning in the lower risk area e.g.
water droplets from spray cleaning, surges of wash water on the floor, use of compressed air, controls of personnel.
Approved carried forward from issue 5

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4.3.6 - The use of Single door ovens/smoke houses for the cooking of high risk products.
High risk areas are expected to be self-contained, fully segregated areas. Best practice is that where there is a
cook step in the production of high risk products, the cooker becomes the transfer point into the high risk area via a
double door system i.e. the cooker is loaded in the low risk area and unloaded directly into the high risk area.
Whilst new cooker installations and new build sites incorporate double door cooking systems many existing plants
are equipped with single door cookers and have established risk based procedures for the loading and unloading of
the cookers to prevent cross contamination of cooked products.
The Standard will therefore accept the use of single door cooking systems where a thorough risk assessment has
been completed. Operating practices must be consistently operable, effective and prevent cross contamination of
cooked products.
The risk assessment must have considered and controlled potential risks from:
Cross over between cooked and raw products in the unloading area
Operators and their clothing e.g. operators handling cooked products who have previously worked with raw
products
Hand contamination resulting from touching surfaces such as common equipment, cooker control panels,
cooker door handles, equipment used for transferring product in and out of cookers.
Air borne contamination from low risk processes e.g. the loading and unloading area should be separate from
the main low risk processing area
The floor e.g. contamination of the wheels of trollies transferring cooked products to the high risk area.
When cooked products are unloaded from the cooker they must be moved immediately to a designated high risk
area meeting the requirements of the Standard.
The procedures in operation where single door cookers are in use will be assessed by the auditor to ensure they are
adequate, effective and understood by operators. The audit report shall describe the procedures in place to protect
the cooked products from contamination.
Approved 7/5/2012

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4.8.5 - The use of boot wash facilities as an alternative to changing into captive footwear
High risk areas need a higher level of environmental control than in high care areas due to the nature of the products handled. The use of clean footwear worn only in the high risk area and effective measures for changing into
such footwear is the preferred option to meet the requirements of the Standard.
The use of boot wash facilities at the entrance to a high risk area will be acceptable where this is managed and
validated to effectively prevent the introduction of pathogens. The site shall have undertaken a risk assessment to
identify the suitability of the boot wash facilities and controls to manage the effective sanitation of footwear. The
controls shall have been validated by microbiological swabbing of footwear and the floors and drains in the high risk
area, to demonstrate the absence of Listeria species.
For such controls to be effective it would be expected that this includes the following:
The footwear shall be company issued and of a design which is easily cleaned i.e. smooth upper surfaces, cleats on
soles shall be sufficiently spaced so as not to trap dirt which may not easily be removed by boot wash equipment.
Consideration of the potential for gross contamination of boots prior to boot washing i.e. the footwear shall not be
worn outside of the facility or in low risk processing areas prior to entering the high risk area.
The boot wash equipment shall be suitably designed, well maintained and demonstrably effective to clean and
sanitise the foot wear.
The minimum cleaning time and levels of detergent and sanitiser used shall be determined, documented and controlled to ensure effective cleaning of footwear.
Records shall be maintained of detergent/sanitiser checks, and effectiveness of cleaning of the boot wash facilities.
Approved 7/5/2012

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4.10.3 - Metal Detection

4.10.3.1 Assessing the need for Metal Detection
Issue 6 of the Standard assumes that metal detection will be used to protect products unless as effective alternative
controls are in place. A risk assessment process may be undertaken to justify circumstances where metal detectors
are not required. The BRC have developed a decision tree to provide guidance on defining where metal detectors
would be required and circumstances where they may not. This applies to products packed in non-metallic containers. The absence of metal detection equipment cannot be justified on the basis of cost.
In all circumstances where products are manufactured to a customers specification, sites must comply with any
customer requirement for metal detection of their products.
Where metal detection is not used and the risk assessment has been accepted by the auditor this will be noted in
the audit report and the justification and alternative controls described.
The process flow diagram (see appendix 1) provides guidance on defining the need for metal detection.
Approved 7/5/2012

4.10.3.3 Acceptability of Metal Detectors fitted with a stop belt rejection system
There have been a number of concerns raised regarding restrictions on the use of stop belt type rejection systems
for metal detectors. This type of reject system is considered by some to present a greater risk of rejected product
being re-introduced into the process flow than automatic rejection systems where the product is positively rejected
into a locked container.
The objective of requirement 4.10.3.3 is to ensure that products identified by the detector as containing metal are
effectively removed. It has been agreed that stop belt style metal detector rejection systems will continue to be
acceptable for all pack types where additional controls are in place to ensure the effective removal and isolation
of products identified as potentially containing metal. Typically this will include the use of a container into which
rejected product is placed, which is secured such that only authorised staff can remove the product, similar to the
locked box system used for automatic rejection systems.
The following additional controls should be considered to ensure that rejected product is effectively segregated and
managed.
The removal of affected product should be restricted to trained, authorised staff, this may be supported by
restricting access to the product once the belt has stopped e.g. by using locked line cover and authorised key
holders.
Rejected product may be marked, destroyed or have the label removed to reduce the risk of re-introduction to
the process flow.
The line restart should be restricted to designated personnel who must verify the location of the rejected product prior to restart (i.e. control panel / button for restart is secure, locked or security coded).
A record made of each occasion when the belt stops in response to the detection of metal in a product.
Approved 7/5/2012
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4.13 Pest control

Guidance was requested to ensure consistency in the grading of non-conformities where evidence of pests was
identified at an audit. The following criteria should be used:
Minor
Where slight evidence of an infestation is found resulting from a casual intruder - i.e. instances of pest ingress of a
single occasion or low numbers occur and are appropriately investigated and actioned.
Major
Any established infestation i.e. where large numbers of pests are breeding within the building or site over a period
of time. This implies a failure of the pest control and inspection measures and should be regarded as a loss of control and lack of maintenance.
Critical
Wherever the presence of an established infestation puts product or ingredients at risk of contamination.
Approved carried forward from issue 5

Section 5 Product Control

No position statements

Section 6 Process Control

No position statements

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Section 7
Personnel
7.4.1 - Protective clothing requirements for enclosed product areas.
Issue 6 requires sites to define different risk zones based on the vulnerability of the products to contamination. The intent of
this is to ensure appropriate focus on the environmental risks to the product and an increased environmental management
of high care and high risk areas. The process also identifies areas and in some cases industries where the product is fully
enclosed and has no or very little risk of contamination from the factory environment during normal production.
The requirement to wear full company issued protective clothing would not be an absolute requirement where all of the
following criteria apply

all products are fully enclosed

the product would, if it were not fully enclosed, be classed as a low risk product
the area is separate from areas containing open product
staff do not need to pass through open product areas to access the area.

The wearing of a company uniform is preferred. Where personal clothing is allowed sites must provide guidance on the
standards of clothing which will be acceptable.
Wherever product lines are entered, for instance adjustments at the filler, protective clothing and hair coverings must be
worn.
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Appendix 1 - Decision Tree for Metal Detection

Where the product is packed into metal packaging an effective alternative test method must
be developed, for example X-ray or metal detecting the product at the stage prior to packing
or the use of magnets and product inspection.

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