BRC Food Safety Management System Implementation Workbook

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We have written this workbook to assist in the implementation of your BRC food safety management system. The workbook is divided into 8 steps that are designed to assist you in implementing your food safety management system effectively: Step One: Introduction to the BRC Global Standard for Food Safety Step Two: Assessment of Prerequisites Step Three: Senior Management Implementation Step Four: Food Safety Plan/HACCP Implementation Step Five: Food Safety Quality Management System Step Six: BRC Implementation & Training Step Seven: Internal Auditing Training & Checklists Step Eight: Final Steps to BRC Certification 1

The Workbook guides you the process of implementing our BRC Food Safety Quality Management System, which is an ideal package for Food Manufacturers looking to meet British Retail Consortium Food Standard 2015 (Issue 7) for Food Safety Quality Management Systems. This comprehensive system contains: Comprehensive Procedures Manual FSMS Record Templates HACCP Manual containing the HACCP Calculator Laboratory Quality Manual Training Modules and Exams BRC Standard for Food Safety Training Module HACCP Training Internal Audit Training and Checklists BRC Global Standard for Food Safety Gap Analysis Checklists Verification and Validation Record Templates Free online support via e-mail The package includes a comprehensive free implementation workbook to assist in the implementation of our BRC food safety management system. As well as being updated this BRC Implementation Package includes additional management tools to help you achieve BRC certification: Unannounced Audit Guidance Allergen Management Module & Risk Assessment Tool Supplier Risk Assessment Tool Product Development Module BRC Risk Assessment Tool Complaint Management Guidelines & Analyser Hygiene Inspection Training Verification Schedule Risk Assessment Tool and Template As a preliminary to Step 1 we recommend that the you purchase a copy of the current issue of the BRC Global Standard for Food Safety 2

Step One: Introduction to the BRC Global Standard for Food Safety This 45 minute comprehensive illustrated and interactive PowerPoint training module presentation will introduce the BRC Global Standard for Food Safety to the management team and explain how to start the process of implementing a BRC compliant Food Safety Management System. 3

Step Two: Assessment of Prerequisites At this stage an assessment should be made by the most senior technical member of the management team to decide if Site Prerequisite Standards within the facility meet the Food Safety Requirements in Sections 4 to 7 of the BRC Standard. The nominated manager should read through the requirements in Section 4 to 7 of the BRC Global Standard for Food Safety and assess for compliance using the checklist below to record their findings. BRC Global Standard For Food Safety Issue 7 2015 Section 4 Site Standards Relevant Documentation Requirements Compliant Section 4 Site Standards Yes No Comments 4.1 External Standards The production site shall be of suitable size, location, construction and design 4.1.1 4.1.2 Local activities and environment External areas shall be maintained 4.1.3 Building fabric maintained 4.2 Security systems 4

Step 2: Corrective Actions from Assessment of Prerequisites The non-compliances identified in the assessment of compliance with Sections 4-7 of the BRC Global Standard for Food Safety should be logged using the form below and used as input for Step Three: Senior Management Implementation. In Step 3 the appropriate corrective action should be allocated by the Senior Management Team and a corrective action plan formulated. Date BRC Standard Section Step 2: Corrective Actions from Assessment of Prerequisites Details of Non Conformance Identified by: Corrective Action Required Responsibility Target completion Date Date Completed 47

Step Three: Senior Management Implementation A Senior Management Implementation checklist is provided that establishes your Food Safety Management System fundamentals including Food Safety Policies and Objectives. The checklist guides Senior Management: in planning the establishment of the FSMS in providing adequate support to establish the FSMS in ensuring there is adequate infrastructure and work environment in allocating responsibility and authority This stage requires the Senior Management to meet and establish the foundations for the Food Safety Management System: Formulating a checklist of Customer, Regulatory, Statutory and other relevant Food Safety requirements Decide which Food Safety requirements the company should address and develop relevant policies. Based on the Food Safety Policy Management Policies establish Food Safety Objectives Define the scope and boundaries of the FSMS Plan the establishment of the FSMS using the project planner Provide adequate support to establish the FSMS Ensure there is adequate infrastructure and work environment and develop a Corrective Action Plan to rectify Prerequisite shortfalls Allocate responsibility and authority Assess, plan and establish appropriate internal and external communication (including the food chain) channels As a decision has already been made to implement a system compliant with the BRC Global Standard for Food Safety, the Senior Management meeting should also consider the requirements of the Standard which are summarised below and should be read direct from the Standard: 48

Section 1 Senior Management Commitment Fundamental requirement - Senior management need to demonstrate they are fully committed to the implementation of the food safety and quality management system, meeting the requirements of the Global Standard for Food Safety and driving continual improvement. 1.1 Relevant Documentation Requirements Section 1 Senior Management Commitment Senior Management Commitment And Continual Improvement 1.1.1 Documented Food Safety Policy 1.1.2 Documented Food Safety Objectives 1.1.3 Management Review 1.1.4 Meeting Program 1.1.5 Human And Financial Resources 1.1.6 Informed Of All Relevant Legislative, Scientific 1.1.7 Current, Original Copy Of The Standard 1.1.8 Announced recertification audits 1.1.9 1.1.10 1.2 1.2.1 Organisation Chart Attendance most senior production or operations manager Non- Conformities Identified At Previous Audit addressed Organisational Structure, Responsibilities And Management Authority 1.2.2 Employees Are Aware Of Responsibilities A meeting should now be co-ordinated involving all the Senior Management Team. 49

Senior Management FSMS Implementation Meeting Date Time Venue Agenda 1. Formulating a checklist of Customer, Regulatory, Statutory and other relevant Food Safety requirements 2. Decide which Food Safety requirements the company should address and develop relevant policies. 3. Based on the Food Safety Policy Management Policies establish Food Safety Objectives 4. Define the scope and boundaries of the FSMS 5. Plan the establishment of the FSMS using the project planner 6. Provide adequate support to establish the FSMS 7. Ensure there is adequate infrastructure and work environment 8. Allocate responsibility and authority 9. Assess, plan and establish appropriate internal and external communication (including the food chain) channels Attendees: Senior Management Team Job Title Name Role in Team Managing Director Site Director Operations Manager Technical Manager Planning Manager Distribution Manager Maintenance Manager Finance Manager Human Resources Manager Chairman Deputy Chair Operations Reporting Food Safety and Quality Reporting Management Representative Planning and Capacity Reporting Distribution Reporting Services and Engineering Provision Financial Reporting Resource reporting 50

Senior Management FSMS Implementation Checklist The Senior Management FSMS Implementation Meeting should follow the guidelines of the Senior Management Implementation Checklist: Senior management formulate a checklist of Customer, Regulatory, Statutory and other relevant Food Safety requirements Customer/Regulatory/Statutory/Other Record Details Action (i) XYZ Customer Requires this BRC Global Standard for Food Safety 2015 Food Regulations Senior Management decides which Food Safety requirements the company should address and develop relevant policies. Requirement Policy Details Action (ii) 51

Senior Management establish and provide Infrastructure and Work Environment Requirements Senior Management provides the Infrastructure and Work Environment required to establish the Food Safety Management System. Having assessed the resources required to implement, maintain, and improve the Food Safety Management System, these resources should be provided including: - Prerequisite requirements identified in Step 2 - Skilled Personnel - Suitable materials - Suitable equipment - Appropriate Hardware and Software - Infrastructure - Information - Finances - Audit resource - Training resource Senior management ensure there is adequate infrastructure, work environment & compliance with prerequisite requirements Infrastructure/Work environment/prerequisite requirements Details Action (vii) 62

is included in updating the food safety quality management system where appropriate: - Results of Inspections by Regulatory Authorities and any changes in regulatory requirements - New information regarding Food Safety Hazards and Control Measures - Food Safety Issues and Health Hazards associated with the product - Anything else considered likely to have an impact on food safety By communicating effectively with all employees all employees will be able to contribute to the effectiveness of the Food Safety Quality Management System. Senior management assess plan and establish appropriate internal and external communication (including the food chain) channels Communication required Details Responsibility 76

Step Four: Food Safety Plan/HACCP Implementation HACCP Training An interactive and illustrated PowerPoint HACCP training presentation is supplied to train your food safety team in the preliminary steps to a Hazard analysis, the principles of HACCP and Instructions in implementing your HACCP system. 79

HACCP Implementation Guide Section 2.3 Describe the Product All raw materials, ingredients, product-contact materials and the characteristics of end products should be described in documents to the extent needed to conduct the hazard analysis. Specifications for all Raw Materials, including Ingredients and Product Contact Materials should be obtained from all suppliers and held in a purchased raw materials file. Specifications should include sufficient detail for the identification and assessment of food safety hazards. For each item the specification should include includes: - Biological, chemical and physical characteristics - Composition of formulated ingredients including additives and processing aids - Origin - Method of production - Delivery method - Storage conditions/requirements - Details of packaging - Preparation and/or handling before use or processing - Food Safety Acceptance criteria - Intended use Use the Sheet HM 002 Product Description in the HACCP Manual to assist you in compiling an end product description. The food safety team should use the form to assist in documenting the end product characteristics, including legal food safety requirements, for the purpose of conducting the Hazard Analysis. The product description may include: - Product name - Composition - What will the purchaser will do with it - Details of the packaging - How the product is processed or manufactured - Composition of the product - Chemical characteristics relevant for food safety such as ph or Aw - Biological characteristics relevant for food safety treatment such as heating, freezing, brining or smoking - Physical characteristics relevant for food safety - Shelf life 88

Significance Severity Probability BRC Food Safety Management System Implementation Workbook The Food Safety Team need to consider the probability of the hazard occurring, the severity of the hazard on the consumer, the vulnerability of the targeted consumer, the survival and multiplication of any biological hazards and any likely toxin production, the presence of chemicals or foreign bodies, contamination at any stage in the process and possible deliberate contamination or adulteration. Taking these factors into account a rating is given for probability and severity and entered: Step Number Step Name Hazards Identified 1 Delivery of Ingredient A Bone 1 3 3 1 Delivery of Ingredient A Campylobacter spp. 2 3 6 1 Delivery of Ingredient A Contamination with Bacteria from pests 3 3 9 1 Delivery of Ingredient A Pesticides 3 1 3 1 Delivery of Ingredient A Salmonella spp. (S. typhimurium, S. enteriditis) 3 3 9 1 Delivery of Ingredient A Bacteria (spore-forming) General 2 2 4 1 Delivery of Ingredient A Pest control chemicals 1 1 1 Firstly the Food Safety Team assesses the likelihood of the hazard occurring and enter: - 1 for Highly Unlikely - 2 for Possible - 3 for Likely Then the Food Safety Team assesses the severity of the hazard and enters: - 1 for Not Severe - 2 for Could possibly cause illness - 3 for Severe (Could be fatal) The Food Safety team should factor in the vulnerability of the targeted consumer, the survival and multiplication of any biological hazards and any likely toxin production, the presence of chemicals or foreign bodies, 97

HACCP Plan Critical Limits Monitoring Procedures Corrective Action Responsibility HACCP Record Minimum / Maximum acceptable levels to ensure condition is in control - measurements to be taken (or observations) method of measurement - devices used (including applicable calibration procedures) - frequency of monitoring - responsibility and authority for monitoring and evaluation of the monitoring results Action to be taken when outside of critical limits to regain control and ensure unsafe product is controlled Who is taking the action Where is it recorded 100

Control Measure Validation Product Category Step Number Hazard Control Measure Validation Methods Third Party Scientific Validation Historical Knowledge Simulated Production Conditions Collection of Data in normal production Admissible in industrial practices Statistical Programmes Mathematical Modelling Internal Validation Required? If so by which method? Applicable Yes No Conclusion Comments CCP Confirmed Authorised by(name): Signature: 106

HACCP Implementation Guide Section 2.13 HACCP Documentation & Record Keeping The food safety team document the HACCP plan - The Food Safety Team should complete the relevant columns in the HACCP Plan Sheet: Step Name Hazard Identified Control Measure Critical Limits Monitoring Procedures Corrective Action Responsibility HACCP Record Delivery of Ingredient A Transfer of Ingredient A Sorting Bone Campylobacter spp. Contamination with Bacteria from pests Example covered and screened delivery area Example covered and screened delivery area Example covered and screened delivery area No Contamination Always load under cover Decide your critical limits and enter here Decide your critical limits and enter here Supervision by Warehouse Manager Decide your monitoring procedures and enter here Decide your monitoring procedures and enter here Retrain Staff. Inspect delivery for contamination. Reject if contaminated enter the corrective action to take if outside of critical limits enter the corrective action to take if outside of critical limits Good In Manager Person Responsible Person Responsible Goods Receipt Record Details of where CCP is recorded Details of where CCP is recorded Procedures and Records should be put in place for all CCP s The management team ensure all staff is competent and adequately trained in the requirements of the prerequisite programmes and the HACCP Plan: Now that the Prerequisite Programmes and HACCP Plans have been documented the Steering Group should develop a training plan to ensure that all staff is trained in the appropriate procedures, limits, corrective actions, and record completion. 108

Stage 8: Final Steps to BRC Certification There a few final steps to achieving BRC Certification: Carry out a Senior Management Review Carry out an assessment of your system to make sure that it meets the requirements of the BRC Global Standard for Food Safety using our Checklist and a copy of the standard Ensure any areas requiring corrective action are addressed Choose your Certification Body Agree a Contract with a Certification Body On-Site Audit Audit & Corrective Action Review Certification & Issuing of the Audit Report Celebrate! Communicate your success! 130

The senior management team carry out food safety management reviews Senior management should review the company management systems, at a minimum, annually to ensure their continuing suitability, adequacy and effectiveness. The review should include assessing the opportunity for improvements and the need for amendments to the systems. The proceedings of all reviews are to be documented. The review meeting is normally chaired by the most Senior Manager and includes Senior Management from Technical, Operations, Engineering, Planning, Distribution and quality departments. Review should inputs include: - Review of the Quality and Food Safety Policy - Review of Management Changes - Minutes and Follow-up actions from previous review meetings - Outstanding Non-conformances as a result of internal and external audits - Results of external second and third-party audits - Trend analysis of Customer and Supplier complaints - Analysis of the results of verification activities including internal hygiene and HACCP plan verification audits - Quality Key Performance Indicators Review and trend analysis - Emergencies and Accidents - Process performance and product conformity - Corrective and preventive action status - Food Safety incidents including allergen control and labelling, recalls, withdrawals, safety or legal issues - Review of planning and development of the processes needed for the realisation of safe products including changes which could affect food safety and the HACCP Plan (including legislation changes and scientific information) - Changes to policies and objectives - Communication activities and effectiveness of communication - Results of review and system updating - Review of Resources and effectiveness of Training - Recommended improvements - Customer Feedback and Sales levels are reviewed to give an indication of trends 131

Ensure any areas requiring corrective action are addressed The non-compliances identified in the assessment of compliance with the BRC Standard should be logged by the Food Safety Team Leader and the appropriate corrective action allocated and taken: Date BRC Section Details of Non Conformance Identified by: Corrective Action Required Responsibility Target completion Date Date Completed 196

Choose your Certification Body Before you can begin preparing for your application, you ll need to decide which Certification Body to use. Do some research and pick one which has a good reputation. BRC Certification Bodies are listed on the BRC website. When selecting a Certification Body you should: Consider customer requirements Consider the scope of the accreditation of the certification body - ensure that the certification body is accredited to assess for the category of products that you produce Confirm that the auditor proposed meets the experience, qualification and training requirements of BRC Agree a Contract with a Certification Body Contact the Certification Body and tell them what you need. They should provide you with a proposal detailing the cost and time involved in a formal assessment. At this stage you will also need to confirm the Scope of your Certification with the Certification Body. The Scope of Certification forms part of the Certificate of Registration. It describes the Food Sector Categories and the products processed and handled on that site. The Certificate of Registration outlines the location of the site and nature and extent of the Certification. The audit, report and certificate will be product and site specific. The scope of the audit will cover the agreed product categories; any excluded categories will be on the certificate when issued. The audit scope should cover the entire process from raw material to end product. Once you are satisfied with the quotations file a certification application with your chosen Certification Body and agree a contract which includes the scope of the audit, expected timescales, the Certification Body s fee structure, the conditions under which the BRC Certificate will be issued, withdrawn or suspended and the appeals, complaints and disputes procedure. The certification body should then issue you with a contract detailing the scope of the audit and reporting requirements. 197