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The new BRCGS and IFS, what do they bring us?

BRCGS 9 has been published, the final version of IFS 8 still requires some patience. Important changes are on food safety culture, competencies and validation. This was done because of innovations in the Codex Alimentarius and the Global Food Safety Initiative (GFSI). What are the major changes?

Improving food safety culture is not new. For years, Précon has been training people on behavior more than knowledge. After all, just because employees are familiar with the way a hairnet should be worn doesn't mean it's actually done. Much more than knowledge, behavior is driven by the culture in which we find ourselves. The culture in a company often forms rather unconsciously and changing that culture is therefore difficult, but not impossible.

Positive open culture

Again, management in particular must get behind the change and promote it. If the quality people are the only initiators, this is doomed to fail. Good example follows good practice, and from the desire to join the group, employees will adopt this behavior as a matter of course. A positive open culture with constructive criticism leads to fewer mistakes and improves the atmosphere. Employees are then more inclined to stay, which is not unimportant in this day and age.

Food safety culture requirements have been introduced in earlier versions of BRCGS and IFS. Now it is more specifically stated that improvement must be worked on. Management must initiate, support and monitor culture improvement. Audits ask about this.

It is often difficult for companies to find enough employees, and the large number of changes increases the risk of errors. For CCPs, it is already common for employees to be trained. BRCGS and IFS now also require that key prerequisites and controls be demonstrably performed by competent employees. Analyses for HACCP, fraud and food defense must be set up and maintained by competent employees. All employees, including temporary employees and externals, must be trained in advance on their duties and on the relevant hygiene rules. Human error is often the cause of recalls, so the background to this change is well understood.

If the quality department is the sole catalyst this is doomed to failure

Validation: HACCP Plan

In the 2020 version of the Codex Alimentarius General Principles of Food Hygiene (GPFH), validation plays a major role. In the previous version, validation focused on control measures and critical limits; in the new version, validation is concerned with the HACCP plan as a whole. It must be assessed whether the plan is capable of guaranteeing the safety of the products. Validation then focuses on hazard identification, critical control points, critical limits, control measures, monitoring, corrective actions and verification.

New GPFH: Basic conditions more important

The new GPFH recognizes that some baseline conditions make a greater contribution to food safety than others. These baseline conditions are referred to as GHPs that require greater attention. In line with this, BRCGS now states that validation is also important for baseline conditions that address specific hazards. These may include, for example, the cleaning program and keeping allergens separate.

BRCGS now includes commissioning of new equipment. This commissioning aims to ensure the safety and quality of the first production runs with new machines. The draft version of IFS 8 also has such a requirement. In addition, that standard requires validation of product shelf life, preparation instructions, nutritional information, packaging suitability and reprocessing procedures, among other things. The ethylene oxide recalls once again made it clear that raw material safety is a significant risk. Procedures for raw materials and suppliers are therefore seen as fundamental in BRCGS. IFS has a knockout criterion for having specifications.

Hazard analysis raw materials

BRCGS requires an assessment of hazards in raw and packaging materials including the possibility of fraud. Supplier approval must be based on GFSI-accredited certification or a supplier audit. A questionnaire may suffice, but only in cases of low risks. Acceptance of raw materials should include sampling and analysis or visual inspection upon receipt or an analytical certificate at each delivery. Packaging materials should be supplied with a declaration of conformity. The draft version of IFS 8 also has such an approach, but does not go as far as BRCGS.

A hazard analysis on raw materials is easier said than done. Many companies know the hazards in their own processes well, but for raw materials it is different. European regulations such as 1881/2006 and 2073/2005 list many combinations of hazards and raw materials, and Regulation 2019/1793 adds country of origin. Keeping up with this legislation is no easy task, and for companies with composite consumer products, it is an almost impossible task. The hazard analysis then easily consists of several hundred, if not more than a thousand lines. It is then quite a challenge, based on this analysis, to draw up a plan for verifying the safety of raw materials. The cost of such a plan runs rather high and the contribution to risk management is often not very clear.

Many companies are well aware of the hazards in their own processes, but it is different for raw materials.

New software tool: GINO

A database with the legal requirements for the various hazards can help. But a database alone still doesn't really help. Estimating hazards, processing changes and mega-sized files remain. In 2023, Précon will therefore launch a new software tool called GINO. This software offers the user instant insight into commodity hazards and current risks. Using a configurable decision model, GINO then creates a verification plan that indicates the verification action per raw material and per supplier. For Précon and its customers, this is an important step in further strengthening food safety.

Want to know more?

Want more information about the news BRCGS? Then check out the training page BRCGS Food version 9 or contact us at info@precongroup.com or +31 30 65 66 010.

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