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Testing New Ingredients with Your BRCGS HACCP Plan

Helen Timothy
September 4, 2019

Checklist: GFSI Standards - Getting Started with BRC

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Checklist: GFSI Standards - Getting Started with BRC

Designed to encourage the development of best food safety practices and to help prepare companies to pursue full BRC certification, the BRC enrollment program incorporates the main features of the BRC Global Food Standard. Our checklist breaks down how to get started.

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HACCP's principles are prevalent across all segments of food production. They are primarily concerned with raw materials, products, and processes, and large brands often mandate them to their suppliers and suppliers' suppliers. Additionally, all GFSI and audit scheme requirements, including BRCGS, integrated HACCP's principles.

BRCGS is one of the most sought-after GFSI certification schemes. It is a leading global brand recognized by thousands of customers worldwide, with more than 30,000 certified suppliers in over 130 countries worldwide. BRCGS developed the Global Standard for Food Safety in 1998 and is now in its eighth issue.

Issue 8 of the Standard focuses on:

  1. Senior Management Commitment

  2. Food Safety Plan – HACCP

  3. Food Safety and Quality Management System

  4. Site Standards

  5. Product Control

  6. Process Control

  7. Personnel

  8. High-risk, High-care, and Ambient High-care Production Risk Zones

  9. Requirements for Traded Products

But when it comes to section 2, Food Safety Plan – HACCP, what do you do when testing new ingredients? Do you have to reverify your HACCP plan every time you test a new ingredient? Some companies check three to four new ingredients one week, a couple more the following week, and then maybe two more a month later, all on the same line. Do each of these need different HACCP plans?

BRCGS Section 2.14.1

Section 2.14.1 states: "The HACCP food safety team shall review the HACCP or food safety plan and prerequisite programmes at least annually and prior to any changes which may affect food safety.

As a guide, these may include the following, although this is not an exhaustive list:

  • change in raw materials or supplier of raw materials

  • change in ingredients/recipe

  • change in processing conditions, process flow, or equipment

  • change in packaging, storage, or distribution conditions

  • change in consumer use

  • emergence of a new risk (e.g. known adulteration of an ingredient or other relevant, published information, such as the recall of a similar product)

  • review following a recall

  • new developments in scientific information associated with ingredients, process, or product.

Appropriate changes resulting from the review shall be incorporated into the HACCP plan or food safety plan and/or prerequisite programmes, fully documented and validation recorded."

To address this potential dilemma, have a HACCP team leader and approval process in place. The HACCP team leader should ensure that the company develops, implements, maintains, and reassesses the HACCP system as needed. The approval process should include all required documentation for current suppliers and new suppliers of new ingredients.

Your approval form should have a list of items and questions such as:

  • Is this a new supplier?

  • Is this a new ingredient?

  • Was the Allergen Statement received?

  • Did you send the Spec Sheet?

  • Did you send the Third Party Audit?

  • Was the Material Safety Data Sheet (MSDS) received?

The HACCP team lead should review this list and all requested documents, and determine whether the new ingredient/supplier should be approved. So while this type of form is used to pose the question, "What are the new risks?" it may be beneficial to have a single question at the end that targets if any of the above information indicates a significant change in product or ingredient risk profile. A significant change would require a review of the HACCP plan. If so, the HACCP team lead must push to revisit the HACCP plan – taking a work instruction point of view. Being critical will ultimately strengthen your documented HACCP policy.

Want to get started with GFSI compliance and don't know where to start? Our BRCGS checklist points you in the right direction and ensures you don't miss critical first steps. Download the checklist here

HACCP GFSI BRCGS
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