BRC Food 6

P=Procedure

E=Evidence
I=Interview
A=Assess
Example evidence
Training required
Risk Assessment

Documentation

Assess during
Management

facility tour
required

required

Review
Senior
Clause Issue Requirement Evidence

Senior
1.1 Management
1.1.1 Policy, signed and communicated x Policy
Objectives and
1.1.2 Objectives x attainment plan
Review meeting
1.1.3 Senior management review x minutes
Monthly meeting
1.1.4 Managmeent meeting program x minutes
1.1.5 Provision of resources

Conferences,
memberships,
technical journals,
1.1.6 Industry updates e-mail updates

Copy of the
1.1.7 Copy of the standard standard or receipt
1.1.8 Maintain certification
Attendance at opening and closing audit
1.1.9 meetings

Review of non-
conformances, root
Root cause analysis of past non- cause analysis,
1.1.10 conformances x verification
 Organizational
structure and
1.2 authority

Organizational
Organizational chart and absence chart, deputies, list
1.2.1 coverage x of responsibilities

Job descriptions
and work
1.2.2 Job descriptions and work instructions x instructions

2 HACCP

2.1 HACCP team

Team list and
2.1.1 HACCP team, training x training records

Prerequisite
2.2 programs
2.2.1 Prerequisite programs

Product
2.3 description
Scope of HACCP plan, products and
2.3.1 process descriptions x

2.3.2 Source of product / process description x

2.4 Intended use

Description of intended use, specific risk

target groups, potenital misuse of
2.4.1 product x

2.5 Flow diagram

Diagrams illustrating process flow and
2.5.1 layout schematic x
 Verification of
2.6 flow diagram
Flow diagrams verified and challenged
2.6.1 annually x

2.7 Listing of hazards x

2.7.1 Listing of potential hazards x
2.7.2 Definition of hazards x
2.7.3 hazard control measures x

CCP
2.8 determination
Using decision tree, identify which
2.8.1 control points are CCP's x decision tree

2.9 CCP limits

2.9.1 Limits for each CCP defined x

validation studies
showing that
control measures
and limits will
effectiveyly control
hazards in all
forseeable
2.9.2 Validation of CCP's x circumstances

2.10 CCP monitoring

Procedures for monitoring CCP limits, and

corrective actions in case of limits being
2.10.1 exceeded P

Recording and
verification
procedures
(verification to
include verifying
records as well as
2.10.2 Recording of monitoring P actions)
2.11 Corrective action

Procedures to follow in the event of limits

being exceded as well as failure of control
2.11.1 measures P

2.12 Verification
Activities to ensure the HACCP plan is
2.12.1 effective

HACCP
documentation
and record
2.13 keeping
Records created and maintained to verify
2.13.1 HACCP is actively in place x

2.14 HACCP review

Review of both implementation and

effetiveness of the HACCP plan verified
annually or in the event of significant
2.14.1 changes x

Food safety and

quality
management
3 systems
Food safety and
3.1 quality manuals
All policies and procedures are
3.1.1 documented.
Fully implemented and available where
3.1.2 needed
 Policies, procedures and work
instructions are formatted as to be
3.1.3 understandable to staff

3.2 Document control

Mechanism for controlling document list of controlled

documents, change
versions, change log and update log, change
3.2.1 procedure P procedure

3.3 Records

reasons for
alteration of
records is
Records are understandble, record documented on
3.3.1 alteration procedure P record
3.3.2 Record retention procedure P

3.4 Internal audit

Internal audits cover all requirements of Internal audit
3.4.1 the Standard x report

audit technique
training for internal
3.4.2 Internal auditors appropriately trained x auditors

Internal audit reports show evidence of

conformance, and closure of non- internal audit
3.4.3 conformance x report

Internal inspections covering site

3.4.4 conditions and hygiene x inspection reports

Supplier approval
3.5 and monitoring
Raw materials
3.5.1 and packaging
 grouped or
Listing of all ingredients and packaging, individual listing of
3.5.1.1 and associated risks x all materials

Supplier approval procedure, and

3.5.1.2 ongoing monitoring procedure P
Exception procedure in case of non-
3.5.1.3 approved supplies being used P

Acceptance
3.5.2 monitoring

reveiving
inspections, pre-
use testing,
additional
Procedure on how incoming materials are document
3.5.2.1 assessed for acceptance P requirements

3.5.2.2 Records of acceptance x Proof of acceptance

Service supplier
3.5.3 management
Procedure for approval and monitoring of
3.5.3.1 service suppliers P

contracts and
Service contracts adressing specifications specifications for
3.5.3.2 or expectations x service suppliers

outsourced
processing
3.5.4 management
docmented in
Brand owner is aware of outsourced contract with brand
3.5.4.1 processing x owner

verification of
certification or
3.5.4.2 Monitoring of contracted processing x audit reports

contracts of
specification and
3.5.4.3 Managing of contracted processing x expectation in place
 results and analysis
3.5.4.4 Monitoring of contract processing results P of process outcome

3.6 Specifications
Specifications in place for all raw
3.6.1 materials and packaging x specifications

Activities and instructions on the process

floor equate to product and customer
3.6.2 specifications
Specifications in place for all finished
3.6.3 products x specifications

Specifications are agreed with or

3.6.4 available to customers
Specifications are reviewed when
3.6.5 required, minimum every 3 years

3.7 Corrective action

Documented procedure for corrective
3.7.1 actions x

Control of non-
conforming
3.8 product
Hold program, including dispensation
3.8.1 program x

3.9 Traceability
Identification of all materials within site
3.9.1 to allow traceability
3.9.2 Mass balace and traceability test x test results

Rework is included in traceability

3.9.3 program
 Complaint
3.10 handling
Complaint program, resolved through
3.10.1 trained staff x
ongoing trend
Complaint data analyzed for trends and analysis for
3.10.2 used for improivements x complaint data

Incident
3.11 management

Incident management procedures based

3.11.1 on potential large scale interruptions P

3.11.2 Recall and product withdrawal procedure P

3.11.3 Procedures tested annually

CB on recall contact
3.11.4 Notification of CB in the event of recall list

4 Site Standards
External
4.1 standards
Protecting site from external
4.1.1 contaminants and impacts A

4.1.2 Site exterior maintained in good order A

Building exterior maintained in good
4.1.3 condition A

4.2 Security

Security risk assessment and mitigation

4.2.1 completed, reviewed annually x
Controlled access and employee security
4.2.2 training x
 Registered with appropriate government
4.2.3 agencies, where required Proof of registration

Layout, flow and

4.3 segregation

site map,
appropriate zone
4.3.1 Site map designating product risk zones x designations
4.3.2 Site map identifying activites x site map

sign in and
4.3.3 Visitors and contractors managed on site awareness activities

4.3.4 Contamination control in low risk areas A

High care areas provide appropriate
4.3.5 practices A
High risk areas segregated, and use
4.3.6 appropriate practices
Sufficient space to work effecitvely
4.3.7 hygenically
4.3.8 Temporary structures do not add risk

4.4 Building
Walls constructed and maintained to
4.4.1 appropriate standard
Floors constructed and maintained to
4.4.2 appropriate standard

Drains constructed and maintained to

appropriate standard. Drainage does not
4.4.3 impact product integrity

If HC /HR, then msut have a drain plan

showing drains, flow direction, back flow Drain plan /
4.4.4 prevention or other risks. drawing
 Ceilings and overheads construted and
4.4.5 maintained to appropriate standard
Suspended ceilings (building voids) on Void inspection
4.4.6 inspection program R record
4.4.7 Ventilation to outside is pest proof.
Windows protected from breakage where
4.4.8 they pose a risk

Doors constructed and maintained to

appropriate standard. Doors do not allow
4.4.9 pest ingress.
4.4.10 Lighting is suitable and sufficient
4.4.11 Light bulbs protected from breakage
4.4.12 Adequate ventilation and extraction
4.4.13 HR areas using filtered air.

4.5 Utilities
Water is potable, plant tested for relevant Plant sample test
4.5.1 contaminants. R results.

plan showing all

taps, outlets and
4.5.2 Water distribution plan x storage.

If used, reference
4.5.3 Restrictions if non-potable water is used. to legislation.

Steam, compressed air, gasses, do not HACCP process flow

diagram showing
pose contamination risks. Compressed air use of utilities,
4.5.4 with direct product contact is filtered. verify protection.

4.6 Equipment

Equipment designed, constructed and

installed to be effectively cleaned and
4.6.1 maintained.
Approvals of
Equipment with direct food contact made suitability or
4.6.2 of suitable materials. conformance
4.7 Maintenance
Preventative maintenance program is
4.7.1 effective x PM program

Equipment inspection program where not

4.7.2 covered by PM program Inspection program

Work orders tied to

4.7.3 Temporary repairs controlled temporary repairs I

Product protected during maintenance

activities. Post maintenance line
4.7.4 clearance procedure used. P I
Approvals for
Approved chemicals / materials used in materials based on
4.7.5 maintenance. use

4.7.6 Shop and engineering rooms maintained

4.8 Staff facilities

Adequate changing facilities for
4.8.1 employees and visitors
4.8.2 Personal storage for employees.
Separate storage for clean uniforms
4.8.3 provided.

In HC areas: - segragated changerooms,

changing instructions, footwear
dedicated to high care area only,
distinctive clothing, handwashing during
4.8.4 changing, handwash and sanitize on entry P

In HR areas: - changing instructions,

dedicated footwear, footwear barrier
system, disctinctive clothing,
handwashing during changing, hand
4.8.5 wash and sanitize on entry P
 Handwashing to include: - suitable
temperature, liquid soap, single use
4.8.6 drying, hands free taps, signage
Washrooms: - segragated, handwashing
4.8.7 with signange
Smoking and waste managed to protect
4.8.8 product

Employee food stored in clean hygienic

state. No food in production or storage
4.8.9 areas.

Cafetria operations suitably controlled to

prevent contamination and employee cafeteria training,
4.8.10 illness x inspections

Chemical and
physical
contamination
4.9 control

4.9.1 Chemical controls

Approved purchase, specifications,

suitability proof, avoidance of scented
products, appropriate labeling,
segregated and secure storage, use by
4.9.1.1 trained personnel x
4.9.1.2 protect product from chemical taint
4.9.2 Metal control
4.9.2.1 Sharps and knife control procedures p sharps policy

Protection from staples, paper clips, and

4.9.2.2 other closures
Glass and brittle
4.9.3 material control
4.9.3.1 Excluded or protected
 List of items, location and condition.
Periodic check program, procedures for
4.9.3.2 cleaning and replacing as needed. p

Glass breakage procedure: - quarantine,

cleaning, inspection and authorization,
4.9.3.3 clothing change, training and recording x p
Products packed
4.9.3.4 in glass

4.9.3.4.1 Segragated storage of empty containers

Breakage control: - removal of product,

cleaning, designated cleaning materials,
lidded waste containers, post breakage
4.9.3.4.2 inspection, restart authorization
4.9.3.4.3 records of breakage
4.9.4 Wood

4.9.4.1 Restricted use, monitoring of condition

Foreign body
detection and
removal
4.10 equipment

Foreign body
detection and
removal
4.10.1 equipment
4.10.1.1 Risk assessment to assess need x
choice and installation based on industry
4.10.1.2 best practice
4.10.1.3 System testing frequency risk based
 findings report /
Investigation and trend analysis of investigations
4.10.1.4 findings x /trend analysis

4.10.2 Filters and sieves

Investigation and trend analysis of
4.10.2.1 findings
4.10.2.2 inspected and checks recorded
Metal detectors
4.10.3 and x-ray
Risk assessment to assess need.
4.10.3.1 Justification for absence x
choice and installation based on industry
4.10.3.2 best practice
4.10.3.3 Reject or stop and alarm system
4.10.3.4 Operating and testing procedures. p

checks to include: - labelled test pieces,

ferrous stainless and non-ferrous, detect
and reject tested, memory / reset tests,
4.10.3.5 use of sample test packs p
4.10.3.6 Test failure procedure p
4.10.4 Magnets
Magnet specification, inspection,
4.10.4.1 cleaning and testing p
4.10.5 Optical sorting
4.10.5.1 Operating and testing procedures. p
Container
4.10.6 cleaning
cleaning and protection of containers
4.10.6.1 based on best practice p
4.10.6.2 Cleaning effectiveness tests.

Housekeeping
4.11 and hygiene
4.11.1 SSOP's x p
4.11.2 Defined expectations for cleaning

4.11.3 Time and resources for effective cleaning

4.11.4 Cleaning verification
Dedicated, distinctive cleaning equipment
4.11.5 properly managed
4.11.6 CIP
4.11.6.1 Systems monitored and maintained
Appropriate desgin and installation,
4.11.6.2 system change log maintained x schematic

Monitored system conditions,

4.11.6.3 effectiveness testing P

4.12 Waste
Licences of waste contractors, including
4.12.1 those for recycling x contracts / licences

Food waste and animal feed streams

4.12.2 segragated
External waste collection identified and
4.12.3 maintained

Unsafe or trademarked materials licence, record of

4.12.4 appropriately denatured and destroyed P destruction

4.13 Pest control

Competent persons perform risk contract, training or

4.13.1 assessment and manage pest control x licencing

If company managed pest control,

licencing, training
effective competency and systems in records, chemical
4.13.2 place x controls

site map, product

Adequate pest control documentation specifications, pest
4.13.3 and records control reports
 Outdoor baits secured in place, no
4.13.4 rodenticides indoors
Bug lights appropriately locted and
4.13.5 functional
Approprate actions in the event of
4.13.6 infestation
Inspection records and follow up of pest inspection
4.13.7 recommendations records

Additional effectiveness survey, typically

4.13.8 quarterly effectiveness report

Trend analysis of inspections and catch

4.13.9 records minimum annually trend analysis

4.14 Storage facilities

Procedures adequate to ensure product

integrity during storage are in place,
4.14.1 understood and followed P

Where temperature control is required, it temperature

4.14.2 is sufficient and monitored monitoring

Where controlled atmosphere is

required, it is maintained and records
4.14.3 maintained
Stock rotation systems are effectively in
4.14.5 place during storage

Shipping and
4.15 transportation
Product integrity is maintained during
4.15.1 loading P

shipping records
4.15.2 Traceability is maintained during shipping indicate lots

Pre-load inspections performed and

4.15.3 recorded P inspection records
 Where temperature control is required, it temperature
4.15.4 is documented monitoring records

Unloading equipment maintained and

4.15.5 clean

Transport procedures to ensure product

integrity, including security and
4.15.6 breakdown P

Sub-contracted transportation meets all contract, load sign

4.15.7 requirements of section 4.15 off documents

5 Product control
Design and
5.1 development
Guidelines and restrictions on R&D
5.1.1 introducing new hazards R&D review policy

HACCP review completed prior to product

5.1.2 introduction to operations
Product trials where needed to validate
5.1.3 process
5.1.4 Shelf life trails or data completed

target market label

Label design satisfies requirements and regulations and
5.1.5 regulations of country of sale approval process

5.1.6 Lable claims have validated evidence

Allergen
5.2 management

Risk assessment as to potential for raw

supplier
materials to be contaminated with certification or
5.2.1 allergens x questionaires

what and where

5.2.2 List showing all allergens on site x allergens are found
 Risk assessment to identify vectors of
5.2.3 allergen contamination x
Documented allergen segregation
5.2.4 procedures in place and effective P

If rework of allergen containing materials

is carried out, appropriate controls in
5.2.5 place

If contamination connot be effectively

controlled, appropriate consumer lable
5.2.6 warnings in place

5.2.7 Validation of allergen free label claims validation studies

Allergen cleaning procedures validated

and verified. Allergen cleaning equipment cleaning validation
5.2.8 segragated and identified studiues

All persons entering the site shall have visitor and

5.2.9 allergen awareness training x contractor training

5.2.10 Effective packaging changeover system

Provenance and
5.3 assured status
Where provenance is required, raw certificates for raw
5.3.1 material verification in place materials

Records of material provenance

maintained. Mass balance every 6 mass balance
5.3.2 months x results

Process flow specific to assured status

flow diagram
products documented and appropriate specific to assured
5.3.3 controls to maintain in place status product

Product
5.4 packaging
 Documented evidence of suitability proof of material
5.4.1 based on intended use for all packaging x compatability

Storage conditions suitable to maintain

packaging integrity. Obsolete packaging
5.4.2 suitably controlled

Product contact liners for work in process

and ingredients purchased by the
5.4.3 company appropriately colored

Inspection and
5.5 testing

Product
inspection and
5.5.1 testing

5.5.1.1 Product testing program based on risk

Results reviewed, analyzed, and where
5.5.1.2 needed, acted upon x trend analysis
5.5.1.3 Ongoing shelf life studies in place

5.5.2 Lab testing

5.5.2.1 Pathogen testing fully segragated
Laboratory controls in place to prevent
5.5.2.2 contamination

Critical lab testing performed by

accredted laborotory, or in accordance to
5.5.2.3 accredtation guidelines x lab accreditation
5.5.2.4 Good lab practices in place x

5.6 Product release

 Where required, positive release
5.6.1 procedures fully implemented P

6 Process controls
Control of
6.1 operations
Process specifications and work
6.1.1 instructions available and suitable x

Process monitoring in place to esnure

6.1.2 production meets specifications

If process controls are automated,

suitable tested failure alert system is in
6.1.3 place

process validation
6.1.4 Process validation frequency basd on risk x matrrix

Procedures to evaluate product in the

6.1.5 event of process deviation P
changeover pre-op
6.1.6 Product changeover procedure P inspections

packaging
6.1.7 Product packaging verification P verification checks

6.2 Quantity control

regulation for
Weight control programs meet regulatory country of
6.2.1 requirements destination

Weight control programs meet customer

6.2.2 specifications

6.3 Calibration

Equipment to be calibrated is:

documented, identified, scheduled,
6.3.1 protected
 Calibration frequency based on risk and calbration methods
6.3.2 procedures based on standard P and matrix

calbration
Reference calibration equipment certificate of
6.3.3 traceable to Standard standards

Procedures to follow in the event of

equipment found out of calibration and
6.3.4 product potentially at risk P

7 Personnel
7.1 Training
Pre-employment training for staff, temps
7.1.1 and contractors x
7.1.2 Training relevant to CCP`s x
Assessment and delivery plan for staff
7.1.3 training job / training matrix
7.1.4 Records of training R
Staff competency and training
7.1.5 effectiveness assessments

7.2 Personal hygiene P jewelry policy

Policies for jewelry, nail care and personal

7.2.1 hygiene
Hand cleaning on entry to production
7.2.2 areas

Cuts protected, bandages appropriately

7.2.3 colored, meteal detectable.
If metal detectors are present, bandages
7.2.4 are tested for detection x test results

7.2.5 Personal medicine policy and procedure x P

7.3 Medical screening

Procedure for employees to notify site of

7.3.1 sickness or sympton if relevant P
Notification to visitors of health and
7.3.2 sickness risk and procedures P

Procedure for site to follow if employees

or visitors indicate they may be suffering
7.3.3 from a relevant disease P

Protective
7.4 clothing

Protctive clothing policy, including

7.4.1 wearing outside of the work environment P
Protective clothing is suitable to protect
7.4.2 the product

Work wear laundered by service

contractor or in house. Self laundry only
7.4.3 for enclosed or low risk zones

Laundry for HC / HR areas includes:

laundry procedures, commercial
sterilization, segragation, protection of
7.4.4 clean work wear P
Gloves suitable for purpose, preferably
7.4.5 colored.
Non-launderable articles maintained
7.4.6 clean and sanitary.
High care / high risk
Clause Event Expectation Evidence Outcome

Meeting to ensure food Issues identified, action

safety and quality plans in place,
Senior measures are in place resources allocated,
management and appropriate action targets defined,
1.1.3 review plans managed Meeting minutes verification of results

Periodic review of
objectives and
operational
performance, a means
of steering the
operation to ensure
Program of meetings to overall goals are met
track objectives, issues and maintained. Data
Management and ongoing operational analysis for senior
1.1.4 meetings results Meeting minutes management review.

Ensure flow diagrams Singed and dated Flow diagrams support

Verification of used within the HACCP flow diagrams, or control activities,
HACCP flow plan and other areas are other evidance of reported in internal
2.6.1 diagrams up to date and accurate their verification audit

Comprehensive review of
the HACCP plan, to
ensure it is effectively in HACCP plan accurately
place and adequately reflects the process.
manages risk within the Reported to senior
2.14.1 HACCP review operation Review notes management review

All clauses and Documented evidence

requirements of the showing conformance
stadnard are audited to to the standard.
ensure effective Reproted to senior
3.4.1 Internal audit compliance Internal audit report management review
 Site conditions and
Environmental and activities meet
hygiene programs and expectations. Reported
Internal results audited and to monthly
3.4.4 inspections inspected Inspection report management meetings

Specifications are
periodically reviewed to Specification review Site ensures
ensure accuracy to program or dated specifications are up to
3.6.5 Specifications current operations specifications date.

Mass balance of finished Full traceability

goods, raw materials and achieved within 4
3.9.2 Traceability test packaging tested Test results hours

Recall procedure is
validated and tested to
ensure operational
readiness and Opportunity for
3.11.3 Recall test effectiveness Test report process improvements
Security risk Operation security risks Security risk Opportunity for
4.2.1 assessment assessed assessment report improvements
Minimum
frequency

Annual

Monthly

Annual, or in
the event of
changes

Annual, or in
the event of
changes

Annual, or
more
frequent
based on risk
Monthly

Every 3 years
or more as
required

Annual

Annual

Annual