Developing Your HACCP Plan for BRCGS Issue 9

BRCGS Issue 9 is set for publication on 1st February 2023. The BRCGS Global Food Safety Standard has set the benchmark for nearly 25 years. Adopted by over 22,000 sites in more than 130 countries, the standard is accepted by 70% of the top 10 global retailers. It provides a system to manage product safety, legality and quality.

Importance of HACCP

Hazard Analysis Critical Control Points (HACCP) is an internationally recognized method of identifying and managing food safety-related risk and is a legal requirement in the UK. This food safety framework aims to prevent any foodborne illnesses and other adverse health consequences of poor food employee practices from occurring. A compliant HACCP strategy, in conjunction with an active food safety program, can provide your customers, the public, and regulatory agencies assurance that your food safety program is well managed.

See AuditComply’s “12 steps to develop a HACCP Plan” here.

Changes to HACCP

You may already have a HACCP Plan in place, but now is the time to review your current procedures to ensure you are compliant with the new requirements in Issue 9. HACCP principles of the current Codex Alimentarius have resulted in the revision of some clauses in the new issue. 

Below we have highlighted some of the key changes to BRCGS Issue 9 that will directly affect your HACCP plan. In section 2.7.4 it states, “Where the control of a specific food safety hazard is achieved through prerequisite programs (see section 2.2.) or control measures other than critical control points (CCPS: see clause 2.8.1), this shall be stated and the adequacy of the program to control the specific hazard validated”. This clause only required validating the specific prerequisite programs for minimizing or eliminating a specific hazard (in ISO 22000 operations PRPs). For example, cleaning up allergen cross-contamination (clause 5.3.8) or ensuring adequate cold storage temperature also during stocking and full storage in order to prevent the risk of bacterial growth. All other prerequisite programmes, such as pest control, staff hygiene or training are not included, neither is general floor or wall cleaning.

The requirements under 2.12 for “Validate the HACCP plan and establish verification procedures” (equivalent to Codex Alimentarius Step 11, Principle 6) are new. This new requirement reflects the recommendation from Codex Alimentarius General Principles of Food Safety for the validation of food safety controls. Changes to the HACCP or food safety plans which may affect product safety, shall be checked to ensure they effectively control the identified hazard before implementation.

Developing a HACCP Plan

Below we have also included the 12 steps you can take to develop your HACCP plan and how to go about implementing it into the culture of your organization.  Writing a food safety plan involves several subsequent steps that you need to follow to achieve the system’s benefits:

1. Assemble a HACCP Team

It’s important the team you put together understands and comes from a wide range of disciplines and backgrounds.

2. Supply Chain Management

The HACCP team needs to create a general description of the food product, ingredients and processing methods. The method of distribution should also be included.

3. Identify the products intended for use

At this stage, a description of the expected use for the food product needs to be created. Consumers can be categorized as the general public or a particular segment of the population (e.g. infants, the elderly etc.)

4. Draw up a flow diagram

This should be a clear, simple way of outlining the steps involved in the process that are directly under the control of the organization.

5. On-site confirmation of flow diagram

It’s important that your flow diagram is aligned with actual operations. Each operation should be observed and any differences between the diagram and normal practice should be recorded and fixed.

6. Conduct a Hazard Analysis (Principle 1)

Stage 6 is when your HACCP team comes together and begins to conduct their hazard analysis. This step is for identifying control measures. A list of all potential hazards should be associated with each step. This process involves two stages: Hazard Identification and Hazard Evaluation.

7. Determine Critical Control Points (CCPS) (Principle 2)

A critical control point is defined as a step at which control can be applied and is essential to prevent or eliminate a food safety hazard or lower it to an acceptable level. The potential hazards that are reasonably likely to cause illness or injury in the absence of their control must be addressed in determining CCPs.

8. Establish critical limits (Principle 3)

A critical limit is used to distinguish between safe and unsafe operating conditions at a CCP. Critical limits must be specified and validated for each CCP. All your critical limits must be scientifically based.

9. Monitor CCPS (Principle 4)

Monitoring is important to guarantee that all critical limits at each CCP are being adhered to. When choosing a system for monitoring, organizations need real-time data and a robust issue management system so operatives can detect any loss of control immediately.

10. Establish Corrective Actions (Principle 5)

If monitoring indicates that critical limits are not being met demonstrating that the process is out of control, corrective action must be taken immediately. The corrective action should take into account the worst-case scenario, but must also be based on the assessment of hazards, risk and severity, and on the final use of the product.

11. Establish procedures for verification (Principle 6)

Once you have completed your HACCP Plan and all the CCPs have been chosen, the plan then has to be verified. Once the HACCP Plan is in operation, it must be reviewed at regular intervals. A formal internal auditing plan of the system will also demonstrate an ongoing commitment to keep the HACCP Plan up to date, as well as representing any verification activity.

12. Establish Documentation and Record Keeping (Principle 7)

The records maintained for the HACCP System should include the following:

– A summary of the hazard analysis, including the rationale for determining hazards and control measures

– The HACCP Plan

– Listing of the HACCP team and assigned responsibilities

– Description of the food, its distribution and intended use

– Verified diagram

– HACCP Plan summary table

Failing to keep your HACCP plan updated might lead to the production of unsafe food. The maximum penalty for failing to keep your food safety standards is a jail 2-year sentence.

Please note: A HACCP Plan should be written to fit each individual organization. There is no ‘one size fits all’ approach. The plan must also be properly maintained and developed according to changing environments and requirements. For more information on creating a HACCP Plan, download our “12 steps to develop a HACCP Plan” here.

About AuditComply

AuditComply is a leading Food & Beverage GRC Management platform connecting all aspects of Risk, Food Safety, Compliance and Quality.

A platform designed by FSQA & Production Managers to meet the challenges of modern food organizations, from manufacturing to food processing and distribution. Whether it’s the ongoing labor shortage, requiring you to do more with less, the increasing risk of contamination in the supply chain, or the spiraling complexity of operations, AuditComply delivers a company-wide focus on safety, quality and compliance. Driving reassurance across the industry that your team is delivering the freshest, highest quality, sustainable food products. 

To learn more about how AuditComply can help ensure compliance with BRCGS Issue 9 request a demo here.