BRC Global Standard For Food Safety Issue 7 Guide To Key Changes PDF English

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46619 BRC Food 6-7_TEXT.indd 1 26/02/2015 20:43

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The Global Standard Food Safety Issue 7: Guide to Key Changes and the terms of the disclaimer set out above shall be construed
in accordance with English law and shall be subject to the non-exclusive jurisdiction of the English Courts.
COPYRIGHT
British Retail Consortium 2015
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BRC GUIDELINE
A GUIDE TO THE CHANGES
FROM ISSUE 6 TO ISSUE 7
The BRC published the Global Standard for Food Safety Issue 7 in January 2015 and the new Standard will be used for all audits
from 1 July 2015. Certificates issued against Issue 6 will remain valid for the duration indicated on the certificate.
This document is intended to provide an introduction to the new Issue 7 and a guide to all users of the changes and the reasons
for the changes.
The Appendix provides a full index of all changes to the requirements and is intended as a reference for managers needing to
update their quality systems in preparation for an audit against Issue 7.
There are a range of guidance documents including the full Interpretation Guide providing guidance on all clauses available. The
documents are all included within the subscription to BRC Participate or to purchase as additional documents from the BRC
Bookshop.
BACKGROUND TO THE PRODUCTION OF ISSUE 7 AND OBJECTIVES

CONSULTATION AND DEVELOPMENT PROCESS
The BRC Food Safety Standard is widely used around the world and, before starting the review for Issue 6, the BRC undertook an
extensive consultation with the users of the Standard to understand the strengths and potential areas for improvement.
The feedback on Issue 6 was generally very positive and the continual growth in use of the Standard around the world, with more
than 18,000 certificated sites in 2014, is a testament to its increasing international popularity.
The consultation and review of emerging food safety concerns since the development of Issue 6 identified a number of
opportunities for further improvement.
The key objectives identified for the working groups were:
Look for new ways to reduce the burden of multiple audits of certificated sites.
Ensure that the grading system provided a true reflection of the standards at the sites and provide more opportunities for the
best sites to differentiate themselves.
Include requirements to encourage sites to reduce their exposure to food fraud.
Review high-care and high-risk requirements and ensure that where higher-risk ambient products are produced, controls are
identified.
Ensure that the requirements and audit process are focused on reducing the issues most frequently causing recalls and
withdrawals.
Revise the enrolment programme to encourage uptake.
The detail of the Standard was developed using two multi-stakeholder working groups: one in North America and one in Europe.
Each group was made up of representatives from retailers, food services, certification bodies, food manufacturers and, in Europe,
an accreditation body, UKAS.
The draft Standard was tested in a series of trial audits and made available for public consultation. More than 2,800 people from
around the world downloaded the draft document. All of the comments on the draft were reviewed before the final draft was
produced.
The BRC would like to thank all of those people who have contributed to the development of Issue 7 of the Standard.

KEY CHANGES TO THE REQUIREMENTS FOR ISSUE 7
STABILITY
The Issue 6 standard was well received and we recognise that the Standard is used as the basis for the quality management
systems that have been established by many thousands of sites around the world. In reviewing and rewriting the Standard we
have tried to concentrate on a few major areas where the standard needed to be revised to reflect the changing food safety
landscape. The vast majority of the requirements of the Standard are unchanged or with slight edits to the wording to aid clarity.
This should mean that for most sites, the focus for getting ready for Issue 7 is concentrated on a few key areas.
REDUCING THE EXPOSURE TO FOOD FRAUD (CLAUSES 5.4.13)

There have been several very high-profile food fraud or adulteration issues in the last couple of years including the addition of
melanin to milk powder in China and the substitution of beef by horsemeat in Europe. Whilst the Standard is not designed to
detect food fraud, it should provide confidence to customers that their suppliers have robust systems in place to protect
themselves from being the victims of a fraud further back in the supply chain. Although covered as part of HACCP and supplier
approval in Issue 6, we have increased the focus on fraud prevention by introducing three new clauses. These look at vulnerability
to fraud, as well as introducing tighter controls on supplier approval, particularly the controls of agents and brokers.
SUPPLY CHAIN TRACEABILITY (CLAUSE 3.9.3)

The supply chains for products have become increasingly complex, often including raw materials from around the world and may
include agents or brokers as intermediaries. This has led to a lack of transparency which becomes apparent too often when an
issue occurs requiring full traceability of a raw material. Retailers and food service companies are increasingly looking for more
information about the source of raw materials used in their products to give them confidence in the food safety systems operated
by raw material suppliers. In recognition of this, Issue 7 has extended the requirements for traceability to include assurances about
the traceability system operated by raw material suppliers.
AGENTS AND BROKERS (CLAUSE 3.5.1.3)

Where raw materials are supplied by agents and brokers, it will be necessary to know the manufacturer of the raw material and
ensure that the manufacturer meets the raw material supplier approval process of the site.
PRODUCT LABELLING (CLAUSE 5.2) AND LABELLING AND PACK CONTROL (CLAUSE 6.2)
An analysis of product recall and product withdrawal data shows that the underlying cause of the greatest number of problems is
labelling. Problems occur either because the label information is incorrect as a result of changes to ingredients or suppliers, or
because of errors made during the packing process. To attempt to focus on the issue, clauses relating to labelling and packing
have been expanded and included in a new fundamental statement of intent.
CUSTOMER FOCUS (CLAUSE 3.12)

Many of the customer audits undertaken at BRC-certificated sites focus on the customers own policies. A new set of
requirements has been added to provide customers with greater confidence that sites are aware of and act on customer-specific
policies when producing products for customers.
MANAGEMENT OF SURPLUS FOOD PRODUCTS (CLAUSE 4.13)

The practice of providing surplus products to charities has become more common and is to be encouraged. Issue 7 has two new
clauses designed to ensure that the food is safe and labelled appropriately and that products donated bearing the customers
brand are treated in accordance with the brand owners policies.
NEW AMBIENT HIGH-CARE AREAS (CLAUSE 4.3.7)

Issue 6 introduced more detail on the environmental controls for high-care and high-risk chilled and frozen products. Since
Issue6 there have been a number of high-profile food safety incidents affecting ambient products (e.g. Salmonella contamination
of peanut butter in the US). In response, a new requirement has been introduced to ensure that there are risk-based environmental
controls to protect ambient products where the product is at risk of cross-contamination from a raw material after processing.
CHANGES TO THE PROTOCOL

There have been very few changes to the way in which the Standard is audited and certificated from Issue 6 and full details can be
found within Part III of the Standard. The main changes and reasons for the changes are summarised below.
GRADING The grading structure for Issue 7 has been extended to allow more differentiation between certificated sites. The
new certificated grades will be AA, A, B, C and D with a + added to the grade where the audit is carried out unannounced.

Grading as before is based on the type and number of non-conformities identified at the audit. Full details are provided in the
Standard.
EXCLUSIONS FROM SCOPE The rules for the exclusion of products from the audit scope have been clarified and the
reasons for exclusion need to be included in the audit report. The exclusion of products from scope is discouraged.
VOLUNTARY MODULES The new issue has been designed to enable additional voluntary modules to be added to the
audit to meet particular customer or geographical requirements and reduce the need for further audits. The first of the
voluntary modules covers traded goods, which previously required a second certification audit.
UNANNOUNCED AUDITS The unannounced audit schemes remain voluntary and have been extended to allow access to
any site wanting to join the unannounced scheme irrespective of its previous grade.


APPENDIX
DETAILED CHANGES TO
REQUIREMENTS
This appendix highlights the changes between Issue 6 and Issue 7 and provides a brief commentary on the reasons for each
change, where applicable. There has been a general review of the requirements and standardisation of nomenclature between
the use of the words site and company. This was done to assign responsibility for compliance between requirements which
must be met at the site level site and requirements which may be complied with either at the site or company level where there
is a head office company.
Changes from Issue 6 have been highlighted in red text in the column headed Issue 7. As a guide, the most significant changes
that are most likely to require additional work in preparation for Issue 7 audits have been highlighted in the comments column in
orange. Please note, however, that it is the responsibility of the site to study all requirements of the Standard and ensure that these
are understood and that suitable processes are in place to ensure compliance.
1SENIOR MANAGEMENT COMMITMENT
1.1SENIOR MANAGEMENT COMMITMENT AND CONTINUAL IMPROVEMENT

ISSUE 6 ISSUE 7
CLAUSE REQUIREMENTS CLAUSE REQUIREMENTS COMMENTS
FUNDAMENTAL The companys senior FUNDAMENTAL The sites senior The Standard has
Statement of intent management shall Statement of intent management shall been reviewed to
demonstrate they are fully demonstrate they are fully identify
committed to the committed to the requirements
implementation of the implementation of the which apply
requirements of the Global requirements of the Global directly to the
Standard for Food Safety Standard for Food Safety audited site and
and to processes which and to processes which those which may
facilitate continual facilitate continual be satisfied via a
improvement of food safety improvement of food safety wider company
and quality management. and quality management. approach.
1.1.1 The company shall have a 1.1.1 The site shall have a
documented policy which documented policy which
states the companys states the sites intention to
intention to meet its meet its obligation to
obligation to produce safe produce safe and legal
and legal products to the products to the specified
specified quality and its quality and its responsibility
responsibility to its to its customers. This shall
customers. This shall be: be:
signed by the person signed by the person

with overall with overall
responsibility for the site responsibility for the site
communicated to all communicated to all
staff. staff.

ISSUE 6 ISSUE 7
1.1.2 The companys senior 1.1.2 The sites senior Wording includes
management shall ensure management shall ensure food safety to
that clear objectives are that clear objectives are align with the
defined to maintain and defined to maintain and wording used in
improve the safety, legality improve the safety, legality 1.1.1.
and quality of products and quality of products
manufactured, in manufactured, in
accordance with the quality accordance with the food
policy and this Standard. safety and quality policy
These objectives shall be: and this Standard. These
objectives shall be:
documented and
include targets or clear documented and
measures of success include targets or clear
clearly communicated measures of success
to relevant staff clearly communicated
monitored and results to relevant staff
reported at least monitored and results
quarterly to site senior reported at least
management. quarterly to site senior
management.
1.1.3 Management review 1.1.3 Management review

meetings attended by the meetings attended by the
sites senior management sites senior management
shall be undertaken at shall be undertaken at
appropriate planned appropriate planned
intervals, annually as a intervals, annually as a
minimum, to review the site minimum, to review the site
performance against the performance against the
Standard and objectives Standard and objectives
set in 1.1.2. The review set in clause 1.1.2. The
process shall include the review process shall
evaluation of: include the evaluation of:
previous management previous management

review action plans and review action plans and
time frames timeframes
results of internal, results of internal,
second party and/or second-party and/or
third party audits third-party audits
customer complaints customer complaints
and results of any and results of any
customer performance customer feedback
reviews incidents, corrective
incidents, corrective actions, out-of-
actions, out of specification results and
specification results and non-conforming
non-conforming materials
materials review of the
review of the management of the
management of the systems for HACCP,
HACCP system food defence and
resource requirements. authenticity
resource requirements.

ISSUE 6 ISSUE 7
1.1.3 cont. Records of the meeting 1.1.3 cont. Records of the meeting
shall be documented and shall be documented and
used to revise the used to revise the
objectives. The decisions objectives. The decisions
and actions agreed within and actions agreed within
the review process shall be the review process shall be
effectively communicated effectively communicated
to appropriate staff, and to appropriate staff, and
actions implemented within actions implemented within
agreed time scale. agreed timescales.
1.1.4 The company shall have a 1.1.4 The site shall have a
demonstrable meeting demonstrable meeting
programme which enables programme which enables
food safety, legality and food safety, legality and
quality issues to be brought quality issues to be brought
to the attention of senior to the attention of senior
management at least management at least
monthly and allows for the monthly and allows for the
resolution of issues resolution of issues
requiring immediate action. requiring immediate action.
1.1.5 The companys senior 1.1.5 The companys senior Removed excess
management shall provide management shall provide wording but no
the human and financial the human and financial material change.
resources required to resources required to
produce food safely in produce food safely and in
compliance with the compliance with the
requirements of this requirements of this
Standard and for the Standard. (Removal of
implementation of the HACCP-based food safety
HACCP-based food safety plan.)
plan.
1.1.6 The companys senior 1.1.6 The companys senior Bullet points
management shall have a management shall have a introduced
system in place to ensure system in place to ensure toclarify
that the company is kept that the site is kept requirement.
informed of scientific and informed of and reviews: Reference to
technical developments,
industry codes of practice
scientific and technical authenticity of
raw materials
developments
and all relevant legislation
applicable in the country of
industry codes of added to ensure
this is also
practice
raw material supply,
production and, where
new risks to authenticity considered. This
links with clause
of raw materials
known, the country where
the product will be sold.
all relevant legislation 5.4.1.
applicable in the country
of raw material supply,
production and, where
known, the country
where the product will
be sold.
(Changed to bullet pointed
for clarity.)

ISSUE 6 ISSUE 7
1.1.7 The company shall have a 1.1.7 The site shall have a The Standard will
genuine, original hard copy genuine, original hard copy be available as a
or electronic version of the or electronic version of the free pdf so should
current Standard available. current Standard available be accessible to
and be aware of any all. Any changes
changes to the Standard or will be published
protocol that are published on the BRC
on the BRC website. website and
BRCParticipate.
1.1.8 Where the company is 1.1.8 Where the site is

certificated to the Standard certificated to the Standard
it shall ensure that it shall ensure that
announced recertification announced recertification
audits occur on or before audits occur on or before
the audit due date the audit due date
indicated on the certificate. indicated on the certificate.
1.1.9 The most senior 1.1.9 The most senior The wording
production or operations production or operations change was
manager on site shall manager on site shall introduced to
attend the opening and participate in the opening reflect the
closing meetings of the and closing meetings of the expectation that
audit for Global Standard audit for Global Standard senior managers
for Food Safety for Food Safety are involved
certification. Relevant certification. Relevant rather than just
departmental managers or departmental managers or attending the
their deputies shall be their deputies shall be closing meeting.
available as required during available as required during
the audit process. the audit. (removal of
process)
1.1.10 The companys senior 1.1.10 The sites senior

management shall ensure management shall ensure
that the root causes of that the root causes of
non-conformities identified non-conformities identified
at the previous audit at the previous audit
against the Standard have against the Standard have
been effectively addressed been effectively addressed
to prevent recurrence. to prevent recurrence.

1.2ORGANISATIONAL STRUCTURE, RESPONSIBILITIES AND MANAGEMENT
AUTHORITY
ISSUE 6 ISSUE 7
Statement of intent The company shall have a Statement of intent The company shall have a
clear organisational clear organisational
structure and lines of structure and lines of
communication to enable communication to enable
effective management of effective management of
product safety, legality and product safety, legality and
quality. quality.
1.2.1 The company shall have an 1.2.1 The company shall have an
organisation chart organisation chart
demonstrating the demonstrating the
management structure of management structure of
the company. The the company. The
responsibilities for the responsibilities for the
management of activities management of activities
which ensure food safety, which ensure food safety,
legality and quality shall be legality and quality shall be
clearly allocated and clearly allocated and
understood by the understood by the
managers responsible. It managers responsible. It
shall be clearly shall be clearly
documented who documented who
deputises in the absence of deputises in the absence of
the responsible person. the responsible person.
1.2.2 The companys senior 1.2.2 The sites senior

management shall ensure management shall ensure
that all employees are that all employees are
aware of their aware of their
responsibilities. Where responsibilities. Where
documented work documented work
instructions exist for instructions exist for
activities undertaken, the activities undertaken, the
relevant employees shall relevant employees shall
have access to these and have access to these and
be able to demonstrate that be able to demonstrate that
work is carried out in work is carried out in
accordance with the accordance with the
instruction. instructions.

2THE FOOD SAFETY PLAN HACCP
2.1THE HACCP FOOD SAFETY TEAM CODEX ALIMENTARIUS STEP 1

ISSUE 6 ISSUE 7
FUNDAMENTAL The company shall have a FUNDAMENTAL The company shall have a
Statement of intent fully implemented and Statement of intent fully implemented and
effective food safety plan effective food safety plan
based on Codex based on Codex
Alimentarius HACCP Alimentarius HACCP
principles. principles.
2.1.1 The HACCP plan shall be 2.1.1 The HACCP plan shall be
developed and managed developed and managed
by a multi-disciplinary food by a multi-disciplinary food
safety team that includes safety team that includes
those responsible for those responsible for
quality/technical, quality/technical,
production operations, production operations,
engineering and other engineering and other
relevant functions. relevant functions.
The team leader shall have The team leader shall have
an in-depth knowledge of an in-depth knowledge of
HACCP and be able to HACCP and be able to
demonstrate competence demonstrate competence
and experience. and experience.
The team members shall The team members shall
have specific knowledge of have specific knowledge of
HACCP and relevant HACCP and relevant
knowledge of product, knowledge of product,
process and associated process and associated
hazards. hazards.
In the event of the company In the event of the site not
not having appropriate having appropriate
in-house knowledge, in-house knowledge,
external expertise may be external expertise may be
used, but day-to-day used, but day-to-day
management of the food management of the food
safety system shall remain safety system shall remain
the responsibility of the the responsibility of the
company. company.
2.1.2 (NEW) The scope of each HACCP Existing

plan, including the requirement
products and processes re-allocated to
covered, shall be defined. this section where
(Taken from 2.3.1 in Issue 6) it was considered
to be more
appropriate.

2.2 PREREQUISITE PROGRAMMES
ISSUE 6 ISSUE 7
2.2.1 The company shall 2.2.1 The site shall establish and
establish and maintain maintain environmental
environmental and and operational
operational programmes programmes necessary to
necessary to create an create an environment
environment suitable to suitable to produce safe
produce safe and legal and legal food products
food products (prerequisite (prerequisite programmes).
programmes). As a guide As a guide these may
these may include the include the following,
following, although this is although this is not an
not an exhaustive list: exhaustive list:
cleaning and sanitising cleaning and sanitising

pest control pest control
maintenance maintenance
programmes for programmes for
equipment and equipment and
buildings buildings
personal hygiene personal hygiene
requirements requirements
staff training staff training
purchasing purchasing
transportation transportation
arrangements arrangements
processes to prevent processes to prevent
cross-contamination cross-contamination
allergen controls. allergen controls.
The control measures and The control measures and
monitoring procedures for monitoring procedures for
the prerequisite the prerequisite
programmes must be programmes must be
clearly documented and clearly documented and
shall be included within the shall be included within the
development and reviews development and reviews
of the HACCP. of the HACCP.

2.3DESCRIBE THE PRODUCT CODEX ALIMENTARIUS STEP 2
ISSUE 6 ISSUE 7
2.3.1 The scope of each HACCP 2.3.1 Removal of scope which Re-allocation of
plan, including the has been moved to new parts of the
products and processes clause 2.1.2 requirement for
covered, shall be defined. Issue 6 to more
A full description for each
For each product or group appropriate
product or group of
of products a full clause as
products shall be
description shall be indicated.
developed, which includes
developed, which includes
all relevant information on
all relevant information on
food safety. As a guide, this
food safety. As a guide, this
may include the following,
may include the following,
although this is not an
although this is not an
exhaustive list:
exhaustive list:
composition, e.g. raw composition (e.g. raw

materials, ingredients,
materials, ingredients,
allergens, recipe)
allergens, recipe
origin of ingredients origin of ingredients
physical or chemical physical or chemical

properties that impact
properties that impact
food safety (e.g. pH, aw)
food safety, e.g. pH, aw
treatment and treatment and
processing (e.g.
processing, e.g.
cooking, cooling)
cooking, cooling
packaging system, e.g. packaging system (e.g.
modified atmosphere,
modified atmosphere,
vacuum)
vacuum
storage and distribution storage and distribution
conditions (e.g. chilled,
conditions, e.g. chilled,
ambient)
ambient
target safe shelf life target safe shelf life
under prescribed
under prescribed
storage and usage
storage and usage
conditions.
conditions
instructions for use, and Removal of final bullet point
relating to instructions for
potential for known
customer misuse, e.g. use and known misuse
storage, preparation. moved to 2.4.1

ISSUE 6 ISSUE 7
2.3.2 All relevant information 2.3.2 All relevant information Expanded
needed to conduct the needed to conduct the wording to make
hazard analysis shall be hazard analysis shall be it clear that
collected, maintained, collected, maintained, reference
documented and updated. documented and updated. sourcesused in
The company will ensure The company will ensure development of
that the HACCP plan is that the HACCP plan is the study shall be
based on this may include based on comprehensive maintained.
the following, although this information sources, which Emphasise the
is not an exhaustive list: are referenced and importance of
available on request. As a relevant
the latest scientific guide, this may include the background
literature
following, although this is information.
historical and known not an exhaustive list:
hazards associated with
specific food products the latest scientific
relevant codes of literature
practice historical and known
recognised guidelines hazards associated with
food safety legislation specific food products
relevant for the relevant codes of
production and sale of practice
products recognised guidelines
customer requirements. food safety legislation
relevant for the
production and sale of
products
customer requirements.
2.4IDENTIFY INTENDED USE CODEX ALIMENTARIUS STEP 3

ISSUE 6 ISSUE 7
2.4.1 The intended use of the 2.4.1 The intended use of the Wording
product by the customer product by the customer, extended to
shall be described, and any known alternative ensure all uses of
defining the consumer use, shall be described, the product are
target groups, including defining the consumer considered (e.g.
the suitability of the product target groups, including cabbage sliced to
for vulnerable groups of the the suitability of the product make coleslaw;
population (e.g. infants, for vulnerable groups of the pizza toppings
elderly, allergy sufferers). population (e.g. infants, grazed before
elderly, allergy sufferers). cooking).

2.5CONSTRUCT A PROCESS FLOW DIAGRAM CODEX ALIMENTARIUS STEP 4
ISSUE 6 ISSUE 7
2.5.1 A flow diagram shall be 2.5.1 A flow diagram shall be
prepared to cover each prepared to cover each
product, product category product, product category
or process. This shall set or process. This shall set
out all aspects of the food out all aspects of the food
process operation within process operation within
the HACCP scope, from the HACCP scope, from
raw material receipt raw material receipt
through to processing, through to processing,
storage and distribution. storage and distribution.
As a guide, this should As a guide, this should
include the following, include the following,
although this is not an although this is not an
exhaustive list: exhaustive list:
plan of premises and plan of premises and

equipment layout equipment layout
raw materials including raw materials including
introduction of utilities introduction of utilities
and other contact and other contact
materials, e.g. water, materials (e.g. water,
packaging packaging)
sequence and sequence and
interaction of all process interaction of all process
steps steps
outsourced processes outsourced processes
and subcontracted work and subcontracted work
process parameters potential for process
potential for process delay
delay rework and recycling
rework and recycling low-risk/high-risk/
low/high-care/high-risk high-care area
area segregation segregation
finished products, finished products,
intermediate/semi- intermediate/semi-
processed products, processed products,
by-products and waste. by-products and waste.

2.6VERIFY FLOW DIAGRAM CODEX ALIMENTARIUS STEP 5
ISSUE 6 ISSUE 7
2.6.1 The HACCP food safety 2.6.1 The HACCP food safety
team shall verify the team shall verify the
accuracy of the flow accuracy of the flow
diagrams by on-site audit diagrams by on-site audit
and challenge at least and challenge at least
annually. Daily and annually. Daily and
seasonal variations shall be seasonal variations shall be
considered and evaluated. considered and evaluated.
Records of verified flow Records of verified flow
diagrams shall be diagrams shall be
maintained. maintained.
2.7LIST ALL POTENTIAL HAZARDS ASSOCIATED WITH EACH PROCESS

STEP, CONDUCT A HAZARD ANALYSIS AND CONSIDER ANY MEASURES TO
CONTROL IDENTIFIED HAZARDS CODEX ALIMENTARIUS STEP 6, PRINCIPLE 1
ISSUE 6 ISSUE 7
team shall identify and team shall identify and
record all the potential record all the potential
hazards that are reasonably hazards that are reasonably
expected to occur at each expected to occur at each
step in relation to product, step in relation to product,
process and facilities. This process and facilities. This
shall include hazards shall include hazards
present in raw materials, present in raw materials,
those introduced during those introduced during
the process or surviving the process or surviving
the process steps, and the process steps, and
allergen risks (refer to allergen risks (refer to
clause 5.2). It shall also take clause 5.3). It shall also take
account of the preceding account of the preceding
and following steps in the and following steps in the
process chain. process chain.

ISSUE 6 ISSUE 7
team shall conduct a team shall conduct a
hazard analysis to identify hazard analysis to identify
hazards which need to be hazards which need to be
prevented, eliminated or prevented, eliminated or
reduced to acceptable reduced to acceptable
levels. Consideration shall levels. Consideration shall
be given to the following: be given to the following:
likely occurrence of likely occurrence of

hazard hazard
severity of the effects on severity of the effects on
consumer safety consumer safety
vulnerability of those vulnerability of those
exposed exposed
survival and survival and
multiplication of multiplication of
micro-organisms of micro-organisms of
specific concern to the specific concern to the
product product
presence or production presence or production
of toxins, chemicals or of toxins, chemicals or
foreign bodies foreign bodies
contamination of raw contamination of raw
materials, intermediate/ materials, intermediate/
semi-processed semi-processed
product, or finished product, or finished
product. product.
Where elimination of the Where elimination of the
hazard is not practical, hazard is not practical,
justification for acceptable justification for acceptable
levels of the hazard in the levels of the hazard in the
finished product shall be finished product shall be
determined and determined and
documented. documented.
team shall consider the team shall consider the
control measures control measures
necessary to prevent or necessary to prevent or
eliminate a food safety eliminate a food safety
hazard or reduce it to an hazard or reduce it to an
acceptable level. Where acceptable level. Where
the control is achieved the control is achieved
through existing through existing
prerequisite programmes, prerequisite programmes,
this shall be stated and the this shall be stated and the
adequacy of the adequacy of the
programme to control the programme to control the
hazard validated. specific hazard validated.
Consideration may be Consideration may be
given to using more than given to using more than
one control measure. one control measure.

2.8DETERMINE THE CRITICAL CONTROL POINTS (CCP) CODEX
ALIMENTARIUS STEP 7, PRINCIPLE 2
ISSUE 6 ISSUE 7
2.8.1 For each hazard that 2.8.1 For each hazard that
requires control, control requires control, control
points shall be reviewed to points shall be reviewed to
identify those that are identify those that are
critical. This requires a critical. This requires a
logical approach and may logical approach and may
be facilitated by use of a be facilitated by use of a
decision tree. CCPs shall decision tree. Critical
be those control points control points (CCPs) shall
which are required in order be those control points
to prevent or eliminate a which are required in order
food safety hazard or to prevent or eliminate a
reduce it to an acceptable food safety hazard or
level. If a hazard is identified reduce it to an acceptable
at a step where control is level. If a hazard is identified
necessary for safety but the at a step where control is
control does not exist, the necessary for safety but the
product or process shall be control does not exist, the
modified at that step, or at product or process shall be
an earlier step, to provide a modified at that step, or at
control measure. an earlier step, to provide a
control measure.
2.9ESTABLISH CRITICAL LIMITS FOR EACH CCP CODEX ALIMENTARIUS

STEP 8, PRINCIPLE 3
ISSUE 6 ISSUE 7
2.9.1 For each CCP, the 2.9.1 For each CCP, the Photographs
appropriate critical limits appropriate critical limits added by way of
shall be defined in order to shall be defined in order to an example.
identify clearly whether the identify clearly whether the
process is in or out of process is in or out of
control. Critical limits shall control. Critical limits shall
be: be:
measurable wherever measurable wherever

possible, e.g. time, possible (e.g. time,
temperature, pH temperature, pH)
supported by clear supported by clear
guidance or examples guidance or examples
where measures are where measures are
subjective, e.g. subjective (e.g.
photographs. photographs).

ISSUE 6 ISSUE 7
team shall validate each team shall validate each
CCP. Documented CCP. Documented
evidence shall show that evidence shall show that
the control measures the control measures
selected and critical limits selected and critical limits
identified are capable of identified are capable of
consistently controlling the consistently controlling the
hazard to the specified hazard to the specified
acceptable level. acceptable level.
2.10ESTABLISH A MONITORING SYSTEM FOR EACH CCP CODEX

ISSUE 6 ISSUE 7
2.10.1 A monitoring procedure 2.10.1 A monitoring procedure
shall be established for shall be established for
each CCP to ensure each CCP to ensure
compliance with critical compliance with critical
limits. The monitoring limits. The monitoring
system shall be able to system shall be able to
detect loss of control of detect loss of control of
CCPs and wherever CCPs and wherever
possible provide possible provide
information in time for information in time for
corrective action to be corrective action to be
taken. As a guide, taken. As a guide,
consideration may be consideration may be
given to the following, given to the following,
although this is not an although this is not an
exhaustive list: exhaustive list:
online measurement on-line measurement

offline measurement off-line measurement
continuous continuous
measurement, e.g. measurement (e.g.
thermographs, pH thermographs, pH
meters etc. meters etc.).
where discontinuous Thermographs included
measurement is used, in the bullet point
the system shall ensure
Where discontinuous
that the sample taken is
measurement is used, the
representative of the
system shall ensure that
batch of product.
thesample taken is
representative of the batch
of product.

ISSUE 6 ISSUE 7
2.10.2 Records associated with 2.10.2 Records associated with
the monitoring of each CCP the monitoring of each CCP
shall include the date, time shall include the date, time
and result of measurement and result of measurement
and shall be signed by the and shall be signed by the
person responsible for the person responsible for the
monitoring and verified, as monitoring and verified,
appropriate, by an when appropriate, by an
authorised person. Where authorised person. Where
records are in electronic records are in electronic
form there shall be form there shall be
evidence that records have evidence that records have
been checked and verified. been checked and verified.
2.11ESTABLISH A CORRECTIVE ACTION PLAN CODEX ALIMENTARIUS

STEP 10, PRINCIPLE 5
ISSUE 6 ISSUE 7
team shall specify and team shall specify and
document the corrective document the corrective
action to be taken when action to be taken when
monitored results indicate monitored results indicate
a failure to meet a control a failure to meet a control
limit, or when monitored limit, or when monitored
results indicate a trend results indicate a trend
towards loss of control. towards loss of control.
This shall include the action This shall include the action
to be taken by nominated to be taken by nominated
personnel with regard to personnel with regard to
any products that have any products that have
been manufactured during been manufactured during
the period when the the period when the
process was out of control. process was out of control.

2.12ESTABLISH VERIFICATION PROCEDURES CODEX ALIMENTARIUS
STEP 11, PRINCIPLE 6
ISSUE 6 ISSUE 7
2.12.1 Procedures of verification 2.12.1 Procedures of verification Slight wording
shall be established to shall be established to change to
confirm that the HACCP confirm that the HACCP emphasise the
plan, including controls plan, including controls on-going
managed by prerequisite managed by prerequisite expectation of
programmes, are effective. programmes, continues to effectiveness.
Examples of verification be effective. Examples of
activities include: verification activities
include:
internal audits
review of records where internal audits
acceptable limits have review of records where
been exceeded acceptable limits have
review of complaints by been exceeded
enforcement authorities review of complaints by
or customers enforcement authorities
review of incidents of or customers
product withdrawal or review of incidents of
recall. product withdrawal or
recall.
Results of verification shall
be recorded and Results of verification shall
communicated to the be recorded and
HACCP food safety team. communicated to the
HACCP food safety team.
2.13HACCP DOCUMENTATION AND RECORD KEEPING CODEX

ISSUE 6 ISSUE 7
2.13.1 Documentation and record 2.13.1 Documentation and record
keeping shall be sufficient keeping shall be sufficient
to enable the company to to enable the site to verify
verify that the HACCP that the HACCP controls,
controls, including controls including controls
managed by prerequisite managed by prerequisite
programmes, are in place programmes, are in place
and maintained. and maintained.

2.14REVIEW THE HACCP PLAN
ISSUE 6 ISSUE 7
2.14.1 The HACCP food safety 2.14.1 The HACCP food safety The addition of
team shall review the team shall review the changes to
HACCP plan and HACCP plan and process flow and
prerequisite programmes prerequisite programmes a recall to the list
at least annually and prior at least annually and prior of examples of
to any changes which may to any changes which may issues which
affect product safety. As a affect product safety. As a should trigger a
guide, these may include guide, these may include review of the
the following, although this the following, although this HACCP plan.
is not an exhaustive list: is not an exhaustive list:
change in raw materials change in raw materials

or supplier of raw or supplier of raw
materials materials
change in ingredients/ change in ingredients/
recipe recipe
change in processing change in processing
conditions or equipment conditions, process flow
change in packaging, or equipment
storage or distribution change in packaging,
conditions storage or distribution
change in consumer conditions
use change in consumer
emergence of a new use
risk, for example emergence of a new risk
adulteration of an (e.g. known adulteration
ingredient of an ingredient)
developments in following a recall
scientific information new developments in
associated with scientific information
ingredients, process or associated with
product. ingredients, process or
product.
Appropriate changes
resulting from the review Appropriate changes
shall be incorporated into resulting from the review
the HACCP plan and/or shall be incorporated into
prerequisite programmes, the HACCP plan and/or
fully documented and prerequisite programmes,
validation recorded. fully documented and
validation recorded.

3FOOD SAFETY AND QUALITY MANAGEMENT SYSTEM
3.1FOOD SAFETY AND QUALITY MANUAL

ISSUE 6 ISSUE 7
Statement of intent The companys processes Statement of intent The companys processes
and procedures to meet and procedures to meet
the requirements of this the requirements of this
Standard shall be Standard shall be
documented to allow documented to allow
consistent application, consistent application,
facilitate training, and facilitate training, and
support due diligence in support due diligence in
the production of a safe the production of a safe
product. product.
3.1.1 The companys 3.1.1 The sites documented

documented procedures, procedures, working
working methods and methods and practices
practices shall be collated shall be collated in the form
in the form of a printed or of a printed or electronic
electronic quality manual. quality manual.
3.1.2 The food safety and quality 3.1.2 The food safety and quality
manual shall be fully manual shall be fully
implemented and the implemented and the
manual or relevant manual or relevant
components shall be components shall be
readily available to key staff. readily available to relevant
staff.
3.1.3 All procedures and work 3.1.3 All procedures and work
instructions shall be clearly instructions shall be clearly
legible, unambiguous, in legible, unambiguous, in
appropriate languages and appropriate languages and
sufficiently detailed to sufficiently detailed to
enable their correct enable their correct
application by appropriate application by appropriate
staff. This shall include the staff. This shall include the
use of photographs, use of photographs,
diagrams or other pictorial diagrams or other pictorial
instructions where written instructions where written
communication alone is communication alone is
not sufficient (e.g. there are not sufficient (e.g. there are
issues of literacy or foreign issues of literacy or foreign
language). language).

3.2DOCUMENTATION CONTROL
ISSUE 6 ISSUE 7
Statement of intent The company shall operate Statement of intent The company shall operate
an effective document an effective document
control system to ensure control system to ensure
that only the correct that only the correct
versions of documents, versions of documents,
including recording forms, including recording forms,
are available and in use. are available and in use.
3.2.1 The company shall have a 3.2.1 The company shall have a
procedure to manage procedure to manage
documents which form part documents which form part
of the food safety and of the food safety and
quality system. This shall quality system. This shall
include: include:
a list of all controlled a list of all controlled

documents indicating documents indicating
the latest version the latest version
number number
the method for the the method for the
identification and identification and
authorisation of authorisation of
controlled documents controlled documents
a record of the reason a record of the reason
for any changes or for any changes or
amendments to amendments to
documents documents
the system for the the system for the
replacement of existing replacement of existing
documents when these documents when these
are updated. are updated.
3.3RECORD COMPLETION AND MAINTENANCE

ISSUE 6 ISSUE 7
Statement of intent The company shall Statement of intent The site shall maintain
maintain genuine records genuine records to
to demonstrate the demonstrate the effective
effective control of product control of product safety,
safety, legality and quality. legality and quality.
3.3.1 Records shall be legible, 3.3.1 Records shall be legible, Wording change
retained in good condition maintained in good to emphasise the
and retrievable. Any condition and retrievable. need for records
alterations to records shall Any alterations to records to be kept to
be authorised and shall be authorised and prevent
justification for alteration justification for alteration deterioration.
shall be recorded. Where shall be recorded. Where
records are in electronic records are in electronic
form these shall be suitably form these shall be suitably
backed up to prevent loss. backed up to prevent loss.

ISSUE 6 ISSUE 7
3.3.2 Records shall be retained 3.3.2 Records shall be retained
for a defined period with for a defined period with
consideration given to any consideration given to:
legal or customer
requirements and to the any legal or customer
requirements
shelf life of the product.
This shall take into account, the shelf life of the
product. (Both of these
where it is specified on the
aspects are bullet
label, the possibility that
pointed for clarity)
shelf life may be extended
by the consumer (e.g. by This shall take into account,
freezing). As a minimum, where it is specified on the
records shall be retained label, the possibility that
for the shelf life of the shelf life may be extended
product plus 12 months. by the consumer (e.g. by
freezing).
As a minimum, records
shall be retained for the
shelf life of the product plus
12 months.
3.4INTERNAL AUDITS
ISSUE 6 ISSUE 7
FUNDAMENTAL The company shall be able FUNDAMENTAL The company shall be able
Statement of intent to demonstrate it verifies Statement of intent to demonstrate it verifies
the effective application of the effective application of
the food safety plan and the the food safety plan and the
implementation of the implementation of the
requirements of the Global requirements of the Global
Standard for Food Safety. Standard for Food Safety.
3.4.1 There shall be a planned 3.4.1 There shall be a scheduled Wording change
programme of internal programme of internal to emphasise that
audits with a scope which audits throughout the year the internal audit
covers the implementation with a scope which covers is expected to
of the HACCP programme, the implementation of the consist of a series
prerequisite programmes HACCP programme, of audits of parts
and procedures prerequisite programmes of the system
implemented to achieve and procedures scheduled
this Standard. The scope implemented to achieve through the year
and frequency of the audits this Standard. The scope rather than a
shall be established in and frequency of the audits single annual
relation to the risks shall be established in audit.
associated with the activity relation to the risks
and previous audit associated with the activity
performance; all activities and previous audit
shall be covered at least performance; all activities
annually. shall be covered at least
annually.

ISSUE 6 ISSUE 7
3.4.2 Internal audits shall be 3.4.2 Internal audits shall be Rewording for
carried out by appropriately carried out by appropriately clarity but no
trained competent trained, competent material change.
auditors, who are auditors. Auditors shall be
independent from the independent (i.e. not audit
audited department. their own work).
3.4.3 The internal audit 3.4.3 The internal audit

programme shall be fully programme shall be fully
implemented. Internal audit implemented. Internal audit
reports shall identify reports shall identify
conformity as well as conformity as well as
non-conformity and the non-conformity and the
results shall be reported to results shall be reported to
the personnel responsible the personnel responsible
for the activity audited. for the activity audited.
Corrective actions and Corrective actions and
timescales for their timescales for their
implementation shall be implementation shall be
agreed and completion of agreed and completion of
the actions verified. the actions verified.
3.4.4 In addition to the internal 3.4.4 In addition to the internal

audit programme there audit programme there
shall be a programme of shall be a programme of
documented inspections documented inspections
to ensure that the factory to ensure that the factory
environment and environment and
processing equipment is processing equipment is
maintained in a suitable maintained in a suitable
condition for food condition for food
production. These production. These
inspections shall include: inspections shall include:
hygiene inspections to hygiene inspections to

assess cleaning and assess cleaning and
housekeeping housekeeping
performance performance
fabrication inspections fabrication inspections
to identify risks to the to identify risks to the
product from the product from the
building or equipment. building or equipment.
The frequency of these The frequency of these
inspections shall be based inspections shall be based
on risk but will be no less on risk but will be no less
than once per month in than once per month in
open product areas. open product areas.

3.5SUPPLIER AND RAW MATERIAL APPROVAL AND PERFORMANCE
MONITORING
3.5.1 MANAGEMENT OF SUPPLIERS OF RAW MATERIALS AND PACKAGING

ISSUE 6 ISSUE 7
Statement of intent The company shall have an FUNDAMENTAL The company shall have an Addition of
effective supplier approval Statement of intent effective supplier approval authenticity in
and monitoring system to and monitoring system to response to industry
ensure that any potential ensure that any potential issues.
risks from raw materials risks from raw materials
(including packaging) to (including packaging) to
the safety, legality and the safety, authenticity,
quality of the final product legality and quality of the
are understood and final product are
managed. understood and managed.
3.5.1.1 The company shall 3.5.1.1 The company shall Substitution or

undertake a documented undertake a documented fraud has been
risk assessment of each risk assessment of each added to the risk
raw material or group of raw raw material or group of raw factors. This will
materials to identify materials including relate directly to
potential risks to product packaging to identify the new clause
safety, legality and quality. potential risks to product 5.4.2.
This shall take into account safety, legality and quality.
An annual review
the potential for: This shall take into account
of the risk
the potential for:
allergen contamination assessment is
foreign body risks allergen contamination now required.
microbiological foreign-body risks This enables
contamination microbiological emerging issues
chemical contamination. contamination and recent
Consideration shall also be chemical contamination supplier history of
given to the significance of substitution or fraud performance to
(see clause 5.4.2). be considered
a raw material to the quality
and any
of the final product. Consideration shall also be
adjustment made
given to the significance of
The risk assessment shall to the risk
a raw material to the quality
form the basis for the raw assessment.
of the final product.
material acceptance and
testing procedure and for The risk assessment shall
the processes adopted for form the basis for the raw
supplier approval and material acceptance and
monitoring. testing procedure and for
the processes adopted for
supplier approval and
monitoring. The risk
assessments shall be
reviewed at least annually.

ISSUE 6 ISSUE 7
3.5.1.2 The company shall have a 3.5.1.2 The company shall have a Packaging has
documented supplier documented supplier been specifically
approval and ongoing approval and ongoing referenced in this
monitoring procedure to monitoring procedure to clause and
ensure that suppliers are ensure that all suppliers of suppliers of food
manufacturing products raw materials, including contact and
under hygienic conditions, packaging, (removal of consumer
effectively manage risks to hygienic conditions) packaging need
raw material quality and effectively manage risks to to be included.
safety and are operating raw material quality and
Further detail has
effective traceability safety and are operating
been provided
processes. The approval effective traceability
about the auditor
and monitoring procedure processes. The approval
and scope of an
shall be based on one or a and monitoring procedure
acceptable audit
combination of: shall be based on risk and
where this
supplier audits include one or a
process is used
third party audits or combination of:
for approval. This
certification, e.g. to BRC certification (e.g. to BRC is to ensure the
Global Standards Global Standards or validity of such
supplier questionnaires. other GFSI-recognised audits.
scheme) (moved up)
Where approval is based
on questionnaires, these supplier audits, with a The need for a list
of approved
scope to include
shall be reissued at least suppliers has
product safety,
every three years and been specifically
traceability, HACCP
suppliers required to notify noted. In practice
review and good
the site of any significant to comply fully
manufacturing
changes in the interim. with Issue 6 most
practices, undertaken
by an experienced and sites would
demonstrably already have such
competent product a list.
safety auditor
or, for suppliers assessed
as low risk only, supplier
questionnaires.
Where approval is based
on questionnaires, these
shall be reissued at least
every 3 years and suppliers
will be required to notify the
site of any significant
changes in the interim.
The site shall have an
up-to-date list of approved
suppliers.

ISSUE 6 ISSUE 7
3.5.1.3 Where raw materials are This new clause
(NEW) purchased from agents or works on the
brokers, the site shall know principle that the
the identity of the last same level of
manufacturer or packer, or assurance should
for bulk commodity be applied
products the consolidation irrespective of
place of the raw material. whether the raw
material is
Information to enable the
supplied via an
approval of the
agent or broker or
manufacturer, packer or
directly. It is
consolidator, as in clause
expected that the
3.5.1.2, shall be obtained
information
from the agent/broker or
necessary will be
directly from the supplier,
provided by the
unless the agent/broker is
agent or broker.
themselves certificated to
The intent is to
the BRC Global Standard
ensure
for Agents and Brokers.
transparency.
3.5.1.3 The procedures shall 3.5.1.4 (Now 3.5.1.4) The Exceptions have
define how exceptions are procedures shall define been extended in
handled (e.g. where raw how exceptions to the recognition that
material suppliers are supplier approval the more exacting
prescribed by a customer processes in clause 3.5.1.2 supplier approval
or where products are are handled (e.g. where raw process now
purchased from agents material suppliers are expected may be
and direct audit or prescribed by a customer) impractical where
monitoring has not been or where information for raw materials are
undertaken). effective supplier approval bulk commodity
is not available (e.g. bulk or agricultural
agricultural commodity products. In such
products) and instead cases, alternative
product testing is used to methods such as
verify product quality and testing may be
safety. used to ensure
the safety of the
When a site produces
raw materials.
customer-branded product
the relevant exceptions
shall be identified to the
customer.

3.5.2 RAW MATERIAL AND PACKAGING ACCEPTANCE AND MONITORING PROCEDURES
ISSUE 6 ISSUE 7
Statement of intent Controls on the Statement of intent Controls on the As in 3.5.1,
acceptance of raw acceptance of raw packaging has
materials shall ensure that materials including been specifically
raw materials do not packaging shall ensure that identified and the
compromise the safety, these do not compromise clause extended
legality or quality of the safety, legality or quality to include
products. of products and where authenticity.
appropriate any claims of
authenticity.
3.5.2.1 The company shall have a 3.5.2.1 The company shall have a Packaging
documented procedure for documented procedure for specifically
the acceptance of raw the acceptance of raw added to ensure
materials and packaging materials and packaging this is included as
on receipt based upon the on receipt based upon the a raw material.
risk assessment (3.5.1). risk assessment (clause
Additional
Raw material acceptance 3.5.1.1). Raw material
clarification that
and its release for use shall including packaging
results of tests are
be based on one or a acceptance and its release
reviewed.
combination of: for use shall be based on
one or a combination of:
visual inspection on
receipt product sampling and
certificates of testing (moved up)
conformance specific visual inspection on
to each consignment receipt (moved down)
certificates of analysis certificates of analysis
product sampling and specific to the
testing. consignment
A list of raw materials and certificates of
conformance. (moved
the requirements to be met
down)
for acceptance shall be
available. The parameters A list of raw materials
for acceptance and including packaging and
frequency of testing shall the requirements to be met
be clearly defined. for acceptance shall be
available. The parameters
for acceptance and
frequency of testing shall
be clearly defined,
implemented and
reviewed.
3.5.2.2 The procedures shall be Now included within

fully implemented and 3.5.2.1.
records maintained to
demonstrate the basis for
acceptance of each batch
of raw materials.

3.5.3 MANAGEMENT OF SUPPLIERS OF SERVICES
ISSUE 6 ISSUE 7
Statement of intent The company shall be able Statement of intent The company shall be able Risks to be
to demonstrate that where to demonstrate that where considered have
services are outsourced, services are outsourced been extended to
the service is appropriate the service is appropriate include legality
and any risks presented to and any risks presented to and quality to
food safety have been food safety, legality and bring this in line
evaluated to ensure quality have been with the wording
effective controls are in evaluated to ensure throughout the
place. effective controls are in Standard.
place.
3.5.3.1 There shall be a 3.5.3.1 There shall be a

documented procedure for documented procedure for
the approval and the approval and
monitoring of suppliers of monitoring of suppliers of
services. Such services services. Such services
shall include as shall include, as
appropriate: appropriate:
pest control pest control

laundry services laundry services
contracted cleaning contracted cleaning
contracted servicing contracted servicing
and maintenance of and maintenance of
equipment equipment
transport and transport and
distribution distribution
off-site storage of off-site storage of
ingredients, packaging ingredients, packaging
or products or products
laboratory testing laboratory testing
catering services catering services
waste management. waste management.
3.5.3.2 Contracts or formal 3.5.3.2 Contracts or formal

agreements shall exist with agreements shall exist with
the suppliers of services the suppliers of services
which clearly define service that clearly define service
expectations and ensure expectations and ensure
potential food safety risks potential food safety risks
associated with the service associated with the service
have been addressed. have been addressed.

3.5.4 MANAGEMENT OF OUTSOURCED PROCESSING AND PACKING
ISSUE 6 ISSUE 7
Statement of intent Where any intermediate Statement of intent Where any (removal of This change
process steps in the intermediate) process step extends
manufacture of a product in the manufacture or outsourced
which is included within the packing of a product which processing to
scope of certification is is included within the include packing
subcontracted to a third scope of certification is operations which
party or undertaken at subcontracted to a third were previously
another company site, this party or undertaken at outside the scope
shall be managed to ensure another (removal of of the audit.
this does not compromise company) site, this shall be
the safety, legality or quality managed to ensure it does
of the product. not compromise the safety,
legality, quality or
authenticity of the product.
3.5.4.1 The company shall be able 3.5.4.1 The company shall be able As above, this
to demonstrate that where to demonstrate that where significant
part of the production part of the production change extends
process is outsourced and process or final packing is the audit scope to
undertaken off site, this has outsourced and include the
been declared to the brand undertaken off-site this has management of
owner and, where required, been declared to the brand outsourced
approval granted. owner and, where required, operations
approval granted. packing the
product.
3.5.4.2 The company shall ensure 3.5.4.2 The company shall ensure The competence
that subcontractors are that subcontractors are of the auditor and
approved and monitored approved and monitored scope of the audit
by successful completion by successful completion have been added
of either a documented site of either: to ensure a
audit or third-party credible audit has
certification to the BRC certification to the taken place.
applicable BRC Global
Global Standard for Food
Standard for Food
Safety or other GFSI-
Safety or other GFSI-
recognised Standard (see
recognised scheme
Glossary).
a documented site audit
with a scope to include
product safety,
traceability, HACCP
review and good
manufacturing practices
by an experienced and
demonstrably
competent product
safety auditor.
(Bullet pointed for clarity
and certification audit
moved up for emphasis)

ISSUE 6 ISSUE 7
3.5.4.3 Any outsourced 3.5.4.3 Any outsourced Extended
processing operations processing or packing requirement to
shall: operations shall: reflect the
inclusion of
be undertaken in be undertaken in packing
accordance with accordance with
operations.
established contracts established contracts
which clearly define any which clearly define any
processing processing and/or
requirements and packing requirements
product specification and product
maintain product specification
traceability. maintain product
traceability.
3.5.4.4 The company shall 3.5.4.4 The company shall Extended

establish inspection and establish inspection and requirement to
test procedures for test procedures for reflect the
outsourced product on products where part of the inclusion of
return, including visual, processing or packing packing
chemical and/or have been outsourced, operations.
microbiological testing, including visual, chemical
dependent on risk and/or microbiological
assessment. testing, dependent on risk
assessment.
3.6SPECIFICATIONS
ISSUE 6 ISSUE 7
Statement of intent Specifications shall exist for Statement of intent Specifications shall exist for
raw materials including raw materials including
packaging, finished packaging, finished
products and any product products and any product
or service which could or service which could
affect the integrity of the affect the integrity of the
finished product. finished product.
3.6.1 Specifications for raw 3.6.1 Specifications for raw

materials and packaging materials and packaging
shall be adequate and shall be adequate and
accurate and ensure accurate and ensure
compliance with relevant compliance with relevant
safety and legislative safety and legislative
requirements. The requirements. The
specifications shall include specifications shall include
defined limits for relevant defined limits for relevant
attributes of the material attributes of the material
which may affect the quality which may affect the quality
or safety of the final or safety of the final
products (e.g. chemical, products (e.g. chemical,
microbiological or physical microbiological or physical
standards). standards).

ISSUE 6 ISSUE 7
3.6.2 Manufacturing instructions (Now in 6.1.1) This has been
and process specifications moved to section
shall comply with recipes 6.1.1, which
and quality criteria as covers
detailed in agreed processing
customer specifications. controls.
3.6.3 Specifications shall be 3.6.2 (Now 3.6.2) Accurate, New wording

available for all finished up-to-date specifications emphasises the
products. These shall shall be available for all need for
either be in the agreed finished products. These specifications to
format of the customer or, shall include key data to always be up to
in the case of branded meet customer and legal date, irrespective
products, include key data requirements and assist of if the 3 yearly
to meet legal requirements the user in the safe usage review is due.
and assist the customer in of the product.
the safe usage of the
product.
3.6.4 The company shall seek 3.6.3 (Now 3.6.3) The company
formal agreement of shall seek formal
specifications with relevant agreement of
parties. Where specifications with relevant
specifications are not parties. Where
formally agreed then the specifications are not
company shall be able to formally agreed then the
demonstrate that it has company shall be able to
taken steps to ensure demonstrate that it has
formal agreement is in taken steps to ensure
place. formal agreement is in
place.
3.6.5 Specifications shall be 3.6.4 (Now 3.6.4) Specifications

reviewed whenever shall be reviewed whenever
products change (e.g. products change (e.g.
ingredients, processing ingredients, processing
method) or at least every method) or at least every 3
three years. The date of years. The date of review
review and the approval of and the approval of any
any changes shall be changes shall be recorded.
recorded.

3.7CORRECTIVE AND PREVENTIVE ACTIONS
ISSUE 6 ISSUE 7
FUNDAMENTAL The company shall be able FUNDAMENTAL The site shall be able to
Statement of intent to demonstrate that they Statement of intent demonstrate that it uses
use the information from the information from
identified failures in the identified failures in the
food safety and quality food safety and quality
management system to management system to
make necessary make necessary
corrections and prevent corrections and prevent
recurrence. recurrence.
3.7.1 The company shall have a 3.7.1 The site shall have a Although the
documented procedure for documented procedure for clause has been
handling non- handling and correcting split into two
conformances identified failures identified in the parts, the actual
within the scope of this food safety and quality requirements
Standard to include: system. remain
unchanged from
clear documentation of (Now split into two clauses)
Issue 6.
the non-conformity
assessment of
consequences by a
suitably competent and
authorised person
identification of the
corrective action to
address the immediate
issue
identification of an
appropriate timescale
for correction
identification of
personnel with
appropriate authority
responsible for
corrective action
verification that the
corrective action has
been implemented and
is effective
identification of the root
cause of the non-
conformity and
implementation of any
necessary corrective
action.

ISSUE 6 ISSUE 7
3.7.2 (NEW) Where a non-conformity Although the
places the safety, legality or clause has been
quality of products at risk split into two
this shall be investigated parts, the actual
and recorded including: requirements
remain
clear documentation of unchanged from
the non-conformity
Issue 6.
assessment of
consequences by a
suitably competent and
authorised person
the action to address
the immediate issue
an appropriate
timescale for correction
the person responsible
for correction
verification that the
correction has been
implemented and is
effective
identification of the root
cause of the non-
conformity and
implementation of any
necessary actions to
prevent recurrence.
3.8CONTROL OF NON-CONFORMING PRODUCT

ISSUE 6 ISSUE 7
Statement of intent The company shall ensure Statement of intent The site shall ensure that
that any out-of- any out-of-specification
specification product is product is effectively
effectively managed to managed to prevent
prevent release. unauthorised release.
3.8.1 There shall be documented 3.8.1 There shall be documented

procedures for managing procedures for managing
non-conforming products non-conforming products.
which include: These procedures shall
include:
the requirement for staff
to identify and report the requirement for staff
potentially non- to identify and report a
conforming product potentially non-
clear identification of conforming product
non-conforming clear identification of a
product, e.g. direct non-conforming
labelling or the use of IT product (e.g. direct
systems labelling or the use of IT
systems)

ISSUE 6 ISSUE 7
3.8.1 cont. secure storage to 3.8.1 cont. secure storage to Wording changed
prevent accidental prevent accidental in recognition of
release, e.g. isolation release (e.g. physical or the widespread
areas computer-based use of
referral to the brand isolation) computerised
owner where required referral to the brand warehouse
defined responsibilities owner where required location and
for decision making on defined responsibilities picking systems
the use or disposal of for decision making on to block the
products appropriate to the use or disposal of release of
the issue, e.g. products appropriate to products.
destruction, reworking, the issue (e.g.
downgrading to an destruction, reworking,
alternative label or downgrading to an
acceptance by alternative label or
concession acceptance by
records of the decision concession)
on the use or disposal of records of the decision
the product on the use or disposal of
records of destruction the product
where product is records of destruction
destroyed for food where a product is
safety reasons. destroyed for food
safety reasons.
3.9TRACEABILITY
ISSUE 6 ISSUE 7
FUNDAMENTAL The company shall be able FUNDAMENTAL The site shall be able to
Statement of intent to trace all raw material Statement of intent trace all raw material
product lots (including product lots (including
packaging) from their packaging) from its
supplier through all stages suppliers through all stages
of processing and of processing and dispatch
despatch to their customer to its customers and vice
and vice versa. versa.
3.9.1 Identification of raw 3.9.1 Identification of raw

materials, including primary materials, including primary
and any other relevant and any other relevant
packaging and processing packaging, processing
aids, intermediate/ aids, intermediate/
semi-processed products, semi-processed products,
part used materials, part-used materials,
finished products and finished products and
materials pending materials pending
investigation shall be investigation shall be
adequate to ensure adequate to ensure
traceability. traceability.

ISSUE 6 ISSUE 7
3.9.2 The company shall test the 3.9.2 The site shall test the Primary
traceability system across traceability system across packaging i.e.
the range of product the range of product food contact and
groups to ensure groups to ensure consumer
traceability can be traceability can be packaging added
determined from raw determined from raw to the traceability
material to finished product material including primary exercise.
and vice versa, including packaging to finished
quantity check/mass product and vice versa,
balance. This shall occur at including quantity check/
a predetermined frequency mass balance. This shall
and results shall be occur at a predetermined
retained for inspection. The frequency, as a minimum
test shall take place at least annually (moved into this
annually. Full traceability sentence), and results shall
should be achievable be retained for inspection.
within four hours. Full traceability should be
achievable within 4 hours.
3.9.3 (NEW) The company shall ensure This new clause is

that its suppliers of raw designed to
materials have an effective ensure absolute
traceability system. confidence in
traceability
Where a supplier has been
systems operated
approved based on a
by raw material
questionnaire, instead of
suppliers. This is
certification or audit,
of greatest
verification of the suppliers
relevance where
traceability system shall be
raw material
carried out on first approval
suppliers are
and then at least every 3
approved based
years. This may be
on questionnaires,
achieved by a traceability
in which case
test. Where a raw material
additional
is received directly from a
information will
farm or fish farm, further
be required to
verification of the farms
verify effective
traceability system is not
traceability
mandatory.
systems are in
place.
3.9.3 Where rework or any 3.9.4 (Now 3.9.4) Where rework

reworking operation is or any reworking operation
performed, traceability is performed, traceability
shall be maintained. shall be maintained.

3.10COMPLAINT HANDLING
ISSUE 6 ISSUE 7
Statement of intent Customer complaints shall Statement of intent Customer complaints shall
be handled effectively and be handled effectively and
information used to reduce information used to reduce
recurring complaint levels. recurring complaint levels.
3.10.1 All complaints shall be 3.10.1 All complaints shall be

recorded, investigated and recorded, investigated and
the results of the the results of the
investigation and root investigation (removal of
cause of the issue recorded and root cause which is
where sufficient information now in 3.10.2) of the issue
is provided. Actions recorded where sufficient
appropriate to the information is provided.
seriousness and frequency Actions appropriate to the
of the problems identified seriousness and frequency
shall be carried out of the problems identified
promptly and effectively by shall be carried out
appropriately trained staff. promptly and effectively by
appropriately trained staff.
3.10.2 Complaint data shall be 3.10.2 Complaint data shall be The need for root
analysed for significant analysed for significant cause analysis
trends and used to trends. Where there has has been clarified
implement ongoing been a significant increase and is required
improvements to product in a complaint or a serious now only in
safety, legality and quality, complaint, root cause response to a
and to avoid recurrence. analysis shall be used to significant
This analysis shall be made implement ongoing increase in
available to relevant staff. improvements to product complaints or
safety, legality and quality, serious
and to avoid recurrence. complaints.
This analysis shall be made
available to relevant staff.

3.11MANAGEMENT OF INCIDENTS, PRODUCT WITHDRAWAL AND PRODUCT
RECALL
ISSUE 6 ISSUE 7
Statement of intent The company shall have a Statement of intent The company shall have a
plan and system in place to plan and system in place to
effectively manage effectively manage
incidents and enable the incidents and enable the
effective withdrawal and effective withdrawal and
recall of products should recall of products should
this be required. this be required.
3.11.1 The company shall have 3.11.1 The company shall have Direct reference
documented procedures documented procedures to business
designed to report and designed to report and continuity has
effectively manage effectively manage been removed
incidents and potential incidents and potential and instead the
emergency situations that emergency situations that contingency
impact food safety, legality impact food safety, legality planning has
or quality. This shall include or quality. This shall include been restricted to
consideration of consideration of managing
contingency plans to contingency plans to product safety
maintain business maintain product safety, quality and
continuity. Incidents may quality and legality. legality.
include: Incidents may include:
disruption to key disruption to key

services such as water, services such as water,
energy, transport, energy, transport,
refrigeration processes, refrigeration processes,
staff availability and staff availability and
communications communications
events such as fire, flood events such as fire, flood
or natural disaster or natural disaster
malicious contamination malicious contamination
or sabotage. or sabotage.
Where products which Where products which
have been released from have been released from
the site may be affected by the site may be affected by
an incident, consideration an incident, consideration
shall be given to the need shall be given to the need
to withdraw or recall to withdraw or recall
products. products.

ISSUE 6 ISSUE 7
3.11.2 The company shall have a 3.11.2 The company shall have a
documented product documented product
withdrawal and recall withdrawal and recall
procedure. This shall procedure. This shall
include as a minimum: include as a minimum:
identification of key identification of key

personnel constituting personnel constituting
the recall management the recall management
team, with clearly team, with clearly
identified identified
responsibilities responsibilities
guidelines for deciding guidelines for deciding
whether a product whether a product
needs to be recalled or needs to be recalled or
withdrawn and the withdrawn and the
records to be records to be
maintained maintained
an up-to-date list of key an up-to-date list of key
contacts or reference to contacts (including
the location of such a out-of-hours contact
list, e.g. recall details) or reference to
management team, the location of such a list
emergency services, (e.g. recall management
suppliers, customers, team, emergency
Certification Body, services, suppliers,
regulatory authority customers, certification
a communication plan body, regulatory
including the provision authority)
of information to a communication plan
customers, consumers including the provision
and regulatory of information to
authorities in a timely customers, consumers
manner and regulatory
details of external authorities in a timely
agencies providing manner
advice and support as details of external
necessary, e.g. agencies providing
specialist laboratories, advice and support as
regulatory authority and necessary (e.g.
legal expertise specialist laboratories,
a plan to handle the regulatory authority and
logistics of product legal expertise)
traceability, recovery or a plan to handle the
disposal of affected logistics of product
product and stock traceability, recovery or
reconciliation. disposal of affected
product, and stock
The procedure shall be
reconciliation.
capable of being operated
at any time. The procedure shall be
capable of being operated
at any time.

ISSUE 6 ISSUE 7
3.11.3 The product recall and 3.11.3 The product recall and
withdrawal procedures withdrawal procedures
shall be tested, at least shall be tested, at least
annually, in a way that annually, in a way that
ensures their effective ensures their effective
operation. Results of the operation. Results of the
test shall be retained and test shall be retained and
shall include timings of key shall include timings of key
activities. The results of the activities. The results of the
test and of any actual recall test and of any actual recall
shall be used to review the shall be used to review the
procedure and implement procedure and implement
improvements as improvements as
necessary. necessary.
3.11.4 In the event of a product 3.11.4 In the event of a product

recall, the Certification recall, the certification
Body issuing the current body issuing the current
certificate for the site certificate for the site
against this Standard shall against this Standard shall
be informed within three be informed within 3
working days of the working days of the
decision to issue a recall. decision to issue a recall.
3.12CUSTOMER FOCUS AND COMMUNICATION (NEW)

ISSUE 6 ISSUE 7
Statement of intent The company shall ensure These new
that any customer-specific clauses have
policies or requirements been added to
are understood, ensure that
implemented and clearly customer policies
communicated to relevant are understood
staff and where appropriate and followed. This
suppliers of raw materials, provides a link
packaging and services. between the BRC
audit and specific
customer
expectations.
3.12.1 (NEW) Where a company is At the audit, the

requested to follow specific site will be
customer requirements, expected to be
codes of practice, methods able to
of working etc., these shall demonstrate how
be made known to relevant they access
staff within the site and customer policies
implemented. where these exist
and demonstrate
compliance.

ISSUE 6 ISSUE 7
3.12.2 (NEW) Effective processes shall Where customer
be in place for policies also
communicating customer- apply to raw
specific requirements to material suppliers
the suppliers of raw then the method
materials and services as of informing such
applicable. suppliers needs
to be
demonstrated.

4SITE STANDARDS
4.1EXTERNAL STANDARDS
ISSUE 6 ISSUE 7
Statement of intent The production site shall be Statement of intent The production site shall be The word design
of suitable size, location, of suitable size, location has been changed
construction and design to and construction, and be to maintain as
reduce the risk of maintained to reduce the this is more
contamination and facilitate risk of contamination and applicable.
the production of safe and facilitate the production of
legal finished products. safe and legal finished
products.
4.1.1 Consideration shall be 4.1.1 Consideration shall be

given to local activities and given to local activities and
the site environment, which the site environment, which
may have an adverse may have an adverse
impact on finished product impact on finished product
integrity, and measures integrity, and measures
shall be taken to prevent shall be taken to prevent
contamination. Where contamination. Where
measures have been put measures have been put
into place to protect the site into place to protect the site
(from potential (from potential
contaminants, flooding contaminants, flooding
etc.), they shall be reviewed etc.), they shall be reviewed
in response to any in response to any
changes. changes.
4.1.2 The external areas shall be 4.1.2 The external areas shall be
maintained in good order. maintained in good order.
Where buildings are Where buildings are
surrounded by grassed or surrounded by grassed or
planted areas, they shall be planted areas, they shall be
regularly tended and regularly tended and well
well-maintained. External maintained. External traffic
traffic routes under site routes under site control
control shall be suitably shall be suitably surfaced
surfaced and maintained in and maintained in good
good repair to avoid repair to avoid
contamination of the contamination of the
product. product.
4.1.3 The building fabric shall be 4.1.3 The building fabric shall be
maintained to minimise maintained to minimise
potential for product potential for product
contamination (e.g. contamination (e.g.
elimination of bird roosting elimination of bird roosting
sites, sealing gaps around sites, sealing gaps around
pipes to prevent pest entry, pipes to prevent pest entry,
ingress of water and other ingress of water and other
contaminants). contaminants).

4.2SECURITY
ISSUE 6 ISSUE 7
Statement of intent Security systems shall Statement of intent Security systems shall
ensure that products are ensure that products are
protected from theft or protected from theft or
malicious contamination malicious contamination
whilst under the control of while under the control of
the site. the site.
4.2.1 The company shall 4.2.1 The company shall

undertake a documented undertake a documented
assessment of the security assessment of the security
arrangements and arrangements and
potential risks to the potential risks to the
products from any products from any
deliberate attempt to inflict deliberate attempt to inflict
contamination or damage. contamination or damage.
Areas shall be assessed Areas shall be assessed
according to risk; sensitive according to risk; sensitive
or restricted areas shall be or restricted areas shall be
defined, clearly marked, defined, clearly marked,
monitored and controlled. monitored and controlled.
Identified security Identified security
arrangements shall be arrangements to reduce
implemented and reviewed risks shall be implemented
at least annually. and reviewed at least
annually.
4.2.2 Measures shall be in place 4.2.2 Measures shall be in place

to ensure only authorised to ensure only authorised
personnel have access to personnel have access to
production and storage production and storage
areas and access to the site areas, and access to the
by employees, contractors site by employees,
and visitors shall be contractors and visitors
controlled. A visitor shall be controlled. A visitor
reporting system shall be in reporting system shall be in
place. Staff shall be trained place. Staff shall be trained
in site security procedures in site security procedures
and encouraged to report and encouraged to report
unidentified or unknown unidentified or unknown
visitors. visitors.
4.2.3 (NEW) External storage tanks, Further detailed

silos and any intake pipes controls on
with an external opening external storage
shall be locked. to prevent access
for malicious
contamination.
4.2.3 Where required by 4.2.4 (Now 4.2.4) Where

legislation, the site shall be required by legislation, the
registered with, or be site shall be registered with,
approved by, the or be approved by, the
appropriate authority. appropriate authority.

4.3LAYOUT, PRODUCT FLOW AND SEGREGATION
ISSUE 6 ISSUE 7
FUNDAMENTAL The factory layout, flow of FUNDAMENTAL The factory layout, flow of
Statement of intent processes and movement Statement of intent processes and movement
of personnel shall be of personnel shall be
sufficient to prevent the risk sufficient to prevent the risk
of product contamination of product contamination
and to comply with relevant and to comply with relevant
legislation. legislation.
4.3.1 There shall be a plan of the 4.3.1 There shall be a map of the New production
site which designates areas site which designates areas zone for ambient
where product is at (zones) where product is at high care has
different levels of risk from different levels of risk from been identified as
contamination; that is: contamination; that is: applicable.
enclosed product areas high-risk areas (moved It is also expected

low-risk areas up) for clarity that
high-care areas high-care areas (moved non-production
high-risk areas. up) areas e.g. offices,
See Appendix 2 for ambient high-care canteen are
guidance. This shall be low-risk areas (moved identified as such
down) on the site plans.
taken into account when
determining the enclosed product areas
(moved down)
prerequisite programmes
for the particular areas of non-product areas.
the site. See Appendix 2 for
guidelines on defining the
production risk zones.
This zoning shall be taken
into account when
determining the
prerequisite programmes
for the particular areas of
the site.
4.3.2 The site plan shall define: 4.3.2 The site map(s) shall The requirements
define: for the site map
access points for have been
personnel and travel access points for extended to
routes personnel (removed
provide a more
location of staff facilities travel routes moved
comprehensive
and routes to the into 3rd bullet point)
identification of
facilities from places of access points for raw
routes of
work materials (including
movement to
production process flow packaging)
identify potential
routes for the removal of routes of movement for
areas of cross-
waste personnel
contamination.
routes for the movement routes of movement for
of rework. raw materials

ISSUE 6 ISSUE 7
4.3.2 cont. If it is necessary to allow 4.3.2 cont. routes for the removal of
access through production waste
areas, designated routes for the movement
walkways shall be provided of rework
that ensure there is location of any staff
adequate segregation from facilities including
materials. All facilities shall changing rooms, toilets,
be designed and canteens and smoking
positioned, where areas
possible, so that movement production process
of personnel is by simple, flow.
logical routes. The
(Final paragraph removed
movement of waste and
as deemed to be covered
rework shall not
by 4.3.4)
compromise the safety of
products.
4.3.3 Contractors and visitors, 4.3.3 Contractors and visitors, Wording change
including drivers, shall be including drivers, shall be to clarify the
made aware of all made aware of all controls expected
procedures for access to procedures for access to where contractors
premises and the premises and the are on site.
requirements of the areas requirements of the areas
they are visiting, with they are visiting, with
special reference to special reference to
hazards and potential hazards and potential
product contamination. product contamination.
Contractors involved in Contractors working in
maintenance or repair product processing or
activities shall be under the storage areas (replaces
supervision of a nominated maintenance and repair
person. workers) shall be the
responsibility of a
nominated person.
4.3.4 In low-risk areas the 4.3.4 The movement of The new wording
process flow together with personnel, raw materials, builds upon the
the use of demonstrably packaging, rework and/or requirement in
effective procedures shall waste shall not 4.3.2 to identify
be in place to minimise the compromise the safety of routes of
risk of the contamination of products. The process movement.
raw materials, intermediate/ flow, together with the use
semi-processed products, of demonstrably effective
packaging and finished procedures, shall be in
products. place to minimise the risk of
the contamination of raw
materials, intermediate/
semi-processed products,
packaging and finished
products.

ISSUE 6 ISSUE 7
4.3.5 Where high-care areas are 4.3.6 (Now 4.3.6) Where There are slight
part of the manufacturing high-care areas are part of changes to the
site there should be the manufacturing site wording to make
physical segregation there should be physical the clause clearer,
between these areas and segregation between these including
other parts of the site. areas and other parts of the reference to a
Segregation shall take into site. Segregation shall take documented risk
account the flow of into account the flow of assessment.
product, nature of product, nature of materials
materials, equipment, (including packaging),
personnel, waste, airflow, equipment, personnel,
air quality and utilities waste, airflow, air quality
provision. Where physical and utilities provision
barriers are not in place, the (including drains). Where
site shall have undertaken a physical barriers are not in
full evaluation of the risks of place, the site shall have
cross-contamination and undertaken a documented
alternative effective risk assessment of the
processes shall be in place potential for cross-
to protect products from contamination, and
contamination. (removal of alternative)
effective, validated
processes shall be in place
to protect products from
contamination.
4.3.6 Where high-risk areas are 4.3.5 (Now 4.3.5) Where

part of the manufacturing high-risk areas are part of
site, there shall be physical the manufacturing site,
segregation between these there shall be physical
areas and other parts of the segregation between these
site. Segregation shall take areas and other parts of the
into account the flow of site. Segregation shall take
product, nature of into account the flow of
materials, equipment, product, nature of materials
personnel, waste, airflow, (including packaging),
air quality and utilities equipment, personnel,
provision. The location of waste, airflow, air quality
transfer points shall not and utilities provision
compromise the (including drains). The
segregation between location of transfer points
high-risk areas and other shall not compromise the
areas of the factory. segregation between
Practices shall be in place high-risk areas and other
to minimise risk of product areas of the factory.
contamination (e.g. the Practices shall be in place
disinfection of materials on to minimise risk of product
entry). contamination (e.g. the
disinfection of materials on
entry).

ISSUE 6 ISSUE 7
4.3.7 (NEW) Where ambient high-care New clause
areas are required a setting
documented risk requirements for
assessment shall be ambient product
completed to determine manufacturers
the risk of cross- who have high-
contamination with care areas.
pathogens. The risk
assessment shall take into
account the potential
sources of microbiological
contamination and include:
the raw materials and

products
flow of raw materials,
packaging, products,
equipment, personnel
and waste
airflow and air quality
utilities (including
drains).
Effective processes shall
be in place to protect the
final product from this
contamination. These
processes may include
segregation, management
of process flow or other
controls.
4.3.7 Premises shall allow 4.3.8 (Now 4.3.8) Premises shall

sufficient working space allow sufficient working
and storage capacity to space and storage
enable all operations to be capacity to enable all
carried out properly under operations to be carried
safe hygienic conditions. out properly under safe
hygienic conditions.
4.3.8 Temporary structures 4.3.9 (Now 4.3.9) Temporary

constructed during structures constructed
building work or during building work or
refurbishment, etc. shall be refurbishment etc. shall be
designed and located to designed and located to
avoid pest harbourage and avoid pest harbourage and
ensure the safety and ensure the safety and
quality of products. quality of products.

4.4BUILDING FABRIC: RAW MATERIAL HANDLING, PREPARATION,
PROCESSING, PACKING AND STORAGE AREAS
ISSUE 6 ISSUE 7
Statement of intent The fabrication of the site, Statement of intent The fabrication of the site,
buildings and facilities shall buildings and facilities shall
be suitable for the intended be suitable for the intended
purpose. purpose.
4.4.1 Walls shall be constructed, 4.4.1 Walls shall be (removal of

finished and maintained to constructed) finished and
prevent the accumulation maintained to prevent the
of dirt, minimise accumulation of dirt,
condensation and mould minimise condensation
growth, and facilitate and mould growth, and
cleaning. facilitate cleaning.
4.4.2 Floors shall be suitably 4.4.2 Floors shall be suitably Additional

hard wearing to meet the hard wearing to meet the wording added to
demands of the process, demands of the process, identify the need
and withstand cleaning and withstand cleaning for floors to be
materials and methods. materials and methods. easily cleaned.
They shall be impervious They shall be impervious,
and maintained in good be maintained in good
repair. repair and facilitate
cleaning.
4.4.3 Drainage, where provided, 4.4.3 Drainage, where provided,

shall be sited, designed shall be sited, designed
and maintained to minimise and maintained to minimise
risk of product risk of product
contamination and not contamination and not
compromise product compromise product
safety. Machinery and safety. Machinery and
piping shall be arranged so piping shall be arranged so
that, wherever feasible, that, wherever feasible,
process waste water goes process waste water goes
directly to drain. Where directly to drain. Where
significant amounts of significant amounts of
water are used, or direct water are used, or direct
piping to drain is not piping to drain is not
feasible, floors shall have feasible, floors shall have
adequate falls to cope with adequate falls to cope with
the flow of any water or the flow of any water or
effluent towards suitable effluent towards suitable
drainage. drainage.

ISSUE 6 ISSUE 7
4.4.4 Where sites include 4.4.4 Where sites include Word plan
high-care or high-risk high-risk or high-care replaced by map
facilities, there shall be a facilities, there shall be a the intent
plan of the drains for these map of the drains for these remains the same
areas which shows the areas which shows the but map was more
direction of flow and direction of flow and internationally
location of any equipment location of any equipment recognised.
fitted to prevent the back fitted to prevent the
up of waste water. The flow back-up of waste water.
of drains shall not present a The flow of drains shall not
risk of contamination of the present a risk of
high-care/risk area. contamination of the
high-risk/care area.
4.4.5 Ceilings and overheads 4.4.5 Ceilings and overheads

shall be constructed, shall be constructed,
finished and maintained to finished and maintained to
prevent the risk of product prevent the risk of product
contamination. contamination.
4.4.6 Where suspended ceilings 4.4.6 Where suspended ceilings

or roof voids are present, or roof voids are present,
adequate access to the adequate access to the
void shall be provided to void shall be provided to
facilitate inspection for pest facilitate inspection for pest
activity, unless the void is activity, unless the void is
fully sealed. fully sealed.
4.4.7 Where there is a risk to 4.4.7 Where there is a risk to

product, windows, and roof product, windows, and roof
glazing which is designed glazing which is designed
to be opened for ventilation to be opened for ventilation
purposes, shall be purposes, shall be
adequately screened to adequately screened to
prevent the ingress of prevent the ingress of
pests. pests.
4.4.8 Where they pose a risk to 4.4.8 Where they pose a risk to
product, glass windows product, glass windows
shall be protected against shall be protected against
breakage. breakage.

ISSUE 6 ISSUE 7
4.4.9 Doors shall be maintained 4.4.9 Doors shall be maintained
in good condition. External in good condition:
doors and dock levellers
shall be close fitting or External doors and dock
levellers shall be close
adequately proofed.
fitting or adequately
External doors to open
proofed.
product areas shall not be
opened during production External doors to open
product areas shall not
periods except in
be opened during
emergencies. Where
production periods
external doors to enclosed
except in emergencies.
product areas are opened,
suitable precautions shall (bullet pointed for clarity)
be taken to prevent pest Where external doors to
ingress. enclosed product areas are
opened, suitable
precautions shall be taken
to prevent pest ingress.
4.4.10 Suitable and sufficient 4.4.10 Suitable and sufficient

lighting shall be provided lighting shall be provided
for correct operation of for correct operation of
processes, inspection of processes, inspection of
product and effective product and effective
cleaning. cleaning.
4.4.11 Where they constitute a 4.4.11 Where they constitute a

risk to product, bulbs and risk to product, bulbs and
strip lights including strip lights including
those on electric fly-killer those on electric fly-killer
devices shall be devices shall be
adequately protected. adequately protected.
Where full protection Where full protection
cannot be provided, cannot be provided,
alternative management alternative management
such as wire mesh screens such as wire-mesh screens
or monitoring procedures or monitoring procedures
shall be in place. shall be in place.
4.4.12 Adequate ventilation and 4.4.12 Adequate ventilation and

extraction shall be extraction shall be
provided in product provided in product
storage and processing storage and processing
environments to prevent environments to prevent
condensation or excessive condensation or excessive
dust. dust.

ISSUE 6 ISSUE 7
4.4.13 High-risk areas shall be 4.4.13 High-risk areas shall be
supplied with sufficient supplied with sufficient
changes of filtered air. The changes of filtered air. The
filter specification used and filter specification used and
frequency of air changes frequency of air changes
shall be documented. This shall be documented. This
shall be based on a risk shall be based on a risk
assessment, taking into assessment, taking into
account the source of the account the source of the
air and the requirement to air and the requirement to
maintain a positive air maintain a positive air
pressure relative to the pressure relative to the
surrounding areas. surrounding areas.
4.5UTILITIES WATER, ICE, AIR AND OTHER GASES

ISSUE 6 ISSUE 7
Statement of intent Utilities used within the Statement of intent Utilities used within the
production and storage production and storage
areas shall be monitored to areas shall be monitored to
effectively control the risk effectively control the risk
of product contamination. of product contamination.
4.5.1 All water used as a raw 4.5.1 All water used as a raw Hand washing
material in the manufacture material in the manufacture added for
of processed food, the of processed food, the completeness.
preparation of product, or preparation of product,
Scope of the test
for equipment or plant hand-washing or for
i.e. the chemicals
cleaning shall be supplied equipment or plant
and
in sufficient quantity, be cleaning shall be supplied
microbiological
potable at point of use or in sufficient quantity, be
contaminants to
pose no risk of potable at point of use or
be tested, need to
contamination according pose no risk of
be defined.
to applicable legislation. contamination according
The microbiological and to applicable legislation.
chemical quality of water The microbiological and
shall be analysed at least chemical quality of water
annually. The sampling shall be analysed at least
points and frequency of annually. The sampling
analysis shall be based on points, scope of the test
risk, taking into account the and frequency of analysis
source of the water, on-site shall be based on risk,
storage and distribution taking into account the
facilities, previous sample source of the water, on-site
history and usage. storage and distribution
facilities, previous sample
history and usage.

ISSUE 6 ISSUE 7
4.5.2 An up-to-date plan shall be 4.5.2 An up-to-date schematic Wording changed
available of the water diagram shall be available to allow a diagram
distribution system on site, of the water distribution identifying the
including holding tanks, system on site, including process steps
water treatment and water holding tanks, water rather than a
recycling as appropriate. treatment and water physical map of
The plan shall be used as a recycling as appropriate. the site.
basis for water sampling The diagram shall be used
and the management of as a basis for water
water quality. sampling and the
management of water
quality.
4.5.3 Where legislation 4.5.3 Where legislation

specifically permits the use specifically permits the use
of water which may not be of water which may not be
potable for initial product potable for initial product
cleaning (e.g. for the cleaning (e.g. for the
storage/washing of fish), storage/washing of fish),
the water shall meet the the water shall meet the
designated legal designated legal
requirement for this requirements for this
operation. operation.
4.5.4 Air, other gases and steam 4.5.4 Air, other gases and steam
used directly in contact used directly in contact
with or as an ingredient in with, or as an ingredient in,
products shall be products shall be
monitored to ensure this monitored to ensure this
does not represent a does not represent a
contamination risk. contamination risk.
Compressed air used Compressed air used
directly in contact with the directly in contact with the
product shall be filtered. product shall be filtered.
4.6EQUIPMENT
ISSUE 6 ISSUE 7
Statement of intent All food processing Statement of intent All food-processing
equipment shall be suitable equipment shall be suitable
for the intended purpose for the intended purpose
and shall be used to and shall be used to
minimise the risk of minimise the risk of
contamination of product. contamination of product.
4.6.1 All equipment shall be 4.6.1 All equipment shall be

constructed of appropriate constructed of appropriate
materials. The design and materials. The design and
placement of equipment placement of equipment
shall ensure it can be shall ensure it can be
effectively cleaned and effectively cleaned and

ISSUE 6 ISSUE 7
4.6.2 Equipment which is in 4.6.2 Equipment which is in
direct contact with food direct contact with food
shall be suitable for food shall be suitable for food
contact and meet legal contact and meet legal
requirements where requirements where
applicable. applicable.
4.7MAINTENANCE
ISSUE 6 ISSUE 7
Statement of intent An effective maintenance Statement of intent An effective maintenance
programme shall be in programme shall be in
operation for plant and operation for plant and
equipment to prevent equipment to prevent
contamination and reduce contamination and reduce
the potential for the potential for
breakdowns. breakdowns.
4.7.1 There shall be a 4.7.1 There shall be a

documented planned documented planned
maintenance schedule or maintenance schedule or
condition monitoring condition monitoring
system which includes all system which includes all
plant and processing plant and processing
equipment. The equipment. The
maintenance requirements maintenance requirements
shall be defined when shall be defined when
commissioning new commissioning new
equipment. equipment.
4.7.2 In addition to any planned 4.7.2 In addition to any planned

maintenance programme, maintenance programme,
where there is a risk of where there is a risk of
product contamination by product contamination by
foreign bodies arising from foreign bodies arising from
equipment damage, the equipment damage, the
equipment shall be equipment shall be
inspected at inspected at
predetermined intervals, predetermined intervals,
inspection results inspection results
documented and documented and
appropriate action taken. appropriate action taken.
4.7.3 Where temporary repairs 4.7.3 Where temporary repairs

are made, these shall be are made, these shall be
controlled to ensure the controlled to ensure the
safety or legality of product safety or legality of a
is not jeopardised. These product is not jeopardised.
temporary measures shall These temporary measures
be permanently repaired as shall be permanently
soon as practicable and repaired as soon as
within a defined timescale. practicable and within a
defined timescale.

ISSUE 6 ISSUE 7
4.7.4 The company shall ensure 4.7.4 The site shall ensure that
that the safety or legality of the safety or legality of
product is not jeopardised product is not jeopardised
during maintenance and during maintenance and
subsequent cleaning subsequent cleaning
operations. Maintenance operations. Maintenance
work shall be followed by a work shall be followed by a
documented hygiene documented hygiene
clearance procedure, clearance procedure,
which records that product which records that product
contamination hazards contamination hazards
have been removed from have been removed from
machinery and equipment. machinery and equipment.
4.7.5 (NEW) Maintenance activities New clause

undertaken in high-risk and further specifying
high-care areas shall management of
respect the segregation cross-
requirements of the area. contamination
Wherever possible tools risk from tools in
and equipment shall be the high-risk/care
dedicated for use in the areas.
area and be retained in the
area.
4.7.5 Materials used for 4.7.6 (Now 4.7.6) Materials used Addition of
equipment and plant for equipment and plant allergenic status
maintenance and that pose maintenance and that pose for lubricants to
a risk by direct or indirect a risk by direct or indirect be known so that
contact with raw materials, contact with raw materials, this does not
intermediate and finished intermediate and finished become an
products, such as products, such as allergen hazard.
lubricating oil, shall be food lubricating oil, shall be food
grade. grade and of a known
allergen status.
4.7.6 Engineering workshops 4.7.7 (Now 4.7.7) Engineering The specific

shall be kept clean and tidy workshops shall be kept method of
and controls shall be in clean and tidy and controls preventing
place to prevent shall be in place to prevent engineering
contamination risks to the (removal of contamination debris from
product (e.g. provision of risks to the product and entering
swarf mats at the entrance/ examples) transfer of production areas
exit of workshops). engineering debris to i.e. swarf mats
production or storage was not
areas. internationally
understood and
this has been
replaced by the
intent.

4.8STAFF FACILITIES
ISSUE 6 ISSUE 7
Statement of intent Staff facilities shall be Statement of intent Staff facilities shall be
sufficient to accommodate sufficient to accommodate
the required number of the required number of
personnel, and shall be personnel, and shall be
designed and operated to designed and operated to
minimise the risk of product minimise the risk of product
contamination. The contamination. The
facilities shall be facilities shall be
maintained in good and maintained in good and
clean condition. clean condition.
4.8.1 Designated changing 4.8.1 Designated changing

facilities shall be provided facilities shall be provided
for all personnel, whether for all personnel, whether
staff, visitor or contractor. staff, visitor or contractor.
These shall be sited to These shall be sited to
allow direct access to the allow direct access to the
production, packing or production, packing or
storage areas without storage areas without
recourse to any external recourse to any external
area. Where this is not area. Where this is not
possible, a risk assessment possible, a risk assessment
shall be carried out and shall be carried out and
procedures implemented procedures implemented
accordingly (e.g. the accordingly (e.g. the
provision of cleaning provision of cleaning
facilities for footwear). facilities for footwear).
4.8.2 Storage facilities of 4.8.2 Storage facilities of

sufficient size to sufficient size to
accommodate personal accommodate personal
items shall be provided for items shall be provided for
all personnel who work in all personnel who work in
raw material handling, raw material handling,
preparation, processing, preparation, processing,
packing and storage areas. packing and storage areas.
4.8.3 Outdoor clothing and other 4.8.3 Outdoor clothing and other Production
personal items shall be personal items shall be clothing has
stored separately from stored separately from replaced work
workwear within the production clothing within wear as this was
changing facilities. the changing facilities. considered more
Facilities shall be available Facilities shall be available universally
to separate clean and dirty to separate clean and dirty understood.
workwear. production clothing.

ISSUE 6 ISSUE 7
4.8.4 Where an operation 4.8.5 (Now 4.8.5) Where an New
includes a high-care area, operation includes a requirements that
personnel shall enter via a high-care area, personnel site-provided
specially designated shall enter via a specially footwear cannot
changing facility with designated changing be worn outside
arrangements to ensure facility with arrangements of the factory to
that protective clothing will to ensure that protective restrict
not be contaminated clothing will not be contamination of
before entry to the contaminated before entry footwear and
high-care area. The to the high-care area. This reduce risk where
changing facilities shall shall (removal of changing foot baths are
incorporate the following facilities duplication) used. The
requirements: incorporate the following position
requirements: statement on the
clear instructions for the use of boot-wash
order of changing into Clear instructions for the facilities from
dedicated protective order of changing into
Issue 6 has now
clothes to prevent the and out of dedicated
been
contamination of clean protective clothes to
incorporated into
clothing prevent the
the Standard.
dedicated footwear, by contamination of clean
Note however the
exception shoe clothing
new requirement
coverings shall be Site-provided footwear
to have
provided for visitors only shall not be worn
environmental
to be worn in the outside the factory.
monitoring to
high-care area Protective clothing shall
monitor the
an effective system shall be visually distinctive
effectiveness of
be provided to from that worn in lower
whichever
segregate areas for risk areas and shall not
footwear process
wearing high-care from be worn outside of the
is in place.
other footwear (e.g. a high-care area. (moved
barrier or bench system) up)
or there shall be an Hand-washing during
effective boot wash on the changing procedure
entrance to the high- shall be incorporated to
care area prevent contamination
protective clothing shall of the clean protective
be visually distinctive clothing
from that worn in lower On entry to high-care
risk areas and shall not areas, hand-washing
be worn outside of the and disinfection shall be
high-care area provided and used.

ISSUE 6 ISSUE 7
4.8.4 cont. hand-washing during 4.8.5 cont. There shall be an effective

the changing procedure control of footwear to
shall be incorporated to prevent the introduction of
prevent contamination pathogens into high-care
of the clean protective areas. This may be by a
clothing controlled change of
on entry to high-care footwear before entering
areas, hand-washing the area or by the use of
and disinfection shall be controlled and managed
provided. boot-wash facilities.
(Variation on bullet point 3
in the old 4.8.4)
A programme of
environmental monitoring
shall be established to
assess the effectiveness of
footwear controls.
4.8.5 Where an operation 4.8.4 (Now 4.8.4) Where an There has been a
includes a high-risk area, operation includes a slight change to
personnel shall enter via a high-risk area, personnel the wording.
specially designated shall enter via a specially
The position
changing facility at the designated changing
statement from
entrance to the high-risk facility at the entrance to
Issue 6 has been
area. The changing the high-risk area. The
incorporated,
facilities shall include the changing facilities shall
allowing
following requirements: meet the following
controlled use of
clear instructions for the requirements:
boot-wash
order of changing into Clear instructions shall facilities in place
dedicated protective be provided for the of a compulsory
clothes to prevent the order of changing into change of foot
contamination of clean and out of dedicated wear.
clothing protective clothes to
dedicated footwear shall prevent the A new
requirement has
be provided to be worn contamination of clean
in the high-risk area clothing. been added to
an effective system shall Protective clothing shall require an

environmental
be provided to be visually distinctive
segregate areas for from that worn in other monitoring
wearing high-risk and areas and shall not be programme to be
other footwear, e.g. a worn outside the in place.
barrier or bench system high-risk area. (moved
up)

ISSUE 6 ISSUE 7
4.8.5 cont. protective clothing shall 4.8.4 cont. Hand-washing during

be visually distinctive the changing procedure
from that worn in other shall be incorporated to
areas and shall not be prevent contamination
worn outside of the of the clean protective
high-risk area clothing (i.e. hand-
hand-washing during washing after hair
the changing procedure covering and footwear
shall be incorporated to has been put on, but
prevent contamination before handling clean
of the clean protective protective clothing).
clothing Prior to entry to high-risk
on entry to high-risk areas, hand-washing
areas, hand-washing and disinfection shall be
and disinfection shall be provided and used.
provided. Dedicated footwear
shall be provided to be
worn in the high-risk
area with an effective
system to segregate
areas for wearing
high-risk and other
footwear (i.e. a barrier or
bench system). By
exception the use of
boot-wash facilities are
accepted where these
demonstrably provide
an effective control of
footwear to prevent the
introduction of
pathogenic material into
high-risk areas.
A programme of
environmental monitoring
shall be established to
assess the effectiveness of
footwear controls.

ISSUE 6 ISSUE 7
4.8.6 Suitable and sufficient 4.8.6 Suitable and sufficient Minor change to
hand-washing facilities hand-washing facilities the order of
shall be provided at access shall be provided at access clauses and to
to, and at other appropriate to, and at other appropriate confirm that liquid
points within, production points within, production or foam soaps are
areas. Such hand-wash areas. Such hand-washing acceptable for
facilities shall provide as a facilities shall provide as a hand washing.
minimum: minimum:
sufficient quantity of advisory signs to
water at a suitable prompt hand-washing
temperature (moved up)
liquid soap a sufficient quantity of
single use towels or water at a suitable
suitably designed and temperature (moved
located air driers down)
water taps with hand- water taps with hands-
free operation free operation (moved
advisory signs to up)
prompt hand-washing. liquid/foam soap
(moved down)
single-use towels or
suitably designed and
located air driers.
(moved down)
4.8.7 Toilets shall be adequately 4.8.7 Toilets shall be adequately

segregated and shall not segregated and shall not
open directly into open directly into
production, packing and production or packing
storage areas. Toilets shall areas (removal of storage
be provided with hand- areas).
washing facilities
Toilets shall be provided
comprising:
with hand-washing
basins with soap and facilities comprising:
water at a suitable
temperature basins with soap and
water at a suitable
adequate hand-drying
temperature
facilities
advisory signs to adequate hand-drying
facilities
prompt hand-washing.
advisory signs to
Where hand-washing prompt hand-washing.
facilities within toilet
Where hand-washing
facilities are the only
facilities within toilet
facilities provided before
facilities are the only
re-entering production, the
facilities provided before
requirements of 4.8.6 shall
re-entering production, the
apply and signs shall be in
requirements of clause
place to direct people to
4.8.6 shall apply and signs
hand-wash facilities before
shall be in place to direct
entering production.
people to hand-washing
facilities before entering
production.

ISSUE 6 ISSUE 7
4.8.8 Where smoking is allowed 4.8.8 Where smoking is allowed With the advent of
under national law, under national law, the use of
designated controlled designated controlled electronic
smoking areas shall be smoking areas shall be cigarettes, the
provided which are both provided which are both clause has been
isolated from production isolated from production updated to
areas to an extent that areas to an extent that identify these as
ensures smoke cannot ensures smoke cannot unsuitable to be
reach the product and reach the product and brought into
fitted with sufficient fitted with sufficient production areas.
extraction to the exterior of extraction to the exterior of
the building. Adequate the building. Adequate
arrangements for dealing arrangements for dealing
with smokers waste shall with smokers waste shall
be provided at smoking be provided at smoking
facilities, both inside and at facilities, both inside and at
exterior locations. exterior locations.
Electronic cigarettes shall
not be permitted to be used
or brought into production
or storage areas.
4.8.9 All food brought into 4.8.9 All food brought into
manufacturing premises by manufacturing premises by
staff shall be appropriately staff shall be appropriately
stored in a clean and stored in a clean and
hygienic state. No food hygienic state. No food
shall be taken into storage, shall be taken into storage,
processing or production processing or production
areas. Where eating of food areas. Where eating of food
is allowed outside during is allowed outside during
breaks, this shall be in breaks, this shall be in
suitable designated areas suitable designated areas
with appropriate control of with appropriate control of
waste. waste.
4.8.10 Where catering facilities 4.8.10 Where catering facilities

are provided on the are provided on the
premises, they shall be premises, they shall be
suitably controlled to suitably controlled to
prevent contamination of prevent contamination of
product (e.g. as a source of products (e.g. as a source
food poisoning or of food poisoning or
introduction of allergenic introduction of allergenic
material to the site). material to the site).

4.9CHEMICAL AND PHYSICAL PRODUCT CONTAMINATION CONTROL:
RAW MATERIAL HANDLING, PREPARATION, PROCESSING, PACKING AND
STORAGE AREAS
4.9.1 CHEMICAL CONTROL

ISSUE 6 ISSUE 7
Statement of intent Appropriate facilities and Statement of intent Appropriate facilities and
procedures shall be in procedures shall be in
place to control the risk of place to control the risk of
chemical or physical chemical or physical
contamination of product. contamination of product.
4.9.1.1 Processes shall be in place 4.9.1.1 Processes shall be in place Slight change in
to manage the use, storage to manage the use, storage terminology to
and handling of non-food and handling of non-food emphasise the
chemicals to prevent chemicals to prevent intent for the
chemical contamination. chemical contamination. store to be
These shall include as a These shall include as a designated for
minimum: minimum: storage of
chemicals, with
an approved list of an approved list of access
chemicals for purchase chemicals for purchase
controlled.
availability of material availability of material
safety data sheets and safety data sheets and
specifications specifications
confirmation of confirmation of
suitability for use in a suitability for use in a
food processing food-processing
environment environment
avoidance of strongly avoidance of strongly
scented products scented products
the labelling and/or the labelling and/or
identification of identification of
containers of chemicals containers of chemicals
at all times at all times
segregated and secure a designated storage
storage with restricted area with restricted
access to authorised access to authorised
personnel personnel
use by trained personnel use by trained personnel
only. only.
4.9.1.2 Where strongly scented or 4.9.1.2 Where strongly scented or

taint-forming materials taint-forming materials
have to be used, for have to be used, for
instance for building work, instance for building work,
place to prevent the risk of place to prevent the risk of
taint contamination of taint contamination of
products. products.

4.9.2 METAL CONTROL
ISSUE 6 ISSUE 7
4.9.2.1 There shall be a 4.9.2.1 There shall be a
documented policy for the documented policy for the
control of the use of sharp control of the use of sharp
metal implements metal implements
including knives, cutting including knives, cutting
blades on equipment, blades on equipment,
needles and wires. This needles and wires. This
shall include a record of shall include a record of
inspection for damage and inspection for damage and
the investigation of any lost the investigation of any lost
items. Snap-off blade items. Snap-off-blade
knives shall not be used. knives shall not be used.
4.9.2.2 The purchase of 4.9.2.2 The purchase of

ingredients and packaging ingredients and packaging
which use staples or other which use staples or other
foreign-body hazards as foreign-body hazards as
part of the packaging part of the packaging
materials shall be avoided. materials shall be avoided.
Staples and paper clips Staples, paper clips and
shall not be used in open drawing pins shall not be
product areas. Where used in open product
staples or other items are areas. Where staples or
present as packaging other items are present as
materials or closures, packaging materials or
appropriate precautions closures, appropriate
shall be taken to minimise precautions shall be taken
the risk of product to minimise the risk of
contamination. product contamination.
4.9.3 GLASS, BRITTLE PLASTIC, CERAMICS AND SIMILAR MATERIALS

ISSUE 6 ISSUE 7
4.9.3.1 Glass or other brittle 4.9.3.1 Glass or other brittle
materials shall be excluded materials shall be excluded
or protected against or protected against
breakage in areas where breakage in areas where
open products are handled open products are handled
or there is a risk of product or there is a risk of product

ISSUE 6 ISSUE 7
4.9.3.2 Documented procedures 4.9.3.2 Documented procedures Slight rewording
for handling glass and for handling glass and for clarification
other brittle materials shall other brittle materials (other only.
be in place and than product packaging)
implemented to ensure that shall be in place where
necessary precautions are open products are handled
taken. Procedures shall or there is a risk of product
include as a minimum: contamination. These
procedures shall include as
a list of items detailing a minimum:
location, number, type
and condition a list of items detailing
recorded checks of location, number, type
condition of items, and condition
carried out at a specified recorded checks of
frequency that is based condition of items,
on the level of risk to the carried out at a specified
product frequency that is based
details on cleaning or on the level of risk to the
replacing items to product
minimise potential for details on cleaning or
product contamination. replacing items to
minimise potential for
product contamination.
4.9.3.3 Documented procedures 4.9.3.3 Documented procedures

detailing the action to be detailing the action to be
taken in case of breakage taken in case of breakage
of glass or other brittle of glass or other brittle
items shall be implemented items shall be implemented
and include the following: and include the following:
quarantining the quarantining the

products and products and
production area that production area that
were potentially affected were potentially affected
cleaning the production cleaning the production
area area
inspecting the inspecting the
production area and production area and
authorising to continue authorising to continue
production production
changing of workwear changing of workwear
and inspection of and inspection of
footwear footwear
specifying those staff specifying those staff
authorised to carry out authorised to carry out
the above points the above points
recording the breakage recording the breakage
incident. incident.

4.9.3.4 Products packed into glass or other brittle containers (NOW 4.9.4)
ISSUE 6 ISSUE 7
4.9.3.4.1 The storage of the 4.9.4.1 (Now 4.9.4.1) The storage
containers shall be of the containers shall be
segregated from the segregated from the
storage of raw materials, storage of raw materials,
product or other product or other
packaging. packaging.
4.9.3.4.2 Systems shall be in place to 4.9.4.2 (Now 4.9.4.2) Systems shall

manage container be in place to manage
breakages between the container breakages
container cleaning/ between the container
inspection point and cleaning/inspection point
container closure. This and container closure. This
shall include, as a shall include, as a
minimum, documented minimum, documented
instructions which ensure: instructions which ensure:
the removal and the removal and

disposal of at-risk disposal of at-risk
products in the vicinity products in the vicinity
of the breakage; this of the breakage; this
may be specific for may be specific for
different equipment or different equipment or
areas of the production areas of the production
line line
the effective cleaning of the effective cleaning of
the line or equipment the line or equipment
which may be which may be
contaminated by contaminated by
fragments of the fragments of the
container. Cleaning shall container; cleaning shall
not result in the further not result in the further
dispersal of fragments, dispersal of fragments,
for instance by the use for instance by the use
of high pressure water or of high pressure water or
air air
the use of dedicated, the use of dedicated,
clearly identifiable clearly identifiable
cleaning equipment cleaning equipment
(e.g. colour coded) for (e.g. colour coded) for
removal of container removal of container
breakages. Such breakages; such
stored separately from stored separately from
other cleaning other cleaning
equipment equipment

ISSUE 6 ISSUE 7
4.9.3.4.2 the use of dedicated, 4.9.4.2 cont. the use of dedicated,

cont. accessible lidded waste accessible, lidded waste
containers for the containers for the
collection of damaged collection of damaged
containers and containers and
fragments fragments
a documented a documented
inspection of production inspection of production
equipment is equipment is
undertaken following undertaken following
the cleaning of a the cleaning of a
breakage to ensure breakage to ensure
cleaning has effectively cleaning has effectively
removed any risk of removed any risk of
further contamination further contamination
authorisation is given for authorisation is given for
production to re-start production to restart
following cleaning following cleaning
the area around the line the area around the line
is kept clear of broken is kept clear of broken
glass. glass.
4.9.3.4.3 Records shall be 4.9.4.3 (Now 4.9.4.3) Records shall

maintained of all container be maintained of all
breakages on the line. container breakages on the
Where no breakages have line. Where no breakages
occurred during a have occurred during a
production period, this production period, this
shall also be recorded. This shall also be recorded. This
record shall be reviewed to record shall be reviewed to
identify trends and identify trends and
potential line or container potential line or container
improvements. improvements.
4.9.4WOOD (NOW 4.9.5)

ISSUE 6 ISSUE 7
4.9.4.1 Wood should not be used 4.9.5.1 (Now 4.9.5.1) Wood should
in open product areas not be used in open
except where this is a product areas except
process requirement (e.g. where this is a process
maturation of products in requirement (e.g.
wood). Where the use of maturation of products in
wood cannot be avoided, wood). Where the use of
the condition of wood shall wood cannot be avoided,
be continually monitored to the condition of wood shall
ensure it is in good be continually monitored to
condition and free from ensure it is in good
damage or splinters which condition and free from
could contaminate damage or splinters which
products. could contaminate
products.

4.10FOREIGN-BODY DETECTION AND REMOVAL EQUIPMENT
4.10.1FOREIGN-BODY DETECTION AND REMOVAL EQUIPMENT

ISSUE 6 ISSUE 7
Statement of intent The risk of product Statement of intent The risk of product
contamination shall be contamination shall be
reduced or eliminated by reduced or eliminated by
the effective use of the effective use of
equipment to remove or equipment to remove or
detect foreign bodies. detect foreign bodies.
4.10.1.1 A documented assessment 4.10.1.1 A documented assessment

in association with the in association with the
HACCP study shall be HACCP study shall be
carried out on each carried out on each
production process to production process to
identify the potential use of identify the potential use of
equipment to detect or equipment to detect or
remove foreign body remove foreign-body
contamination. Typical contamination. Typical
equipment to be equipment to be
considered may include: considered may include:
filters filters
sieves sieves
metal detection metal detection
magnets magnets
optical sorting optical sorting
equipment equipment
X-ray detection X-ray detection
equipment equipment
other physical other physical
separation equipment separation equipment
e.g. gravity separation, (e.g. gravity separation,
fluid bed technology. fluid bed technology).
4.10.1.2 The type, location and 4.10.1.2 The type, location and
sensitivity of the detection sensitivity of the detection
and/or removal method and/or removal method
shall be specified as part of shall be specified as part of
the companys the sites documented
documented system. system. Industry best
Industry best practice shall practice shall be applied
be applied with regard to with regard to the nature of
the nature of the ingredient, the ingredient, material,
material, product and/or product and/or the packed
the packed product. The product. The location of
location of the equipment the equipment or any other
or any other factors factors influencing the
influencing the sensitivity sensitivity of the equipment
of the equipment shall be shall be validated and
validated and justified. justified.

ISSUE 6 ISSUE 7
4.10.1.3 The company shall ensure 4.10.1.3 The site shall ensure that
that the frequency of the the frequency of the testing
testing of the foreign body of the foreign-body
detection and/or removal detection and/or removal
equipment is defined and equipment is defined and
takes into consideration: takes into consideration:
specific customer specific customer

requirements requirements
the companys ability to the sites ability to
identify, hold and identify, hold and
prevent the release of prevent the release of
any affected materials, any affected materials,
should the equipment should the equipment
fail. fail.
4.10.1.4 Where foreign material is 4.10.1.4 Where foreign material is

detected or removed by the detected or removed by the
equipment, the source of equipment, the source of
any unexpected material any unexpected material
shall be investigated. shall be investigated.
Information on rejected Information on rejected
materials shall be used to materials shall be used to
identify trends and where identify trends and where
possible instigate possible instigate
preventive action to reduce preventive action to reduce
the occurrence of the occurrence of
contamination by the contamination by the
foreign material. foreign material.
4.10.2 FILTERS AND SIEVES

ISSUE 6 ISSUE 7
4.10.2.1 Filters and sieves used for 4.10.2.1 Filters and sieves used for
foreign body control shall foreign-body control shall
be of a specified mesh size be of a specified mesh size
or gauge and designed to or gauge and designed to
provide the maximum provide the maximum
practical protection for the practical protection for the
product. Material retained product. Material retained
or removed by the system or removed by the system
shall be examined and shall be examined and
recorded to identify recorded to identify
contamination risks. contamination risks.

ISSUE 6 ISSUE 7
4.10.2.2 Filters and sieves shall be 4.10.2.2 Filters and sieves shall be
regularly inspected or regularly inspected or
tested for damage on a tested for damage on a
documented frequency documented frequency
based on risk. Records based on risk. Records
shall be maintained of the shall be maintained of the
checks. Where defective checks. Where defective
filters or sieves are filters or sieves are
identified this shall be identified this shall be
recorded and the potential recorded and the potential
for contamination of for contamination of
products investigated and products investigated and
appropriate action taken. appropriate action taken.
4.10.3 METAL DETECTORS AND X-RAY EQUIPMENT

ISSUE 6 ISSUE 7
4.10.3.1 Metal detection equipment 4.10.3.1 Metal detection equipment
shall be in place unless risk shall be in place unless risk
assessment demonstrates assessment demonstrates
that this does not improve that this does not improve
the protection of final the protection of final
products from metal products from metal
contamination. Where contamination. Where
metal detectors are not metal detectors are not
used justification shall be used justification shall be
documented. The absence documented. The absence
of metal detection would of metal detection would
only normally be based on only normally be based on
the use of an alternative, the use of an alternative,
more effective, method of more effective method of
protection (e.g. use of protection (e.g. use of
X-ray, fine sieves or filtration X-ray, fine sieves or filtration
of products). of products).
4.10.3.2 Where metal detectors or Removed as covered by

X-ray equipment is used, 4.10.1.2
this shall be situated at the
latest practical step in the
process flow and, wherever
possible, after the product
has been packaged.

ISSUE 6 ISSUE 7
4.10.3.3 The metal detector or X-ray 4.10.3.2 (Now 4.10.3.2) The metal
equipment shall detector or X-ray
incorporate one of the equipment shall
following: incorporate one of the
an automatic rejection following:
device, for continuous an automatic rejection
in-line systems, which device, for continuous
shall either divert in-line systems, which
contaminated product shall either divert
out of the product flow contaminated product
or to a secure unit out of the product flow
accessible only to or to a secure unit
authorised personnel accessible only to
a belt stop system with authorised personnel
an alarm where the a belt stop system with
product cannot be an alarm where the
automatically rejected, product cannot be
e.g. for very large packs automatically rejected
in-line detectors which (e.g. for very large
identify the location of packs)
the contaminant shall be in-line detectors which
operated to allow identify the location of
effective segregation of the contaminant to allow
the affected product. effective segregation of
the affected product.
4.10.3.4 The company shall 4.10.3.3 (Now 4.10.3.3) The site

establish and implement shall establish and
documented procedures implement documented
for the operation and procedures for the
testing of the metal or X-ray operation and testing of the
equipment. This shall metal or X-ray equipment.
include as a minimum: This shall include as a
responsibilities for the minimum:
testing of equipment responsibilities for the
the operating testing of equipment
effectiveness and the operating
sensitivity of the effectiveness and
equipment and any sensitivity of the
variation to this for equipment and any
particular products variation to this for
the methods and particular products
frequency of checking the methods and
the detector frequency of checking
recording of the results the detector
of checks. recording of the results
of checks.

ISSUE 6 ISSUE 7
4.10.3.5 Metal detector checking 4.10.3.4 (Now 4.10.3.4) Metal Recognition that
procedures shall be based detector checking for products in foil
on best practice and shall procedures shall be based packs it may be
as a minimum include: on good practice and shall appropriate to
use of test pieces as a minimum include the
following:
have only ferrous
test pieces.
incorporating a sphere
of metal of a known Use of test pieces Additional clause
diameter. The test incorporating a sphere requiring checks
pieces shall be marked of metal of a known on fail safe
with the size and type of diameter selected on systems which
test material contained the basis of risk. The test prevent the metal
tests carried out using pieces shall be marked detector
separate test pieces with the size and type of operating if there
containing ferrous test material contained. is a fault; for
metal, stainless steel Tests carried out using example,
and typically non- separate test pieces problems with
ferrous metal, unless the containing ferrous reject system
product is within a foil metal, stainless steel reject bin full, etc
container and typically non- (where fitted).
a test that both the ferrous metal, unless the
New expectation
detection and rejection product is within a foil
mechanisms are container where ferrous that where
working effectively only may be applicable. product flow
under normal working A test that both the metal detectors
are used it is
conditions detection and rejection
checks that test the mechanisms are working necessary to
understand the
memory/reset function effectively under normal
of the metal detector by working conditions. speed of the
passing successive test Checks that test the product through
the pipe to
packs through the unit. memory/reset function
of the metal detector by establish that the
In addition, where metal
passing successive test reject system is
detectors are incorporated
packs through the unit correctly
on conveyors:
at typical line operating synchronised
the test piece shall be speed. with the detection
passed as close as
possible to the centre of Checks of failsafe systems of metal.
fitted to the detection and
the metal detector
rejection systems.
aperture and wherever
possible be carried out In addition, where metal
by inserting the test detectors are incorporated
piece within a clearly on conveyors, the test
identified sample pack piece shall be passed as
of the food being close as possible to the
produced at the time of centre of the metal detector
the test. aperture and wherever
possible be carried out by
inserting the test piece
within a clearly identified
sample pack of the food
being produced at the time
of the test.

ISSUE 6 ISSUE 7
4.10.3.5 Where in-line metal 4.10.3.4 Where in-line metal

cont. detectors are used the test cont. detectors are used the test
piece shall be placed in the piece shall be placed in the
product flow wherever this product flow wherever this
is possible. is possible and the correct
timing of the rejection
system to remove identified
contamination shall be
validated.
4.10.3.6 The company shall 4.10.3.5 (Now 4.10.3.5) The site

establish and implement shall establish and
corrective action and implement corrective
reporting procedures in the action and reporting
event of the testing procedures in the event of
procedure identifying any the testing procedure
failure of the foreign body identifying any failure of the
detector. Action shall foreign-body detector.
include a combination of Action shall include a
isolation, quarantining and combination of isolation,
re-inspection of all product quarantining and re-
produced since the last inspection of all product
successful test. produced since the last
successful test.
4.10.4MAGNETS
ISSUE 6 ISSUE 7
4.10.4.1 The type, location and the 4.10.4.1 The type, location and
strength of magnets shall strength of magnets shall
be fully documented. be fully documented.
Documented procedures Documented procedures
shall be in place for the shall be in place for the
inspection, cleaning, inspection, cleaning,
strength testing and strength testing and
integrity checks. Records integrity checks. Records
of all checks shall be of all checks shall be
4.10.5 OPTICAL SORTING EQUIPMENT

ISSUE 6 ISSUE 7
4.10.5.1 Each unit shall be checked 4.10.5.1 Each unit shall be checked
in accordance with the in accordance with the
manufacturers instructions manufacturers instructions
or recommendations. or recommendations.
Checks shall be Checks shall be
documented. documented.

4.10.6 CONTAINER CLEANLINESS GLASS JARS, CANS AND OTHER RIGID CONTAINERS
ISSUE 6 ISSUE 7
4.10.6.1 Based on risk assessment, 4.10.6.1 Based on risk assessment,
procedures shall be procedures shall be
implemented to minimise implemented to minimise
foreign body foreign-body
contamination originating contamination originating
with the packaging with the packaging
container (e.g. jars, cans container (e.g. jars, cans
and other preformed rigid and other pre-formed rigid
containers). This may containers). This may
include the use of covered include the use of covered
conveyors, container conveyors, container
inversion and foreign body inversion and foreign-body
removal through rinsing removal through rinsing
with water or air jets. with water or air jets.
4.10.6.2 The effectiveness of the 4.10.6.2 The effectiveness of the

container cleaning container cleaning
checked and recorded checked and recorded
during each production. during each production.
Where the system Where the system
incorporates a rejection incorporates a rejection
system for dirty or system for dirty or
damaged containers, the damaged containers, the
check shall incorporate a check shall incorporate a
test of both the detection test of both the detection
and effective rejection of and effective rejection of
the test container. the test container.
4.11HOUSEKEEPING AND HYGIENE

ISSUE 6 ISSUE 7
FUNDAMENTAL Housekeeping and FUNDAMENTAL Housekeeping and
Statement of intent cleaning systems shall be Statement of intent cleaning systems shall be
in place which ensure in place which ensure
appropriate standards of appropriate standards of
hygiene are maintained at hygiene are maintained at
all times and the risk of all times and the risk of
product contamination is product contamination is
minimised. minimised.
4.11.1 (NEW) The premises and New clause to

equipment shall be enable more
maintained in a clean and consistent
hygienic condition. allocation of
non-conformities
where examples
of poor cleaning
are identified.

ISSUE 6 ISSUE 7
4.11.1 Documented cleaning 4.11.2 (Now 4.11.2) Documented Modification of
procedures shall be in cleaning procedures shall the requirement
place and maintained for be in place and maintained to ensure that the
the building, plant and all for the building, plant and expectation of the
equipment. Cleaning all equipment. Cleaning cleaning
procedures shall as a procedures for processing procedures are
minimum include the: equipment, food contact more risk based
surfaces and environmental by identifying
responsibility for cleaning in high-care/ areas needing
cleaning
high-risk areas shall as a in-depth cleaning
item/area to be cleaned minimum include the: procedures.
frequency of cleaning
method of cleaning, responsibility for
including dismantling cleaning
equipment for cleaning item/area to be cleaned
purposes where frequency of cleaning
required method of cleaning,
cleaning chemicals and including dismantling
concentrations equipment for cleaning
cleaning materials to be purposes where
used required
cleaning records and cleaning chemicals and
responsibility for concentrations
verification. cleaning materials to be
used
The frequency and
methods of cleaning shall cleaning records and
responsibility for
be based on risk.
verification.
The procedures shall be
The frequency and
implemented to ensure
methods of cleaning shall
appropriate standards of
be based on risk.
cleaning are achieved.
The procedures shall be
implemented to ensure
appropriate standards of
cleaning are achieved.

ISSUE 6 ISSUE 7
4.11.2 Limits of acceptable and 4.11.3 (Now 4.11.3) As a minimum The clause has
unacceptable cleaning for food contact surfaces, been refocused
performance shall be processing equipment and on food contact
defined, based on the for environmental cleaning surfaces,
potential hazards (e.g. in high-care/high-risk processing
microbiological, allergen or areas, limits of acceptable equipment and
foreign body and unacceptable cleaning environmental
contamination). performance shall be cleaning in
Acceptable levels of defined. This shall be high-care/
cleaning may be defined by based on the potential high-risk areas.
visual appearance, ATP hazards (e.g.
It also specifically
bioluminescence microbiological, allergen,
expects
techniques (see Glossary), foreign-body
validation where
microbiological testing or contamination or product-
cleaning is part of
chemical testing as to-product contamination).
a prerequisite
appropriate. The cleaning Acceptable levels of
plan to mitigate a
and disinfection cleaning may be defined by
risk.
procedures and frequency visual appearance, ATP
shall be validated and bioluminescence Added point
records maintained. techniques (see glossary), about product-to-
microbiological testing or product
chemical testing as contamination;
appropriate. Where for example,
cleaning procedures are species to
part of a defined species in meat
prerequisite plan to control cutting plants.
the risk of a specific hazard New sub-clause
the cleaning and to ensure there is
disinfection procedures no risk of cleaning
and frequency shall be chemical residues
validated and records on food contact
maintained. This shall surfaces.
include the risk from
cleaning chemical residues
on food contact surfaces.
4.11.3 The resources for 4.11.4 (Now 4.11.4) The resources

undertaking cleaning shall for undertaking cleaning
be available. Where it is shall be available. Where it
necessary to dismantle is necessary to dismantle
equipment for cleaning equipment for cleaning
purposes or to enter large purposes or to enter large
equipment for cleaning, equipment for cleaning,
this shall be appropriately this shall be appropriately
scheduled and, where scheduled and, where
necessary, planned for necessary, planned for
non-production periods. non-production periods.
Cleaning staff shall be Cleaning staff shall be
adequately trained or adequately trained or
engineering support engineering support
provided where access provided where access
within equipment is within equipment is
required for cleaning. required for cleaning.

ISSUE 6 ISSUE 7
4.11.4 The cleanliness of 4.11.5 (Now 4.11.5) The
equipment shall be cleanliness of equipment
checked before equipment shall be checked before
is released back into full equipment is released back
production. The results of into production. The results
checks on cleaning, of checks on cleaning,
including visual, analytical including visual, analytical
and microbiological and microbiological
checks, shall be recorded checks, shall be recorded
and used to identify trends and used to identify trends
in cleaning performance in cleaning performance
and instigate and instigate
improvements where improvements where
required. required.
4.11.5 Cleaning equipment shall 4.11.6 (Now 4.11.6) Cleaning Need for visually
be: equipment shall be: distinctive
cleaning
fit for purpose hygienically designed equipment in
suitably identified for and fit for purpose
high-care and
intended use, e.g. suitably identified for high-risk areas to
colour coded or labelled intended use (e.g.
easily identify
cleaned and stored in a colour coded or
equipment which
hygienic manner to labelled)
should not be in
prevent contamination. cleaned and stored in a
the area.
hygienic manner to
Equipment used for
prevent contamination.
cleaning in high-care and
high-risk areas shall be Equipment used for
dedicated for use in that cleaning in high-care and
area. high-risk areas shall be
visually distinctive and
dedicated for use in that
area.
4.11.6 CLEANING IN PLACE (CIP) (NOW 4.11.7)

ISSUE 6 ISSUE 7
4.11.6.1 Cleaning-in-place (CIP) 4.11.7.1 (Now 4.11.7.1) Cleaning-in-
facilities, where used, shall place (CIP) facilities, where
be monitored and used, shall be monitored
maintained to ensure their and maintained to ensure
effective operation. their effective operation.

ISSUE 6 ISSUE 7
4.11.6.2 A schematic plan of the 4.11.7.2 (Now 4.11.7.2) A schematic Clarification that a
layout of the CIP system diagram of the layout of the diagram or mimic
shall be available. There CIP system including diagram is
shall be an inspection process piping circuits intended where
report or other verification shall be available. There the word plan was
that: shall be an inspection used in Issue 6.
report or other validation
systems are hygienically that:
Word change
designed with no dead from verification
areas, limited systems are hygienically to validation
interruptions to flow designed with no dead because the
streams and good areas, limited expectation is
system drain ability. interruptions to flow that the report
scavenge pumps are streams and good validates the
operated to ensure that system drain ability cleaning process
there is no build-up of scavenge/return pumps required.
cleaning fluids in the are operated to ensure
Change of
vessels. that there is no build-up
wording to
spray balls effectively of CIP solutions in the
incorporate proxy
clean vessels by vessels
switches/make
providing full surface spray balls and rotating
and break
coverage and are spray devices effectively
connections to
periodically inspected clean vessels by
prevent cross-
for blockages. Rotating providing full surface
contamination
spray devices should coverage and are
between cleaning
have a defined periodically inspected
solutions and
operational time. for blockages (Removal
product.
CIP equipment has of rotating spray devices
adequate separation should have a defined
from active product operational time)
lines, e.g. through the CIP equipment has
use of double seat adequate separation
valves, manually from active product lines
controlled links or (e.g. through the use of
blanks in pipework. double seat valves,
manually controlled
The system shall be
links, blanks in pipework
revalidated following
or make-or-break
alterations or additions to
connections with proxy
the CIP equipment. A log of
switches as interlocks)
changes to the CIP system
to prevent or safeguard
shall be maintained.
against cross-
contamination.
The system shall be
revalidated following
alterations or additions to
the CIP equipment. A log of
changes to the CIP system
shall be maintained.

ISSUE 6 ISSUE 7
4.11.6.3 The CIP equipment shall be 4.11.7.3 (Now 4.11.7.3) The CIP
operated to ensure effective equipment shall be
cleaning is carried out: operated to ensure effective
cleaning is carried out:
The process
parameters, time, The process parameters,
detergent time, detergent
concentrations, flow rate concentrations, flow rate
and temperatures shall and temperatures shall
be defined to ensure be defined to ensure
removal of the removal of the
appropriate target appropriate target hazard
hazard, e.g. soil, (e.g. soil, allergens,
allergens, vegetative vegetative
microorganisms, spores. microorganisms, spores).
This shall be validated This shall be validated
and records of the and records of the
validation maintained. validation maintained.
Detergent Detergent concentrations
concentrations shall be shall be checked
checked routinely. routinely.
Process verification CIP process verification
shall be undertaken by shall be undertaken by
analysis of rinse waters analysis of rinse waters
and/or first product and/or first product
through the line for the through the line for the
presence of cleaning presence of cleaning
fluids or by tests of ATP fluids or by tests of ATP
(bioluminescence (bioluminescence
techniques) allergens or techniques), allergens
micro-organisms as or micro-organisms as
appropriate. appropriate.
Detergent tanks shall be Detergent tanks shall be
kept stocked up and a kept stocked up and a
log maintained of when log maintained of when
these are filled and these are drained,
emptied. Recovered cleaned, filled and
pre-rinse solutions shall emptied. Recovered
be monitored for a post-rinse solutions shall
build-up of carry-over be monitored for a
from the detergent build-up of carry-over
tanks. from the detergent tanks.
Filters, where fitted, shall Filters, where fitted, shall
be cleaned and be cleaned and
inspected at a defined inspected at a defined
frequency. frequency.

4.12WASTE/WASTE DISPOSAL
ISSUE 6 ISSUE 7
Statement of intent Waste disposal shall be Statement of intent Waste disposal shall be
managed in accordance managed in accordance
with legal requirements with legal requirements
and to prevent and to prevent
accumulation, risk of accumulation, risk of
contamination and the contamination and the
attraction of pests. attraction of pests.
4.12.1 Where licensing is required 4.12.1 Where licensing is required Slight clarification
for the disposal of by law for the removal of of existing clause
categorised waste, it shall waste, it shall be removed wording.
be removed by licensed by licensed contractors
contractors and records of and records of removal
disposal shall be shall be maintained and
maintained and available available for audit.
for audit.
4.12.2 Food products intended to Moved to 4.13

be supplied for animal feed
shall be segregated from
waste and managed in
accordance with relevant
legislative requirements.
4.12.3 External waste collection 4.12.2 (Now 4.12.2) External

containers and rooms waste collection containers
housing waste facilities and rooms housing waste
shall be managed to facilities shall be managed
minimise risk. These shall to minimise risk. These
be: shall be:
clearly identified clearly identified

designed for ease of use designed for ease of use
and effective cleaning and effective cleaning
well-maintained to allow well maintained to allow
cleaning and, where cleaning and, where
required, disinfection required, disinfection
emptied at appropriate emptied at appropriate
frequencies frequencies
covered or doors kept covered or doors kept
closed as appropriate. closed as appropriate.
4.12.4 If unsafe products or 4.12.3 (Now 4.12.3) If unsafe

substandard trademarked products or substandard
materials are transferred to trademarked materials are
a third party for destruction transferred to a third party
or disposal, that third party for destruction or disposal,
shall be a specialist in that third party shall be a
secure product or waste specialist in secure product
disposal and shall provide or waste disposal and shall
records which includes the provide records which
quantity of waste collected include the quantity of
for destruction or disposal. waste collected for
destruction or disposal.

4.13MANAGEMENT OF SURPLUS FOOD AND PRODUCTS FOR ANIMAL FEED
(NEW)
ISSUE 6 ISSUE 7
Statement of intent Effective processes shall New clauses
be in place to ensure the added to reflect
safety and legality of the increased
by-products of the primary donation of
processing activity of the surplus foods to
site. charities. The
intent is to ensure
that the food is
safe and carried
out in accordance
with the brand
owners
requirements.
4.13.1 (NEW) Surplus customer-branded New clauses.

products shall be disposed
of in accordance with
customer-specific
requirements. Customer
brand names shall be
removed from packed
surplus products under the
control of the factory before
the product enters the
supply chain unless
authorised otherwise by
the customer.
4.13.2 (NEW) Where customer-branded

products which do not
meet specification are sold
to staff or passed on to
charities or other
organisations this shall be
with the prior consent of
the brand owner.
Processes shall be in place
to ensure that all products
are fit for consumption and
meet legal requirements.
4.13.3 (NEW) (Partially 4.12.2 and NEW) Existing clause

By-products and relocated from
downgraded/surplus waste section
products intended for because products
animal feed shall be for animal feed
segregated from waste and need to be
protected from considered as a
contamination during food product for
storage. Products for animals.
animal feed shall be Terminology used
managed in accordance to reflect this.
with relevant legislative
requirements.

4.13PEST CONTROL (NOW 4.14)
ISSUE 6 ISSUE 7
Statement of intent The whole site shall have Statement of intent The whole site shall have
an effective preventive pest an effective preventive pest
control programme in control programme in
place to minimise the risk of place to minimise the risk of
infestation and there shall infestation and there shall
be the resources available be the resources available
to rapidly respond to any to rapidly respond to any
issues which occur to issues which occur to
prevent risk to products. prevent risk to products.
4.14.1 (NEW) If pest activity is identified it New clause added

shall not present a risk of to recognise that
contamination to products, where an
raw materials or packaging. infestation has
been identified in
The presence of any
pest control
infestation on site shall be
records, is being
identified in pest control
effectively
records and be part of an
controlled and
effective pest management
does not present
programme to eliminate or
a risk to product
manage the infestation
then this is not a
such that it does not
non-conformity.
present a risk to products,
raw materials or packaging.
4.13.1 The company shall either 4.14.2 (Now 4.14.2) The site shall
contract the services of a either contract the services
competent pest control of a competent pest control
organisation, or shall have organisation, or shall have
appropriately trained staff, appropriately trained staff,
for the regular inspection for the regular inspection
and treatment of the site to and treatment of the site to
deter and eradicate deter and eradicate
infestation. The frequency infestation. The frequency
of inspections shall be of inspections shall be
determined by risk determined by risk
assessment and shall be assessment and shall be
documented. Where the documented. Where the
services of a pest control services of a pest control
contractor are employed, contractor are employed,
the service contract shall the service scope shall be
be clearly defined and clearly defined and reflect
reflect the activities of the the activities of the site.
site.

ISSUE 6 ISSUE 7
4.13.2 Where a company 4.14.3 (Now 4.14.3) Where a site New bullet
undertakes its own pest undertakes its own pest highlighting that
control, it shall be able to control, it shall be able to where there
effectively demonstrate effectively demonstrate arelegal
that: that: requirements in a
country to be a
pest control operations pest control operations pest control
are undertaken by are undertaken by
operative these
trained and competent trained and competent
are satisfied.
staff with sufficient staff with sufficient
knowledge to select knowledge to select
appropriate pest control appropriate pest control
chemicals and proofing chemicals and proofing
methods and methods and
understand the understand the
limitations of use, limitations of use,
relevant to the biology of relevant to the biology of
the pests associated the pests associated
with the site with the site
sufficient resources are staff undertaking pest
available to respond to control activities meet
any infestation issues any legal requirements
there is ready access to for training or
specialist technical registration
knowledge when sufficient resources are
required available to respond to
legislation governing any infestation issues
the use of pest control there is ready access to
products is understood specialist technical
dedicated locked knowledge when
facilities are used for the required
storage of pesticides. legislation governing
the use of pest control
products is understood
dedicated locked
facilities are used for the
storage of pesticides.
4.13.3 Pest control 4.14.4 (Now 4.14.4) Pest control

documentation and documentation and
records shall be records shall be
maintained. This shall maintained. This shall
include as a minimum: include as a minimum:
an up-to-date plan of an up-to-date plan of

the full site identifying the full site, identifying
numbered pest control numbered pest control
device locations device locations
identification of the baits identification of the baits
and/or monitoring and/or monitoring
devices on site devices on site
clearly defined clearly defined
responsibilities for site responsibilities for site
management and for the management and for the
contractor contractor

ISSUE 6 ISSUE 7
details of pest control details of pest control

products used, products used,
including instructions including instructions
for their effective use for their effective use
and action to be taken in and action to be taken in
case of emergencies case of emergencies
any observed pest any observed pest
activity activity
details of pest control details of pest control
treatments undertaken. treatments undertaken.
4.13.4 Bait stations shall be 4.14.5 (Now 4.14.5) Bait stations Further
robust, of tamper resistant or other rodent control clarification of the
construction, secured in devices (removal of tamper clause from Issue
place and appropriately resistant construction and 6 to make this
located to prevent secured in place) shall be more applicable
contamination risk to appropriately located and to practices
product. Missing bait maintained to prevent worldwide.
boxes shall be recorded, contamination risk to
reviewed and investigated. product. Toxic rodent baits
Toxic rodent baits shall not shall not be used within
be used within production production or storage
areas or storage areas areas where open product
where open product is is present except when
present except when treating an active
treating an active infestation. Where toxic
infestation. baits are used these shall
be secured.
Any missing bait stations
shall be recorded, reviewed
and investigated.
4.13.5 Fly-killing devices and/or 4.14.6 (Now 4.14.6) Fly-killing

pheromone traps shall be devices and/or pheromone
correctly sited and traps shall be correctly
operational. If there is a sited and operational. If
danger of insects being there is a danger of insects
expelled from a fly-killing being expelled from a
extermination device and fly-killing extermination
contaminating the product, device and contaminating
alternative systems and the product, alternative
equipment shall be used. systems and equipment
shall be used.
4.13.6 In the event of infestation, 4.14.7 (Now 4.14.7) In the event of Clause expanded
or evidence of pest activity, infestation, or evidence of to ensure that risk
immediate action shall be pest activity, immediate of product
taken to eliminate the action shall be taken to contamination in
hazard. Any potentially identify at-risk product and the event of
affected products should to minimise the risk of discovery of
be subject to the non- product contamination. infestation is
conforming product Any potentially affected addressed.
procedure. products should be subject
to the non-conforming
product procedure.

ISSUE 6 ISSUE 7
4.13.7 Records of pest control 4.14.8 (Now 4.14.8) Records of
inspections, pest proofing pest control inspections,
and hygiene pest proofing and hygiene
recommendations and recommendations and
actions taken shall be actions taken shall be
maintained. It shall be the maintained. It shall be the
responsibility of the responsibility of the site to
company to ensure all of ensure that all of the
the relevant relevant recommendations
recommendations made made by its contractor or
by their contractor or in-house expert are carried
in-house expert are carried out in a timely manner.
out in a timely manner.
4.13.8 An in-depth, documented 4.14.9 (Now 4.14.9) An in-depth, Expanded the

pest control survey shall be documented pest control wording to make
undertaken at a frequency survey shall be undertaken it clearer what the
based on risk, but typically at a frequency based on objectives are for
quarterly, by a pest control risk, but as a minimum the site survey.
expert to review the pest annually, by a pest control
More flexibility
control measures in place. expert to review the pest
has been allowed
The timing of the survey control measures in place.
on the frequency
shall be such as to allow The survey shall:
of the survey
access to equipment for
inspection where a risk of provide an in-depth which must now
inspection of the facility be as a minimum
stored product insect
for pest activity annually.
infestation exists.
review the existing pest
control measures in
place and make any
recommendations for
change.
The timing of the survey
shall be such as to allow
access to equipment for
inspection where a risk of
stored product insect
infestation exists.
4.13.9 Results of pest control 4.14.10 (Now 4.14.10) Results of

inspections shall be pest control inspections
assessed and analysed for shall be assessed and
trends on a regular basis, analysed for trends on a
but as a minimum: regular basis, but, as a
minimum:
in the event of an
infestation in the event of an
annually. infestation
This shall include a catch annually.
analysis from trapping This shall include a catch
devices to identify problem analysis from trapping
areas. The analysis shall be devices to identify problem
used as a basis for areas. The analysis shall be
improving the pest control used as a basis for
procedures. improving the pest control
procedures.

ISSUE 6 ISSUE 7
4.14.11 Employees shall New clause added
(NEW) understand the signs of to ensure staff
pest activity and be aware who may come
of the need to report any across pests e.g.
evidence of pest activity to cleaners,
a designated manager. engineers have
received some
training to ensure
that the
infestation is
identified and
reported.
4.14STORAGE FACILITIES (NOW 4.15)

ISSUE 6 ISSUE 7
Statement of intent All facilities used for the Statement of intent All facilities used for the
storage of ingredients, storage of raw materials,
in-process product and packaging, in-process
finished products shall be products and finished
suitable for its purpose. products shall be suitable
for its purpose.
4.14.1 Documented procedures 4.15.1 (Now 4.15.1) Documented

to maintain product safety procedures to maintain
and quality during storage product safety and quality
shall be developed on the during storage shall be
basis of risk assessment, developed on the basis of
understood by relevant risk assessment,
staff and implemented understood by relevant
accordingly. These may staff and implemented
include as appropriate: accordingly. These may
include, as appropriate:
managing chilled and
frozen product transfer managing chilled and
between temperature frozen product transfer
controlled areas between temperature-
segregation of products controlled areas
where necessary to segregation of products
avoid cross- where necessary to
contamination (physical, avoid cross-
microbiological or contamination (physical,
allergens) or taint uptake microbiological or
storing materials off the allergens) or taint uptake
floor and away from storing materials off the
walls floor and away from
specific handling or walls
stacking requirements specific handling or
to prevent product stacking requirements
damage. to prevent product
damage.

ISSUE 6 ISSUE 7
4.15.2 (Now 4.15.2) (Formerly
5.4.2) Where appropriate,
packaging shall be stored
away from other raw
materials and finished
product. Any part-used
packaging materials
suitable for use shall be
effectively protected from
contamination and clearly
identified to maintain
traceability before being
returned to an appropriate
storage area.
Obsolete packaging shall
be stored in a separate area
and systems shall be in
place to prevent accidental
use.
4.14.2 Where temperature control 4.15.3 (Now 4.15.3) Where

is required, the storage temperature control is
area shall be capable of required, the storage area
maintaining product shall be capable of
temperature within maintaining product
specification and operated temperature within
to ensure specified specification and operated
temperatures are to ensure specified
maintained. Temperature temperatures are
recording equipment with maintained. Temperature
suitable temperature recording equipment with
alarms shall be fitted to all suitable temperature
storage facilities or there alarms shall be fitted to all
shall be a system of storage facilities or there
recorded manual shall be a system of
temperature checks, recorded manual
typically on at least a temperature checks,
four-hourly basis or at a typically on at least a
frequency which allows for 4-hourly basis or at a
intervention before product frequency which allows for
temperatures exceed intervention before product
defined limits for the safety, temperatures exceed
legality or quality of defined limits for the safety,
products. legality or quality of
products.
4.14.3 Where controlled 4.15.4 (Now 4.15.4) Where

atmosphere storage is controlled atmosphere
required, the storage storage is required, the
conditions shall be storage conditions shall be
specified and effectively specified and effectively
controlled. Records shall controlled. Records shall
be maintained of the be maintained of the
storage conditions. storage conditions.

ISSUE 6 ISSUE 7
4.14.4 Where storage outside is 4.15.5 (Now 4.15.5) Where Added
necessary, items shall be storage outside is requirement to
protected from necessary, items shall be ensure where
contamination and protected from products are
deterioration. contamination and stored outside
deterioration. these do not
represent a
Items shall be checked for
contamination
suitability before being
risk when brought
brought into the factory.
into the factory.
4.14.5 Receipt documents and/or 4.15.6 (Now 4.15.6) The site shall
product identification shall facilitate correct stock
facilitate correct stock rotation of raw materials,
rotation of raw materials, intermediate products and
intermediate products and finished products in
finished products in storage and ensure
storage and ensure materials are used in the
materials are used in the correct order in relation to
correct order in relation to their manufacturing date
their manufacturing date and within the prescribed
and within the prescribed shelf life.
shelf life.
(Removal of receipt
documents and/or product
identification)
4.15DISPATCH AND TRANSPORT (NOW 4.16)

ISSUE 6 ISSUE 7
Statement of intent Procedures shall be in Statement of intent Procedures shall be in Addition of
place to ensure that the place to ensure that the security to
management of dispatch management of dispatch statement of
and of the vehicles and and of the vehicles and intent reflecting
containers used for containers used for concerns about
transporting products from transporting products from substitution in
the site do not present a the site do not present a transit.
risk to the safety or quality risk to the safety, security or
of the products. quality of the products.

to maintain product safety procedures to maintain
and quality during loading product safety and quality
and transportation shall be during loading and
developed and transportation shall be
implemented. These may developed and
include as appropriate: implemented. These may
include, as appropriate:

ISSUE 6 ISSUE 7
4.15.1 cont. controlling temperature 4.16.1 cont. controlling temperature

of loading dock areas of loading dock areas
the use of covered bays the use of covered bays
for vehicle loading or for vehicle loading or
unloading unloading
securing loads on securing loads on
pallets to prevent pallets to prevent
movement during transit movement during transit
inspection of loads prior inspection of loads prior
to dispatch. to dispatch.
4.15.2 Traceability shall be Removed Traceability is

ensured during already covered
transportation. There shall in section 3.9 and
be a clear record of this was
dispatch and receipt of considered to be
goods and materials duplication.
demonstrating that
sufficient checks have
been completed during the
transfer of goods.
4.15.3 All vehicles or containers 4.16.2 (Now 4.16.2) All vehicles or

used for the dispatch of containers used for the
products shall be dispatch of products shall
inspected prior to loading be inspected prior to
to ensure that they are fit for loading to ensure that they
purpose. This shall ensure are fit for purpose. This
that they are: shall ensure that they are:
in a suitably clean in a (removal of suitably)

condition clean condition
free from strong odours free from strong odours
which may cause taint to which may cause taint to
products products
suitably maintained to in a suitable condition to
prevent damage to prevent damage to
products during transit products during transit
equipped to ensure any equipped to ensure any
temperature temperature
requirements can be requirements can be
Records of inspections Records of inspections
shall be maintained. shall be maintained.

ISSUE 6 ISSUE 7
4.15.4 Where temperature control 4.16.3 (Now 4.16.3) Where
is required, the transport temperature control is
shall be capable of required, the transport shall
maintaining product be capable of maintaining
temperature within product temperature within
specification, under specification, under
minimum and maximum minimum and maximum
load. Temperature load. Temperature
data-logging devices data-logging devices
which can be interrogated which can be interrogated
to confirm time/ to confirm time/
temperature conditions or temperature conditions or
a system to verify and a system to monitor and
record at predetermined record at predetermined
frequencies the correct frequencies the correct
operation of refrigeration operation of refrigeration
equipment shall be used equipment shall be used
and records maintained. and records maintained.
4.15.5 Maintenance systems and 4.16.4 (Now 4.16.4) Maintenance Subtle word
documented cleaning systems and documented change to identify
procedures shall be cleaning procedures shall that these will be
maintained for all vehicles be available for all vehicles available to be
and equipment used for and equipment used for audited.
loading/unloading (e.g. loading/unloading
hoses connecting to silo (removal of examples).
installations). There shall be There shall be records of
records of the measures the measures taken.
taken.
4.15.6 The company shall have 4.16.5 (Now 4.16.5) The company
documented procedures shall have documented
for the transport of procedures for the
products, which shall transport of products,
include: which shall include:
any restrictions on the any restrictions on the

use of mixed loads use of mixed loads
requirements for the requirements for the
security of products security of products
during transit, during transit,
particularly when particularly when
vehicles are parked and vehicles are parked and
unattended unattended
clear instructions in the clear instructions in the
case of vehicle case of vehicle
breakdown, accident or breakdown, accident or
failure of refrigeration failure of refrigeration
systems which ensure systems, which ensure
the safety of the the safety of the
products is assessed products is assessed
and records maintained. and records maintained.

ISSUE 6 ISSUE 7
4.15.7 Where the company 4.16.6 (Now 4.16.6) Where the
employs third-party company employs
contractors, all the third-party contractors, all
requirements specified in the requirements specified
this section shall be clearly in this section shall be
defined in the contract and clearly defined in the
verified or the contracted contract and verified or the
company shall be contracted company shall
certificated to the Global be certificated to the
Standard for Storage and Global Standard for
Distribution or similar Storage and Distribution or
internationally recognised similar GFSI-recognised
Standard. scheme.

5PRODUCT CONTROL
5.1PRODUCT DESIGN/DEVELOPMENT
ISSUE 6 ISSUE 7
Statement of intent Product design and Statement of intent Product design and
development procedures development procedures
shall be in place for new shall be in place for new
products or processes and products or processes and
any changes to product, any changes to product,
packaging or packaging or
manufacturing processes manufacturing processes
to ensure that safe and to ensure that safe and
legal products are legal products are
produced. produced.
5.1.1 The company shall provide 5.1.1 The company shall provide
clear guidelines on any clear guidelines on any
restrictions to the scope of restrictions to the scope of
new product new product
developments to control developments to control
the introduction of hazards the introduction of hazards
which would be which would be
unacceptable to the unacceptable to the site or
company or customers customers (e.g. the
(e.g. the introduction of introduction of allergens,
allergens, glass packaging glass packaging or
or microbiological risks). microbiological risks).
5.1.2 All new products and 5.1.2 All new products and
changes to product changes to product
formulation, packaging or formulation, packaging or
methods of processing methods of processing
shall be formally approved shall be formally approved
by the HACCP team leader by the HACCP team leader
or authorised HACCP or authorised HACCP
committee member. This committee member. This
shall ensure that hazards shall ensure that hazards
have been assessed and have been assessed and
suitable controls, identified suitable controls, identified
through the HACCP through the HACCP
system, are implemented. system, are implemented.
This approval shall be This approval shall be
granted before products granted before products
are introduced into the are introduced into the
factory environment. factory environment.
5.1.3 Trials using production 5.1.3 Trials using production

equipment shall be carried equipment shall be carried
out where it is necessary to out where it is necessary to
validate that product validate that product
formulation and formulation and
manufacturing processes manufacturing processes
are capable of producing a are capable of producing a
safe product of the required safe product of the required
quality. quality.

ISSUE 6 ISSUE 7
5.1.4 Shelf-life trials shall be 5.1.4 Shelf-life trials shall be Transport added
undertaken using undertaken using because in some
documented protocols documented protocols instances
reflecting conditions reflecting conditions vibration, periods
experienced during experienced during of transfer, and
storage and handling. storage, transport and weaker
Results shall be recorded handling. Results shall be temperature
and retained and shall recorded and retained and controls in
confirm compliance with shall confirm compliance transport may
relevant microbiological, with relevant need to be
chemical and organoleptic microbiological, chemical considered in
criteria. Where shelf-life and organoleptic criteria. establishing shelf
trials prior to production are Where shelf-life trials prior life.
impractical, for instance for to production are
some long-life products, a impractical, for instance for
documented science- some long-life products, a
based justification for the documented science-
assigned shelf life shall be based justification for the
produced. assigned shelf life shall be
produced.
5.1.5 All products shall be Moved to section 5.2

labelled to meet legal Product labelling (clause
requirements for the 5.2.1)
designated country of use
and shall include
information to allow the
safe handling, display,
storage, preparation and
use of the product within
the food supply chain or by
the customer. There shall
be a process to verify that
ingredient and allergen
labelling is correct based
on the product recipe.
5.1.6 Where a product is Moved to section 5.2

designed to enable a claim Product labelling (clause
to be made to satisfy a 5.2.3)
consumer group (e.g. a
nutritional claim, reduced
sugar), the company shall
ensure that the product
formulation and production
process is fully validated to
meet the stated claim.

5.2PRODUCT LABELLING (NEW)
ISSUE 6 ISSUE 7
Statement of intent Product labelling shall New section to
comply with the add emphasis to
appropriate legal the importance of
requirements and contain the accuracy of
information to enable the label information
safe handling, display, in reducing
storage and preparation of incidents of
the product within the food withdrawal or
supply chain or by the recall.
customer.
5.2.1 (Now 5.2.1) (Formerly 5.1.5)

All products shall be
labelled to meet legal
requirements for the
designated country of use
and shall include
information to allow the
safe handling, display,
storage, preparation and
use of the product within
the food supply chain or by
the customer. There shall
be a process to verify that
ingredient and allergen
labelling is correct based
on the product recipe and
ingredient specifications.
5.2.2 (NEW) There shall be effective Checklist added

processes in place to of changes that
ensure that labelling should trigger the
information is reviewed review of the label
whenever changes occur information. The
to: effective process
is likely to require
the product recipe a defined
raw materials procedure and
the supplier of raw person to
materials
authorise the
the country of origin of changes.
raw materials
legislation.
5.2.3 (Now 5.2.3) (Formerly
5.1.6) Where a product is
designed to enable a claim
to be made to satisfy a
consumer group (e.g. a
nutritional claim, reduced
sugar), the company shall
ensure that the product
formulation and production
process is fully validated to
meet the stated claim.

ISSUE 6 ISSUE 7
5.2.4 (NEW) Where the label information New clause to
is the responsibility of a ensure that where
customer or a nominated changes which
third party the company may affect labels
shall provide: occur, the
customer is
information to enable informed to
the label to be
enable a decision
accurately created
to be made on any
information whenever a
label change.
change occurs which
may affect the label
information.
5.2MANAGEMENT OF ALLERGENS (NOW 5.3)

ISSUE 6 ISSUE 7
FUNDAMENTAL The company shall have a FUNDAMENTAL The site shall have a Addition of
Statement of intent developed system for the Statement of intent (removal of developed) country of sale to
management of allergenic system for the reflect that
materials which minimises management of allergenic legislative
the risk of allergen materials which minimises requirements on
contamination of products the risk of allergen allergens which
and meets legal contamination of products need to be
requirements for labelling. and meets legal labelled varies
requirements for labelling internationally
in the country of sale.
5.2.1 The company shall carry 5.3.1 (Now 5.3.1) The site shall
out an assessment of raw carry out an assessment of
materials to establish the raw materials to establish
presence and likelihood of the presence and
contamination by allergens likelihood of contamination
(refer to glossary). This shall by allergens (refer to
include review of raw glossary). This shall include
material specifications and, review of raw material
where required, obtain specifications and, where
additional information from required, obtain additional
suppliers, for example information from suppliers,
through questionnaires to for example through
understand the allergen questionnaires to
status of the raw material, understand the allergen
its ingredients and the status of the raw material,
factory in which it is its ingredients and the
produced. factory in which it is
produced.

ISSUE 6 ISSUE 7
5.2.2 The company shall identify 5.3.2 (Now 5.3.2) The company
and list allergen-containing shall identify and list
materials handled on site. allergen-containing
This shall include raw materials handled on site.
materials, processing aids, This shall include raw
intermediate and finished materials, processing aids,
products and any new intermediate and finished
product development products, and any new
ingredients or products. product development
ingredients or products.
5.2.3 A documented risk 5.3.3 (Now 5.3.3) A documented

assessment shall be risk assessment shall be
carried out to identify carried out to identify
routes of contamination routes of contamination
and establish documented and establish documented
policies and procedures for policies and procedures for
handling raw materials, handling raw materials,
intermediate and finished intermediate and finished
products to ensure products to ensure
cross-contamination is cross-contamination is
avoided. This shall include: avoided. This shall include:
consideration of the consideration of the

physical state of the physical state of the
allergenic material, i.e. allergenic material (i.e.
powder, liquid, powder, liquid,
particulate particulate)
identification of potential identification of potential
points of cross- points of cross-
contamination through contamination through
the process flow the process flow
assessment of the risk of assessment of the risk of
allergen cross- allergen cross-
contamination at each contamination at each
process step process step
identification of suitable identification of suitable
controls to reduce or controls to reduce or
eliminate the risk of eliminate the risk of
cross-contamination. cross-contamination.

ISSUE 6 ISSUE 7
shall be established to procedures shall be
ensure the effective established to ensure the
management of allergenic effective management of
materials to prevent allergenic materials to
cross-contamination into prevent cross-
products not containing contamination into
the allergen. This shall products not containing
include as appropriate: the allergen. This shall
include as appropriate:
physical or time
segregation whilst physical or time
allergen-containing segregation while
materials are being allergen-containing
stored, processed or materials are being
packed stored, processed or
the use of separate or packed
additional protective the use of separate or
over clothing when additional protective
handling allergenic overclothing when
materials handling allergenic
use of identified, materials
dedicated equipment use of identified,
and utensils for dedicated equipment
processing and utensils for
scheduling of processing
production to reduce scheduling of
changes between production to reduce
products containing an changes between
allergen and products products containing an
not containing the allergen and products
allergen not containing the
systems to restrict the allergen
movement of airborne systems to restrict the
dust containing movement of airborne
allergenic material dust containing
waste handling and allergenic material
spillage controls waste handling and
restrictions on food spillage controls
brought onto site by restrictions on food
staff, visitors, brought onto site by
contractors and for staff, visitors,
catering purposes. contractors and for
catering purposes.
5.2.5 Where rework is used, or 5.3.5 (Now 5.3.5) Where rework

reworking operations is used, or reworking
carried out, procedures operations carried out,
shall be implemented to procedures shall be
ensure rework containing implemented to ensure
allergens is not used in rework containing
products that do not allergens is not used in
already contain the products that do not
allergen. already contain the
allergen.

ISSUE 6 ISSUE 7
5.2.6 Where the nature of the 5.3.6 (Now 5.3.6) Where the
production process is such nature of the production
that cross-contamination process is such that
from an allergen cannot be cross-contamination from
prevented, a warning shall an allergen cannot be
be included on the label. prevented, a warning
National guidelines or should be included on the
codes of practice shall be label. National guidelines
used when making such a or codes of practice shall
warning statement. be used when making such
a warning statement.
5.2.7 Where a claim is made 5.3.7 (Now 5.3.7) Where a claim Addition of
regarding the suitability of a is made regarding the verification of the
food for allergy or food suitability of a food for effectiveness of
sensitivity sufferers, the allergy or food sensitivity the process.
company shall ensure that sufferers, the site shall
the production process is ensure that the production
fully validated to meet the process is fully validated to
stated claim. This shall be meet the stated claim and
documented. the effectiveness of the
process is routinely
verified. This shall be
documented.
5.2.8 Equipment or area cleaning 5.3.8 (Now 5.3.8) Equipment or

procedures shall be area cleaning procedures
designed to remove or shall be designed to
reduce to acceptable levels remove or reduce to
any potential cross- acceptable levels any
contamination by allergens. potential cross-
The cleaning methods shall contamination by allergens.
be validated to ensure they The cleaning methods shall
are effective and the be validated to ensure they
effectiveness of the are effective and the
procedure routinely effectiveness of the
verified. Cleaning procedure routinely
equipment used to clean verified. Cleaning
allergenic materials shall equipment used to clean
either be identifiable and allergenic materials shall
specific for allergen use, either be identifiable and
single use, or effectively specific for allergen use,
cleaned after use. single use, or effectively
cleaned after use.
5.2.9 All relevant personnel, Moved to Personnel

including engineers, training 7.1.4
temporary staff and
contractors, shall have
received general allergen
awareness training and be
trained in the companys
allergen-handling
procedures.

ISSUE 6 ISSUE 7
5.2.10 An effective system of Moved to 6.2 Labelling and
documented checks shall pack control
be in place at line start-up,
following product
changeover and changes
in batches of packaging to
ensure that the labels
applied are correct for the
products packed.
5.3PROVENANCE, ASSURED STATUS AND CLAIMS OF IDENTITY PRESERVED

MATERIALS (NOW 5.4 PRODUCT AUTHENTICITY, CLAIMS AND CHAIN OF
CUSTODY)
ISSUE 6 ISSUE 7
Statement of intent Systems of traceability, Statement of intent Systems shall be in place to New clauses
identification and minimise the risk of added to allow
segregation of raw purchasing fraudulent or sites to develop
materials, intermediate and adulterated food raw an effective
finished products shall be materials and to ensure that approach to
in place to ensure that all all product descriptions reduce their
claims relating to and claims are legal, exposure to
provenance or assured accurate and verified. purchasing
status can be fraudulent
substantiated. materials.
5.4.1 (NEW) The company shall have

processes in place to
access information on
historical and developing
threats to the supply chain
which may present a risk of
adulteration or substitution
of raw materials. Such
information may come
from:
trade associations
government sources
private resource
centres.

ISSUE 6 ISSUE 7
5.4.2 (NEW) A documented vulnerability
assessment shall be
carried out on all food raw
materials or groups of raw
materials to assess the
potential risk of adulteration
or substitution. This shall
take into account:
historical evidence of
substitution or
adulteration
economic factors which
may make adulteration
or substitution more
attractive
ease of access to raw
materials through the
supply chain
sophistication of routine
testing to identify
adulterants
nature of the raw
material.
The vulnerability
assessment shall be kept
under review to reflect
changing economic
circumstances and market
intelligence which may alter
the potential risk. It shall be
formally reviewed annually.
5.4.3 (NEW) Where raw materials are

identified as being at
particular risk of
adulteration or substitution
appropriate assurance
and/or testing processes
shall be in place to reduce
the risk.

ISSUE 6 ISSUE 7
5.3.1 Where claims are to be 5.4.4 (Now 5.4.4) Where Examples added
made on finished packs products are labelled or to clarify the
about the provenance, claims are made on existing Issue 6
assured or identity finished packs which are clause.
preserved status (see dependent on a status of a
Glossary) of raw materials raw material including:
used, the status of each
batch of the raw material specific provenance or
origin
shall be verified and
records maintained. breed/varietal claims
assured status (e.g.
GlobalGAP)
genetically modified
organism (GMO) status
identity preserved
named specific
trademarked
ingredients
the status of each batch of
the raw material shall be
verified (removal of records
maintained).
(Taken from 5.3.2 Issue 6)
The facility shall maintain
purchasing records,
traceability of raw material
usage and final product
packing records to
substantiate claims. The
site shall undertake
documented mass balance
tests at a frequency to meet
the particular scheme
requirements or at least
every 6 months in the
absence of a scheme-
specific requirement.
5.3.2 Where a claim is made Now a part of 5.4.4

relating to the provenance,
assured or identity
preserved status of a
product or ingredient, the
facility shall maintain
purchasing records,
traceability of raw material
usage and final product
packing records to
substantiate claims. The
company shall undertake
documented mass balance
tests at least every six
months and at a frequency
to meet the particular
scheme requirements.

ISSUE 6 ISSUE 7
5.4.5 (NEW) Where claims are made New clause to
about the methods of allow verification
production (e.g. organic, of claims
Halal, Kosher) the site shall supported by
maintain the necessary certification.
certification status in order
to make such a claim.
5.3.3 The process flow for the 5.4.6 (Now 5.4.6) The process
production of products flow for the production of
where claims are made products where claims are
shall be documented and made shall be documented
potential areas for and potential areas for
contamination or loss of contamination or loss of
identity identified. identity identified.
Appropriate controls shall Appropriate controls shall
be established to ensure be established to ensure
the integrity of the product the integrity of the product
claims. claims.
5.4PRODUCT PACKAGING (NOW 5.5)

ISSUE 6 ISSUE 7
Statement of intent Product packaging shall be Statement of intent Product packaging shall be
appropriate for the appropriate for the
intended use and shall be intended use and shall be
stored under conditions to stored under conditions to
minimise contamination prevent contamination and
and deterioration. minimise deterioration.
5.4.1 When purchasing or 5.5.1 (Now 5.5.1) When

specifying food contact purchasing or specifying
packaging the supplier of food contact packaging
packaging materials shall the supplier of packaging
be made aware of any materials shall be made
particular characteristics of aware of any particular
the food (e.g. high fat characteristics of the food
content, pH or usage (e.g. high fat content, pH or
conditions such as usage conditions such as
microwaving) which may microwaving) which may
affect packaging suitability. affect packaging suitability.
Certificates of conformity Certificates of conformity
or other evidence shall be or other evidence shall be
available for product available for product
packaging to confirm it packaging to confirm it
conforms to relevant food complies with relevant food
safety legislation and is safety legislation and is
suitable for its intended suitable for its intended
use. use.

ISSUE 6 ISSUE 7
5.4.2 Where appropriate, Now 4.15.2
away from raw materials
and finished product. Any
part-used packaging
materials suitable for use
shall be effectively
protected from
contamination and clearly
identified before being
returned to an appropriate
storage area. Obsolete
in a separate area and
systems shall be in place to
prevent accidental use.
5.4.3 Product contact liners (or 5.5.2 (Now 5.5.2) Product Clause clarified to
raw material/work-in- (removal of contact) liners define that this
progress contact liners) and bags purchased by the applies to direct
purchased by the company company for use in direct product contact.
shall be appropriately contact with ingredients, or
coloured and resistant to work in process, shall be
tearing to prevent appropriately coloured and
accidental contamination. resistant to tearing to
prevent accidental
contamination.

5.5PRODUCT INSPECTION AND LABORATORY TESTING (NOW 5.6)
5.5.1 PRODUCT INSPECTION AND TESTING (NOW 5.6.1)

ISSUE 6 ISSUE 7
Statement of intent The company shall Statement of intent The company shall
undertake or subcontract undertake or subcontract
inspection and analyses inspection and analyses
which are critical to confirm which are critical to confirm
product safety, legality and product safety, legality and
quality, using appropriate quality, using appropriate
procedures, facilities and procedures, facilities and
standards. standards.
5.5.1.1 There shall be a scheduled 5.6.1.1 (Now 5.6.1.1) There shall be

programme of testing a scheduled programme of
covering products and the testing covering products
processing environment and the processing
which may include environment, which may
microbiological, chemical, include microbiological,
physical and organoleptic chemical, physical and
testing according to risk. organoleptic testing
The methods, frequency according to risk. The
and specified limits shall be methods, frequency and
documented. specified limits shall be
documented.
5.5.1.2 Test and inspection results 5.6.1.2 (Now 5.6.1.2) Test and Added sentence
shall be recorded and inspection results shall be to ensure that
reviewed regularly to recorded and reviewed there is an
identify trends. Appropriate regularly to identify trends. understanding of
actions shall be The significance of external the significance
implemented promptly to laboratory results shall be of the results of
address any unsatisfactory understood and acted analysis
results or trends. upon accordingly. undertaken.
Appropriate actions shall
be implemented promptly
to address any
unsatisfactory results or
trends.
5.5.1.3 The company shall ensure 5.6.1.3 (Now 5.6.1.3) The site shall Wording changed
that a system of on-going ensure that a system of to recognise that
shelf-life assessment is in ongoing shelf-life microbiological
place. This shall be based assessment is in place. and chemical
on risk and shall include This shall be based on risk testing will not
microbiological and and shall include sensory always be
sensory analysis as well as analysis and as applicable required to
relevant chemical factors microbiological testing and determine shelf
such as pH and aw. relevant chemical factors life.
Records and results from such as pH and aw.
shelf life tests shall validate Records and results from
the shelf life period shelf-life tests shall verify
indicated on the product. the shelf-life period
indicated on the product.

5.5.2 LABORATORY TESTING (NOW 5.6.2)
ISSUE 6 ISSUE 7
5.5.2.1 Pathogen testing shall be 5.6.2.1 (Now 5.6.2.1) Pathogen Reworded to
subcontracted to an testing shall be more precisely
external laboratory or, subcontracted to an define the
where conducted external laboratory or, restrictions on
internally, the laboratory where conducted location of
facility shall be fully internally, the laboratory pathogen testing
segregated from the facility shall be fully facilities.
manufacturing site and segregated from the
have operating procedures production and storage
to prevent any risk of areas and have operating
product contamination. procedures to prevent any
risk of product
contamination.
5.5.2.2 Where routine testing 5.6.2.2 (Now 5.6.2.2) Where

laboratories are present on routine testing laboratories
a manufacturing site, they are present on a
shall be located, designed manufacturing site, they
and operated to eliminate shall be located, designed
potential risks to product and operated to eliminate
safety. Controls shall be potential risks to product
documented, implemented safety. Controls shall be
and shall include documented, implemented
consideration of the and shall include
following: consideration of (removal
of the following):
design and operation of
drainage and ventilation design and operation of
systems drainage and ventilation
access and security of systems
the facility access and security of
movement of laboratory the facility
personnel movement of laboratory
protective clothing personnel
arrangements protective clothing
processes for obtaining arrangements
product samples processes for obtaining
disposal of laboratory product samples
waste. disposal of laboratory
waste.

ISSUE 6 ISSUE 7
5.5.2.3 Where the company 5.6.2.3 (Now 5.6.2.3) Where the
undertakes or company undertakes or
subcontracts analyses subcontracts analyses
which are critical to product which are critical to product
safety or legality, the safety or legality, the
laboratory or laboratory or
subcontractors shall have subcontractors shall have
gained recognised gained recognised
laboratory accreditation or laboratory accreditation or
operate in accordance with operate in accordance with
the requirements and the requirements and
principles of ISO 17025. principles of ISO/IEC
Documented justification 17025. Documented
shall be available where justification shall be
accredited methods are available where accredited
not undertaken. methods are not
undertaken.
5.5.2.4 Procedures shall be in 5.6.2.4 (Now 5.6.2.4) Procedures

place to ensure reliability of shall be in place to ensure
laboratory results, other reliability of laboratory
than those critical to safety results, other than those
and legality specified in critical to safety and legality
5.5.2.3. These shall include: specified in clause 5.6.2.3.
These shall include:
use of recognised test
methods, where use of recognised test
available methods, where
documented testing available
procedures documented testing
ensuring staff are procedures
suitably qualified and/or ensuring staff are
trained and competent suitably qualified and/or
to carry out the analysis trained and competent
required to carry out the analysis
use of a system to verify required
the accuracy of test use of a system to verify
results, e.g. ring or the accuracy of test
proficiency testing results (e.g. ring or
use of appropriately proficiency testing)
calibrated and use of appropriately
maintained equipment. calibrated and
maintained equipment.

5.6PRODUCT RELEASE (NOW 5.7)
ISSUE 6 ISSUE 7
Statement of intent The company shall ensure Statement of intent The site shall ensure that
that finished product is not finished product is not
released unless all agreed released unless all agreed
procedures have been procedures have been
followed. followed.
5.6.1 Where products require 5.7.1 (Now 5.7.1) Where

positive release, products require positive
procedures shall be in release, procedures shall
place to ensure that release be in place to ensure that
does not occur until all release does not occur until
release criteria have been all release criteria have
completed and release been completed and
authorised. release authorised.

6PROCESS CONTROL
6.1CONTROL OF OPERATIONS
ISSUE 6 ISSUE 7
FUNDAMENTAL The company shall operate FUNDAMENTAL The site shall operate to
Statement of intent to documented procedures Statement of intent documented procedures
and/or work instructions and/or work instructions
that ensure the production that ensure the production
of consistently safe and of consistently safe and
legal product with the legal product with the
desired quality desired quality
characteristics, in full characteristics, in full
compliance with the compliance with the
HACCP food safety plan. HACCP food safety plan.
6.1.1 Documented process 6.1.1 Documented process Additional

specifications and work specifications and work sentence moved
instructions shall be instructions shall be from former
available for the key available for the key specification
processes in the processes in the clause 3.6.2.
production of products to production of products to
ensure product safety, ensure product safety,
legality and quality. The legality and quality. The
specifications as specifications as
appropriate shall include: appropriate shall include:
recipes including recipes including

identification of any identification of any
allergens allergens
mixing instructions, mixing instructions,
speed, time speed, time
equipment process equipment process
settings settings
cooking times and cooking times and
temperatures temperatures
cooling times and cooling times and
temperatures temperatures
labelling instructions labelling instructions
coding and shelf life coding and shelf-life
marking marking
any additional critical any additional critical
control points identified control points identified
in the HACCP plan. in the HACCP plan.
Process specifications
shall be in accordance with
the agreed finished
product specification.

ISSUE 6 ISSUE 7
6.1.2 Process monitoring, such 6.1.2 Process monitoring, such
as of temperature, time, as of temperature, time,
pressure and chemical pressure and chemical
properties, shall be properties, shall be
implemented, adequately implemented, adequately
controlled and recorded to controlled and recorded to
ensure that product is ensure that product is
produced within the produced within the
required process required process
specification. specification.
6.1.3 In circumstances where 6.1.3 In circumstances where Addition of

process parameters are process parameters or quality.
controlled by in-line product quality are
monitoring devices, these controlled by in-line
shall be linked to a suitable monitoring devices, these
failure alert system that is shall be linked to a suitable
routinely tested. failure alert system that is
routinely tested.
6.1.4 Where variation in 6.1.4 Where variation in Addition of

processing conditions may processing conditions may verification to the
occur within equipment occur within equipment clause.
critical to the safety or critical to the safety or
quality of products, the quality of products, the
processing characteristics processing characteristics
shall be validated at a shall be validated and
frequency based on risk verified at a frequency
and performance of based on risk and
equipment (e.g. heat performance of equipment
distribution in retorts, (e.g. heat distribution in
ovens and processing retorts, ovens and
vessels; temperature processing vessels;
distribution in freezers and temperature distribution in
cold stores). freezers and cold stores).
6.1.5 In the case of equipment 6.1.5 In the case of equipment

failure or deviation of the failure or deviation of the
process from specification, process from specification,
place to establish the place to establish the
safety status and quality of safety status and quality of
the product to determine the product to determine
the action to be taken. the action to be taken.

ISSUE 6 ISSUE 7
6.1.6 Documented checks of the Now moved to 6.2.2
production line shall be
carried out before
commencing production
and following changes of
product. These shall
ensure that lines have been
suitably cleaned and are
ready for production.
Documented checks shall
be carried out at product
changes to ensure all
products and packaging
from the previous
production have been
removed from the line
before changing to the next
production.
6.1.7 Documented procedures Now moved to 6.2.3

shall be in place to ensure
that products are packed
into the correct packaging
and correctly labelled.
These shall include checks
at the start of packing,
during the packaging run,
following packaging
changes and when
changing batches of
packaging materials, in
order to ensure that correct
packaging materials are
used. The procedures shall
also include verification of
any code information or
other printing carried out at
the packing stage.

6.2LABELLING AND PACK CONTROL (NEW)
ISSUE 6 ISSUE 7
FUNDAMENTAL The management controls New section
Statement of intent of product labelling added to provide
activities shall ensure that emphasis to the
products will be correctly controls of
labelled and coded. labelling in
response to the
relatively high
level of recalls/
withdrawals
associated with
labelling issues.
6.2.1 (NEW) There shall be a formal New clause to

process for the allocation control allocation
of packaging materials to of packaging
packing lines and control in materials to the
the packing area which packing area to
ensures that only the reduce the
packaging for immediate opportunity for
use is available to the errors.
packaging machines.
Where off-line coding or
printing of packaging
materials occurs, checks
shall be in place that only
correctly printed material is
available at the packaging
machines.
6.2.2 (Now 6.2.2) (Formerly

6.1.6) Documented checks
of the production line shall
be carried out before
commencing production
and following changes of
product. These shall
ensure that lines have been
suitably cleared and are
ready for production.
Documented checks shall
be carried out at product
changes to ensure all
products and packaging
from the previous
production have been
removed from the line
before changing to the next
production.

ISSUE 6 ISSUE 7
6.2.3 (Now 6.2.3) (Formerly 6.1.7) Requirements
Documented procedures extended to
shall be in place to ensure provide additional
that products are packed clarity of checks
into the correct packaging which may be
and correctly labelled. required to
These shall include checks: ensure correct
labelling.
at the start of packing
during the packing run
when changing batches
of packaging materials
at the end of each
production run.
The checks shall also
include verification of any
printing carried out at the
packing stage including, as
appropriate:
date coding
batch coding
quantity indication
pricing information
bar coding
country of origin.
6.2.4 (NEW) Where on-line vision New requirement
equipment is used to check applicable only
product labels and printing, where on-line
procedures shall be in label equipment
place to ensure that the is used.
system is correctly set up
and capable of alerting or
rejecting product when
packaging information is
out of specification.

6.2QUANTITY WEIGHT, VOLUME AND NUMBER CONTROL (NOW 6.3)
ISSUE 6 ISSUE 7
Statement of intent The company shall operate Statement of intent The site shall operate a
a quantity control system quantity control system
which conforms to legal which conforms to legal
requirements in the country requirements in the country
where the product is sold where the product is sold
and any additional industry and any additional industry
sector codes or specified sector codes or specified
customer requirement. customer requirements.
6.2.1 The frequency and 6.3.1 (Now 6.3.1) The frequency

methodology of quantity and methodology of
checking shall meet the quantity checking shall
requirements of meet the requirements of
appropriate legislation appropriate legislation
governing quantity governing quantity
verification, and records of verification, and records of
checks shall be checks shall be retained.
maintained.
6.2.2 Where the quantity of the 6.3.2 (Now 6.3.2) Where the
product is not governed by quantity of the product is
legislative requirements not governed by legislative
(e.g. bulk quantity), the requirements (e.g. bulk
product must conform to quantity), the product must
customer requirements conform to customer
and records shall be requirements and records
maintained. shall be maintained.

6.3CALIBRATION AND CONTROL OF MEASURING AND MONITORING DEVICES
(NOW 6.4)
ISSUE 6 ISSUE 7
Statement of intent The company shall be able Statement of intent The site shall be able to
to demonstrate that demonstrate that
measuring and monitoring measuring (removal of
equipment is sufficiently monitoring) equipment is
accurate and reliable to sufficiently accurate and
provide confidence in reliable to provide
measurement results. confidence in
measurement results.
6.3.1 The company shall identify 6.4.1 (Now 6.4.1) The site shall
and control measuring identify and control
equipment used to monitor measuring equipment
CCPs, product safety and used to monitor critical
legality. control points, product
safety and legality. This
This shall include as a
shall include as a minimum:
minimum:
a documented list of a documented list of

equipment and its
equipment and its
location
location
an identification code an identification code
and calibration due date
and calibration due date
prevention from prevention from
adjustment by
adjustment by
unauthorised staff
unauthorised staff
protection from protection from
damage, deterioration
damage, deterioration
or misuse.
or misuse.
6.3.2 All identified measuring 6.4.2 (Now 6.4.2) All identified

devices, including new measuring devices,
equipment, shall be including new equipment,
checked and where shall be checked and
necessary adjusted: where necessary adjusted:
at a predetermined at a predetermined
frequency, based on risk frequency, based on risk
assessment assessment
to a defined method to a defined method
traceable to a traceable to a
recognised national or recognised national or
international Standard international standard
where possible. where possible.
Results shall be Results shall be
documented. Equipment documented. Equipment
shall be readable and be of shall be readable and be of
a suitable accuracy for the a suitable accuracy for the
measurements it is required measurements it is required
to perform. to perform.

ISSUE 6 ISSUE 7
6.3.3 Reference measuring 6.4.3 (Now 6.4.3) Reference Added point to
equipment shall be measuring equipment shall ensure calibration
calibrated and traceable to be calibrated and traceable criteria considers
a recognised national or to a recognised national or the accuracy
international Standard and international standard and required of the
records maintained. records maintained. The equipment.
uncertainty of calibration
shall be considered when
equipment is used to
assess critical limits.
6.3.4 Procedures shall be in 6.4.4 (Now 6.4.4) Procedures

place to record actions to shall be in place to record
be taken when the actions to be taken when
prescribed measuring and the prescribed measuring
monitoring devices are (removal of and monitoring)
found not to be operating devices are found not to be
within specified limits. operating within specified
Where the safety or legality limits. Where the safety or
of products is based on legality of products is
equipment found to be based on equipment found
inaccurate, action shall to to be inaccurate, action
be taken to ensure at-risk shall be taken to ensure
product is not offered for at-risk product is not
sale. offered for sale.

7PERSONNEL
7.1TRAINING: RAW MATERIAL HANDLING, PREPARATION, PROCESSING,

PACKING AND STORAGE AREAS
ISSUE 6 ISSUE 7
FUNDAMENTAL The company shall ensure FUNDAMENTAL The company shall ensure
Statement of intent that all personnel Statement of intent that all personnel
performing work that performing work that
affects product safety, affects product safety,
legality and quality are legality and quality are
demonstrably competent demonstrably competent
to carry out their activity, to carry out their activity,
through training, work through training, work
experience or qualification. experience or qualification.
7.1.1 All relevant personnel, 7.1.1 All relevant personnel, Addition of

including temporary staff including agency-supplied agency-supplied
and contractors, shall be staff, temporary staff and staff.
appropriately trained prior contractors, shall be
to commencing work and appropriately trained prior
adequately supervised to commencing work and
throughout the working adequately supervised
period. throughout the working
period.
7.1.2 Where personnel are 7.1.2 Where personnel are

engaged in activities engaged in activities
relating to critical control relating to critical control
points, relevant training points, relevant training
and competency and competency
assessment shall be in assessment shall be in
place. place.
7.1.3 The company shall put in 7.1.3 The site shall put in place
place documented documented programmes
programmes covering the covering the training needs
training needs of relevant of relevant personnel.
personnel. These shall
These shall include as a
include as a minimum:
minimum:
identifying the identifying the
necessary
necessary
competencies for
competencies for
specific roles
specific roles
providing training or
providing training or
other action to ensure
other action to ensure
staff have the necessary
staff have the necessary
competencies
competencies
reviewing the
reviewing the
effectiveness of training
effectiveness of training
the delivery of training in
the delivery of training in
the appropriate
the appropriate
language of trainees.
language of trainees.

ISSUE 6 ISSUE 7
7.1.4 (Now 7.1.4) (Formerly 5.2.9) This requirement
All relevant personnel, has moved from
including engineers, the allergen
agency-supplied staff and section 5.2.9.
temporary staff and
contractors, shall have
received general allergen
awareness training and be
trained in the sites
allergen-handling
procedures.
7.1.4 Records of all training shall 7.1.5 (Now 7.1.5) Records of all
be available. This shall training shall be available.
include as a minimum: This shall include as a
minimum:
the name of the trainee
and confirmation of the name of the trainee
attendance and confirmation of
the date and duration of attendance
the training the date and duration of
the title or course the training
contents, as appropriate the title or course
the training provider. contents, as appropriate
Where training is the training provider.
undertaken by agencies on Where training is
behalf of the company, undertaken by agencies on
records of the training shall behalf of the company,
be available. records of the training shall
be available.
7.1.5 The company shall 7.1.6 (Now 7.1.6) The company

routinely review the shall routinely review the
competencies of its staff. competencies of its staff.
As appropriate, it shall As appropriate, it shall
provide relevant training. provide relevant training.
This may be in the form of This may be in the form of
training, refresher training, training, refresher training,
coaching, mentoring or coaching, mentoring or
on-the-job experience. on-the-job experience.

7.2PERSONAL HYGIENE: RAW MATERIAL HANDLING, PREPARATION,
PROCESSING, PACKING AND STORAGE AREAS
ISSUE 6 ISSUE 7
Statement of intent The companys personal Statement of intent The sites personal hygiene Slight change of
hygiene standards shall be standards shall be wording to better
appropriate to the products developed to minimise the express the intent
produced, documented, risk of product
and adopted by all contamination from
personnel, including personnel, be appropriate
agency staff, contractors to the products produced
and visitors to the and be adopted by all
production facility. personnel, including
agency-supplied staff,
contractors and visitors to
the production facility.
7.2.1 The requirements for 7.2.1 The requirements for Addition of nail art
personal hygiene shall be personal hygiene shall be as this is
documented and documented and becoming more
communicated to all communicated to all common in some
personnel. This shall personnel. This shall countries and
include as a minimum the include as a minimum the may lead to
following requirements : following requirements: contamination
when handling
Watches shall not be Watches shall not be products.
worn. worn.
Jewellery shall not be Jewellery shall not be
worn, with the exception worn, with the exception
of a plain wedding ring of a plain wedding ring
or wedding wristband. or wedding wristband.
Rings and studs in Rings and studs in
exposed parts of the exposed parts of the
body, such as ears, body, such as ears,
noses, tongues and noses, tongues and
eyebrows, shall not be eyebrows, shall not be
worn. worn.
Fingernails shall be kept Fingernails shall be kept
short, clean and short, clean and
unvarnished. False unvarnished.
fingernails shall not be False fingernails and nail
permitted. art shall not be permitted
Excessive perfume or Excessive perfume or
aftershave shall not be aftershave shall not be
worn. worn.
Compliance with the Compliance with the
requirements shall be requirements shall be
checked routinely. checked routinely.
7.2.2 Hand cleaning shall be 7.2.2 Hand-washing shall be

performed on entry to the performed on entry to the
production areas and at a production areas and at a
frequency that is frequency that is
appropriate to minimise the appropriate to minimise the
risk of product risk of product

ISSUE 6 ISSUE 7
7.2.3 All cuts and grazes on 7.2.3 All cuts and grazes on
exposed skin shall be exposed skin shall be
covered by an covered by an
appropriately coloured appropriately coloured
plaster that is different from plaster that is different from
the product colour the product colour
(preferably blue) and (preferably blue) and
containing a metal contains a metal detectable
detectable strip. These strip. These shall be site
shall be company issued issued and monitored.
and monitored. Where Where appropriate, in
appropriate, in addition to addition to the plaster, a
the plaster, a glove shall be glove shall be worn.
worn.
7.2.4 Where metal detection 7.2.4 Where metal detection

equipment is used, a equipment is used, a
sample from each batch of sample from each batch of
plasters shall be plasters shall be
successfully tested successfully tested
through the equipment and through the equipment and
records shall be kept. records shall be kept.
7.2.5 Processes and written 7.2.5 Processes and written

instructions for staff shall instructions for staff shall
be in place to control the be in place to control the
use and storage of use and storage of
personal medicines, so as personal medicines, so as
to minimise the risk of to minimise the risk of
product contamination. product contamination.

7.3MEDICAL SCREENING
ISSUE 6 ISSUE 7
Statement of intent The company shall ensure Statement of intent The company shall have
that procedures are in procedures in place to
place to ensure that ensure that employees,
employees, agency staff, agency staff, contractors or
contractors or visitors are visitors are not a source of
not a source of transmission of food-borne
transmission of food-borne diseases to products.
diseases to products.
7.3.1 The company shall have a 7.3.1 The site shall make Rewording of the
procedure which enables employees aware of the clause to make
notification by employees, symptoms of infection, the intent clear
including temporary disease or condition which whilst accepting
employees, of any relevant would prevent a person that in some
infection, disease or working with open food. countries there
condition with which they The site shall have a are restrictions on
may have been in contact procedure which enables what personal
or be suffering from. notification by employees, information is
including temporary allowed to be
employees, of any relevant asked of
symptoms, infection, employees.
disease or condition with
which they may have been
in contact or be suffering
from.
7.3.2 Where there may be a risk 7.3.2 Where there may be a risk Reworded as
to product safety, visitors to product safety, visitors above.
and contractors shall be and contractors shall be
required to complete a made aware of the types of
health questionnaire or symptoms, infection,
otherwise confirm that they disease or condition which
are not suffering from a would prevent a person
condition which may put visiting areas with open
product safety at risk, prior food. Where permitted by
to entering the raw material, law, visitors shall be
preparation, processing, required to complete a
packing and storage areas. health questionnaire or
otherwise confirm that they
are not suffering from any
symptoms which may put
product safety at risk, prior
to entering the raw material,
preparation, processing,
packing and storage areas.

ISSUE 6 ISSUE 7
7.3.3 There shall be documented 7.3.3 There shall be documented
procedures for employees, procedures for employees,
contractors and visitors, contractors and visitors
relating to action to be relating to action to be
taken where they may be taken where they may be
suffering from or have been suffering from or have been
in contact with an in contact with an
infectious disease. Expert infectious disease. Expert
medical advice shall be medical advice shall be
sought where required. sought where required.
7.4PROTECTIVE CLOTHING: EMPLOYEES OR VISITORS TO PRODUCTION

AREAS
ISSUE 6 ISSUE 7
Statement of intent Suitable company-issued Statement of intent Suitable site-issued
protective clothing shall be protective clothing shall be
worn by employees, worn by employees,
contractors or visitors contractors or visitors
working in or entering working in or entering
production areas. production areas.
7.4.1 The company shall 7.4.1 The company shall Clarification that
document and document and the clause also
communicate to all communicate to all applies to agency
employees, contractors or employees (including and temporary
visitors the rules regarding agency and temporary staff.
the wearing of protective personnel), contractors or
clothing in specified work visitors the rules regarding
areas (e.g. high-care or the wearing of protective
low-risk areas). This shall clothing in specified work
also include policies areas (e.g. high-care or
relating to the wearing of high-risk areas). This shall
protective clothing away also include policies
from the production relating to the wearing of
environment (e.g. removal protective clothing away
before entering toilets, use from the production
of canteen and smoking environment (e.g. removal
areas). before entering toilets, use
of canteen and smoking
areas).

ISSUE 6 ISSUE 7
7.4.2 Protective clothing shall be 7.4.2 Protective clothing shall be
available that: available that:
is provided in sufficient is provided in sufficient

numbers for each numbers for each
employee employee
is of suitable design to is of suitable design to
prevent contamination prevent contamination
of the product (as a of the product (as a
minimum containing no minimum containing no
external pockets above external pockets above
the waist or sewn on the waist or sewn-on
buttons) buttons)
fully contains all scalp fully contains all scalp
hair to prevent product hair to prevent product
contamination contamination
includes snoods for includes snoods for
beards and moustaches beards and
where required to moustaches, where
prevent product required, to prevent
contamination. product contamination.
7.4.3 Laundering of protective 7.4.3 Laundering of protective

clothing shall take place by clothing shall take place by
an approved contracted or an approved contracted or
in-house laundry using in-house laundry using
defined and verified criteria defined (removal of and
to validate the verified) criteria to validate
effectiveness of the the effectiveness of the
laundering process. laundering process. The
Washing of workwear by laundry must operate
the employee is procedures which ensure:
exceptional but shall be
acceptable where the adequate segregation
between dirty and
protective clothing is to
cleaned clothes
protect the employee from
the products handled and effective cleaning of the
protective clothing
the clothing is worn in
enclosed product or protective clothing for
high-risk or high-care
low-risk areas only.
areas is commercially
sterile following the
washing and drying
process
cleaned clothes are
supplied protected from
contamination until use
(e.g. by the use of covers
or bags).
(Bullet points taken from
7.4.4)

ISSUE 6 ISSUE 7
7.4.3 cont. 7.4.3 cont. Washing of protective

clothing by the employee is
exceptional but shall be
acceptable where the
protective clothing is to
protect the employee from
the products handled and
the clothing is worn in
enclosed product or
low-risk areas only.
7.4.4 Where protective clothing 7.4.4 Where protective clothing

for high-care or high-risk for high-care or high-risk
areas is provided by a areas is cleaned by a
contracted laundry, this contracted or in-house
shall be audited either laundry, this shall be
directly or by a third party, audited either directly or by
or should have a relevant a third party. The frequency
certification. The laundry of these audits should be
must operate procedures based on risk.
which ensure:
effective cleaning of the

protective clothing
clothes are
commercially sterile
following the washing
and drying process
adequate segregation
between dirty and
cleaned clothes
cleaned clothes are
protected from
contamination until
delivered to the site, e.g.
by the use of covers or
bags.
7.4.5 (NEW) Protective clothing shall be New clause to

changed at an appropriate ensure protective
frequency, based on risk. clothing is
For high-risk and high-care changed at an
areas the protective appropriate
clothing shall be changed frequency.
at least daily.
7.4.5 If gloves are used, they 7.4.6 (Now 7.4.6) If gloves are
shall be replaced regularly. used, they shall be
Where appropriate, gloves replaced regularly. Where
shall be suitable for food appropriate, gloves shall be
use, of a disposable type, suitable for food use, of a
of a distinctive colour (blue disposable type, of a
where possible), be intact distinctive colour (blue
and not shed loose fibres. where possible), be intact
and not shed loose fibres.

ISSUE 6 ISSUE 7
7.4.6 Where items of personal 7.4.7 (Now 7.4.7) Where items of
protective clothing that are personal protective
not suitable for laundering clothing that are not
are provided (such as chain suitable for laundering are
mail, gloves and aprons), provided (such as chain
these shall be cleaned and mail, gloves and aprons),
sanitised at a frequency these shall be cleaned and
based on risk. sanitised at a frequency
based on risk.

BRC Global Standards
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OD SAFETY

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For more information about BRC, contact:

British Retail Consortium

Tel: +44 (0) 20 7854 8900

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BACKGROUND TO THE PRODUCTION OF ISSUE 7 AND OBJECTIVES

The key objectives identified for the working groups were:

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REDUCING THE EXPOSURE TO FOOD FRAUD (CLAUSES 5.4.13)

SUPPLY CHAIN TRACEABILITY (CLAUSE 3.9.3)

AGENTS AND BROKERS (CLAUSE 3.5.1.3)

CUSTOMER FOCUS (CLAUSE 3.12)

MANAGEMENT OF SURPLUS FOOD PRODUCTS (CLAUSE 4.13)

NEW AMBIENT HIGH-CARE AREAS (CLAUSE 4.3.7)

CHANGES TO THE PROTOCOL

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1SENIOR MANAGEMENT COMMITMENT

1.1SENIOR MANAGEMENT COMMITMENT AND CONTINUAL IMPROVEMENT

signed by the person signed by the person

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1.1.3 Management review 1.1.3 Management review

previous management previous management

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1.1.8 Where the company is 1.1.8 Where the site is

1.1.10 The companys senior 1.1.10 The sites senior

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1.2.2 The companys senior 1.2.2 The sites senior

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2.1THE HACCP FOOD SAFETY TEAM CODEX ALIMENTARIUS STEP 1

2.1.2 (NEW) The scope of each HACCP Existing

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cleaning and sanitising cleaning and sanitising

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composition, e.g. raw composition (e.g. raw

physical or chemical physical or chemical

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2.4IDENTIFY INTENDED USE CODEX ALIMENTARIUS STEP 3

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plan of premises and plan of premises and

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2.7LIST ALL POTENTIAL HAZARDS ASSOCIATED WITH EACH PROCESS

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likely occurrence of likely occurrence of

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2.9ESTABLISH CRITICAL LIMITS FOR EACH CCP CODEX ALIMENTARIUS

measurable wherever measurable wherever

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2.10ESTABLISH A MONITORING SYSTEM FOR EACH CCP CODEX

online measurement on-line measurement

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2.11ESTABLISH A CORRECTIVE ACTION PLAN CODEX ALIMENTARIUS

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2.13HACCP DOCUMENTATION AND RECORD KEEPING CODEX

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change in raw materials change in raw materials

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3.1FOOD SAFETY AND QUALITY MANUAL

3.1.1 The companys 3.1.1 The sites documented

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