BRCGS Food Safety Management System Implementation Workbook

This workbook is provided to assist in the implementation of your

BRCGS food safety management system. The workbook is divided into
8 steps that are designed to assist you in implementing your food safety
management system effectively:

✓ Step One: Introduction to the BRCGS Global Standard for Food

Safety Issue 9 & Meeting FSMA Requirements for Food
✓ Step Two: Senior Management Implementation
✓ Step Three: Food Safety Plan/HACCP Implementation
✓ Step Four: Food Safety Quality Management System
✓ Step Five: BRCGS Implementation Planning & Training
✓ Step Six: Internal Auditing Training & Checklists
✓ Step Seven: Final Steps to BRCGS Certification

The Workbook guides you through the process of implementing our

BRCGS Food Safety Quality Management System, which is an ideal
package for Food Manufacturers looking to meet British Retail
Consortium Global for Food Safety 2022 (Issue 9) and Module 13
MEETING FSMA REQUIREMENTS FOR FOOD

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This comprehensive system contains:

✓ Comprehensive Procedures Manual

✓ HACCP Manual containing the HACCP Calculator
✓ Laboratory Quality Manual
✓ Training Modules
→ Implementing the BRCGS Food Safety Management System
Presentation
→ Integrating FSMA Requirements with BRCGS Food
Presentations
→ HACCP Training and FSMA Hazards Analysis & Preventive
Controls Guidance & Tools
→ Internal Audit & Hygiene Inspection Training
→ Training and Checklists
✓ FSQMS, Verification and Validation Record Templates
✓ Free online support via e-mail

As well as being updated this BRCGS Implementation Package includes

additional management tools to help you achieve BRCGS certification:

✓ Allergen Management Module & Risk Assessment Tool

✓ Supplier Risk Assessment Tool
✓ Product Development Module
✓ BRCGS Risk Assessment Tool
✓ Complaint Management Guidelines & Analyzer
✓ Verification Schedule Risk Assessment Tool and Template

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Step One: Introduction to the IFSQN BRCGS Food Safety

Management System Issue 9 & Meeting FSMA Requirements

Introduction to the IFSQN BRCGS Food Safety Quality Management

System Issue 9

This PowerPoint training module presentation will introduce the BRCGS

Global Standard for Food Safety to the management team and explain
how to start the process of implementing a BRCGS compliant Food
Safety Management System using the IFSQN Implementation Package.

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Integrating FSMA Requirements with BRCGS Food

This PowerPoint training module presentation explains how to Integrate

FSMA Requirements into a BRCGS compliant Food Safety Management
System.

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Step Two: Senior Management Implementation

A Senior Management Implementation checklist is provided that

establishes your Food Safety Management System fundamentals
including Food Safety Policies and Objectives.

The checklist guides Senior Management:

✓ in planning the establishment of the FSQMS

✓ in providing adequate support to establish the FSQMS
✓ in ensuring there is adequate infrastructure and work
environment
✓ in allocating responsibility and authority

This stage requires the Senior Management to meet and establish the
foundations for the Food Safety Management System:

✓ Formulating a checklist of Customer, Regulatory, Statutory and

other relevant Food Safety requirements
✓ Decide which Food Safety requirements the company should
address and develop relevant policies.
✓ Based on the Food Safety Policy Management Policies establish
Food Safety Objectives
✓ Define the scope and boundaries of the FSQMS
✓ Plan the establishment of the FSQMS using the project planner
✓ Provide adequate support to establish the FSQMS
✓ Ensure there is adequate infrastructure and work environment and
develop a Corrective Action Plan to rectify Prerequisite shortfalls
✓ Allocate responsibility and authority
✓ Assess, plan and establish appropriate internal and external
communication (including the food chain) channels
✓ Plan to establish a food safety culture

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As a decision has already been made to implement a system compliant

with the BRCGS Global Standard for Food Safety, the Senior
Management meeting should also consider the requirements of the
Standard which are summarized below and should be read direct from
the Standard:

Section 1 Senior Management Commitment

The site’s senior management shall demonstrate they are fully committed to the
implementation of the requirements of the Global Standard Food Safety and to processes
which facilitate continual improvement of food safety, quality management and the site’s
food safety and quality culture.
1.1 Senior Management Commitment and Continual Improvement
Documented Food Safety Policy - produce safe, legal and authentic products to the
1.1.1
specified quality
1.1.2 Plan and Develop Food Safety & Quality Culture

1.1.3 Documented Food Safety Objectives for safety, authenticity, legality and quality

1.1.4 Management Review

1.1.5 Meeting Program

1.1.6 Confidential Reporting System

1.1.7 Human and Financial Resources

Informed of scientific/technical developments, industry codes of practice, new risks
1.1.8
to authenticity of raw materials & relevant legislation
1.1.9 Current, Original Copy of the Standard

1.1.13 Logo & certification status

Appropriate registrations with the relevant authorities where required by
1.1.14
legislation
1.2 Organizational Structure, Responsibilities and Management Authority
1.2.1 Organization Chart

1.2.2 Employees Are Aware of Responsibilities

1.2.3 Staff shall be aware of the need to report any risks

1.2.4 Use of external expertise

A meeting should now be coordinated involving all the Senior

Management Team.

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Senior Management FSQMS Implementation Meeting

Date

Time

Venue

Agenda

1. Formulating a checklist of Customer, Regulatory, Statutory and

other relevant Food Safety requirements
2. Decide which Food Safety requirements the company should
address and develop relevant policies.
3. Based on the Food Safety Policy Management Policies establish
Food Safety Objectives
4. Define the scope and boundaries of the FSQMS
5. Plan the establishment of the FSQMS using the project planner
6. Provide adequate support to establish the FSQMS
7. Ensure there is adequate infrastructure and work environment
8. Allocate responsibility and authority
9. Assess, plan and establish appropriate internal and external
communication (including the food chain) channels
10. Plan to establish a food safety culture

Attendees:

Senior Management Team

Job Title Name Role in Team
Managing Director Chairman
General Manager Deputy Chair
Operations Manager Operations Reporting
Technical Manager Food Safety and Quality Reporting
Planning Manager Planning and Capacity Reporting
Distribution Manager Distribution Reporting
Maintenance Manager Services and Engineering Provision
Finance Manager Financial Reporting
Human Resources Manager Resource reporting

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Senior Management FSQMS Implementation Checklist

The Senior Management FSQMS Implementation Meeting should follow

the guidelines of the Senior Management Implementation Checklist:

Senior management formulate a checklist of Customer, Regulatory, Statutory

and other relevant Food Safety requirements
Customer/Regulatory/Statutory/Other Record Details
FSMA Final Rule for Preventive Controls
for Human Food
BRCGS Global Standard for Food Safety
Issue 9
Food Regulations
CODEX Recommended International
Action
Code of Practice General Principles of
(i)
Food Hygiene (2020) Chapter Two
HAZARD ANALYSIS AND CRITICAL
CONTROL POINT (HACCP) SYSTEM AND
GUIDELINES FOR ITS APPLICATION.
BRCGS Module 13 MEETING FSMA
REQUIREMENTS FOR FOOD

Senior Management decides which Food Safety requirements the company

should address and develop relevant policies.
Requirement Policy Details

Action
(ii)

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Senior Management can choose/adapt the templates supplied with the

system to assist in documenting policies and objectives:

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Senior Management Establish the Project Plan

Senior Management can adapt/use the template supplied with the

system to establish a Project Plan.

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Senior Management Establish Food Safety Responsibility & Authority

Levels

Responsible
Process Activity
Persons
Purchases Purchasing Purchase ingredients from approved and certified
Manager sources
Ensure purchase orders comply with applicable
specifications
Quality Ensure adequate information on supply application form
Manager Ensure suppliers adhere to supply handling practices
Perform suppliers audit or review supply status where
necessary
Receiving and QA/QC & Compare Purchase Order and Delivery note or check
warehousing Store contracts as per Suppliers Specifications criteria (if
Executives applicable)
Check receiving temperature, pest infestations, quality,
packing conditions and truck hygiene.
Observe unloading practices
Handle incoming goods as per documented procedures
Ensure Good Storage Practices and FIFO rotation
principles
Preparation of QA/QC, Follow safe food preparation and handling practices
Ingredients Production Check environmental hygiene and safety
Manager & Check equipment process performance and
Production maintenance
Executive Check water quality and safety
Check raw materials identification and traceability
Production QC/QC, Maintain product recipes and characteristics
Production Do not modify recipes prior to approval from top
Manager, management
Supervisor & Follow safe food handling practices
Operators Ensure Good Manufacturing Practices are adhered to
Follow cleaning and sanitation standards and
procedures
Follow the handling standards of raw and processed
foods
Holding and Filling of Production Follow safe food holding procedures
Processed Food Supervisor & Hold foods outside the range of danger zone
Operators Follow safe food filling procedures into primary
packaging
Capping, coding and Production Follow safe capping procedures
packing Supervisor & Ensure food in primary packaging are hygienically
Operators located
Ensure coding for traceability is performed to
procedures
Follow secondary packaging procedures to protect
products

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Internal Communication

The Senior Management Team should assume responsibility for

ensuring that appropriate communication processes are established,
implemented and maintained regarding the effectiveness of the quality,
food safety (including any food safety issues) and environmental control
systems.

These communication processes can include:

- Team briefings
- Staff reviews
- Daily Management meetings
- Shift Handover meetings
- Newsletters
- Notice boards

Regular communication is important to keep all employees aware of

company performance in meeting policies and objectives. The following
key information should be communicated regularly:

- Key Performance Indicators

- Results of External Audits
- Results of Customer visits
- Results of Inspections by Regulatory Authorities
- Preventive actions
- Serious complaints
- Product withdrawal
- New product launches
- Changes in raw materials, ingredients and services
- Changes in processes, production systems, packaging,
equipment and/or products
- Changes in cleaning and disinfection procedures
- Customers or customer requirement changes
- Changes in production premises, equipment (including
location), storage systems, distribution systems and the
surrounding environment
- Management Changes and changes in levels of responsibility
and authority

The following additional key information should be communicated

promptly to the food safety team so that they can ensure the information

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is included in updating the food safety quality management system

where appropriate:

- Results of Inspections by Regulatory Authorities and any

changes in regulatory requirements
- New information regarding Food Safety Hazards and Control
Measures
- Food Safety Issues and Health Hazards associated with the
product
- Anything else considered likely to have an impact on food
safety

By communicating effectively with all employees all employees will be

able to contribute to the effectiveness of the Food Safety Quality
Management System.

Senior management assess plan and establish appropriate internal and

external communication (including the food chain) channels
Communication required Details Responsibility

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Step Three: Food Safety Plan/HACCP Implementation

HACCP Training

A HACCP training presentation is supplied to train your food safety team

in the preliminary steps to a Hazard analysis, the principles of HACCP
and Instructions in implementing your HACCP system.

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HACCP System

The HACCP System is implemented by following the FSQMS

procedures:

FSQMS Section 2
FS 2 HACCP System
FS 2.1.1 HACCP Team
FS 2.1.2 HACCP Scope
FS 2.2 HACCP Prerequisites
FS 2.3 HACCP Product Description and Relevant Information
FS 2.4 HACCP Intended Use
FS 2.5 HACCP Flow Diagrams
FS 2.6 HACCP Flow Diagram Verification
FS 2.7.1 Hazard Identification
FS 2.7.2 Hazard Assessment
FS 2.7.3 Identification of Control Measures
FS 2.8 Identification of Critical Control Points (CCPs)
FS 2.9 Establishing Validated Critical Limits for each CCP
FS 2.10 Establishing a Monitoring System for each CCP
FS 2.11 Establishing a Corrective Action Plan
FS 2.12 Validating the HACCP Plan and Establishing Verification
Procedures
FS 2.13 Establishing HACCP Documents and Records

Supplementary HACCP Tools and Documents

HACCP Calculator CODEX 2022 & BRCGS Issue 9 & Instructions

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HACCP - Meeting FSMA Requirements for Food

FSMA and Preventive Controls

Training presentations are provided to train your food safety team in the
requirements of FSMA for Preventive Controls and Supply Chain
Controls

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HACCP Implementation Tasks

HACCP Implementation Tasks are to be completed by the Food Safety

Team using the guidelines included in this HACCP Implementation
Section. We will go through the task by section as the requirements are
listed in Section 2 of the BRCGS Global Standard for Food Safety. Note
that the documents match the clauses of the section for ease of
implementation.

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This implementation is based on CODEX Guidelines for HACCP

Application:

The Food Safety System has been developed based on CODEX

Recommended International Code of Practice General Principles of
Food Hygiene 2020 Edition - CHAPTER TWO - HAZARD ANALYSIS
AND CRITICAL CONTROL POINT (HACCP) SYSTEM AND
GUIDELINES FOR ITS APPLICATION - SECTION 3: APPLICATION

3.1 Assemble HACCP Team and Identify Scope (Step 1)

3.2 Describe product (Step 2)
3.3 Identify intended use and users (Step 3)
3.4 Construct flow diagram (Step 4)
3.5 On-site confirmation of flow diagram (Step 5)
3.6 List all potential hazards that are likely to occur and associated with
each step, conduct a hazard analysis to identify the significant hazards,
and consider any measures to control identified hazards (Step 6/
Principle 1)
3.7 Determine the Critical Control Points (Step 7/ Principle 2)
3.8 Establish validated critical limits for each CCP (Step 8/ Principle 3)
3.9 Establish a Monitoring System for Each CCP (Step 9/ Principle 4)
3.10 Establish corrective actions (Step 10/ Principle 5)
3.11 Validation of the HACCP Plan and Verification Procedures (Step 11/
Principle 6)
3.11.1 Validation of the HACCP Plan
3.11.2 Verification Procedures
3.12 Establish Documentation and Record Keeping (Step 12/ Principle 7)
3.13 Training

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HACCP Implementation Guide Section 2.1 Food Safety Team

A core multidisciplinary team is utilized within the company to develop

the Food Safety Management System and HACCP (Food Safety) plans.
This team includes personnel from engineering, production operations
quality assurance, technical management and other relevant functions
with knowledge of the relevant raw materials, packaging, processing
aids, products and associated processes. This core team is
supplemented by other staff when specific areas or products are being
analyzed and by departmental staff who can contribute expert
knowledge of their particular areas.

The HACCP team have knowledge and experience of HACCP,

Products, the Process, the Equipment, and Associated Hazards. Food
Safety Team Members have knowledge and experience of HACCP
Systems and in developing and implementing a food safety
management system.

Key personnel identified as HACCP team members are HACCP trained

and have appropriate experience, all of which is documented on the
HACCP teams training records. Expert external assistance is used as an
aid, when in-house knowledge is limited, but day-to-day management of
the food safety system remains the responsibility of the HACCP Team.

A typical HACCP Team may include:

Team Member HACCP Training

Technical Manager (PCQI) Advanced

Laboratory Manager Intermediate

Processing Manager Intermediate

Engineering Manager Intermediate

Operations Manager Intermediate

Warehouse Manager Intermediate

Production Manager Intermediate

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Control Measure Validation

Product Category
Step Number
Hazard
Control Measure
Applicable
Validation Methods Comments
Yes No
Third Party Scientific
Validation
Historical Knowledge
Simulated Production
Conditions
Collection of Data in normal
production
Admissible in industrial
practices
Statistical Programs
Mathematical Modelling
Conclusion
Internal Validation Required?
If so by which method?

CCP Confirmed
Authorized by(Name):
Signature:

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HACCP Implementation Guide Section 2.12

Validating the HACCP Plan

Before the HACCP (Food Safety) Plan can be implemented and prior to
any change that may affect product safety, the HACCP Plan is validated
by the HACCP (Food Safety) Team; this consists of making sure that the
following elements together are capable of ensuring control of the
significant hazards relevant to the food business:
Hazards
Critical Control Points
Critical Limits
Control Measures
Frequency & Type of Monitoring of CCPs
Corrective Actions
Recorded information

For existing HACCP food safety plans, validation may be possible using
existing verification procedures and results

Establish Verification Procedures

Verification Planning

The Food Safety Team should define the methods, frequencies and
responsibilities for verification activities. Verification activities should be
put in place by the Food Safety Team to confirm the effective operation
of the Food Safety Management System.

The following areas should be verified by HACCP verification audit and

review of Key Performance indicators:

HACCP plan is implemented and effective

PRP(s) Infrastructure and Maintenance are implemented
Hazards are below identified acceptable levels
All other procedures required for the effective operation of the Food
Safety Management system are implemented and effective

The Food Safety Representative is usually responsible for establishing

an audit schedule and allocating audit responsibility.

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HACCP - Meeting FSMA Requirements for Food

FSMA and Preventive Controls

When implementing your Food Safety (HACCP) System remember to

ensure the requirements of FSMA for Preventive Controls and Supply
Chain Controls are considered. Preventive Controls are required for
Significant Hazards.

Remember (c) Hazard evaluation. (1)

(i) The hazard analysis must include an evaluation of the hazards
identified in paragraph (b) of this section to assess the severity of the
illness or injury if the hazard were to occur and the probability that the
hazard will occur in the absence of preventive controls.

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Step Four: Food Safety Quality Management System

This Food Safety Management System Implementation Package

contains comprehensive BRCGS compliant documentation.

The Food Safety Quality Manual contains comprehensive top level

procedures templates that form the foundations of your Food Safety
Management System so you don't have to spend 1,000's of hours writing
compliant procedures.

There are procedures that cover each clause and section of the BRCGS
Global Standard for Food Safety Issue 9

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Food Safety Management System, Verification and Validation Record

Templates

A comprehensive range of easy to use food safety record templates are

included in the package

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Food Safety and Quality Management System Implementation

Food Safety and Quality Management System Implementation can be

completed using the Food Safety Management System templates:

1 Senior Management Commitment

FS 1.1 Senior Management Commitment

FS 1.1.1 Food Safety and Quality Policy
FS 1.1.2 Food Safety Culture
FS 1.1.2 Food Safety Culture Planning
FS 1.1.2 Food Safety Culture - Expected Behaviors
FS 1.1.3 Food Safety and Quality Objectives
FS 1.1.4 Senior Management Review
FS 1.1.4 Appendix Senior Management Review Record
FS 1.1.5 Management Meetings
FS 1.1.6 Appendix Integrity Helpline
FS 1.1.6 Confidential Reporting System
FS 1.1.7 Human and Financial Resources
FS 1.2 Responsibility and Authority
FS 1.2 Appendix Example Organizational Chart
FS 1.2 Responsibility Appendix Example Job Descriptions
FS 1.2A Communication

2 The Food Safety Plan – HACCP

FS 2 HACCP System
FS 2.1 HACCP Team and Scope
FS 2.2 HACCP Prerequisites
FS 2.3 HACCP Product Description and Relevant Information
FS 2.4 HACCP Intended Use
FS 2.5 HACCP Flow Diagrams
FS 2.6 HACCP Flow Diagram Verification
FS 2.7.1 Hazard Identification
FS 2.7.2 Hazard Assessment
FS 2.7.3 Identification of Control Measures
FS 2.8 Identification of Critical Control Points (CCPs)
FS 2.9 Establishing Validated Critical Limits for each CCP
FS 2.10 Establishing a Monitoring System for each CCP
FS 2.11 Establishing a Corrective Action Plan
FS 2.12 FS 2.12 Validating the HACCP Plan and Establishing
Verification Procedures
FS 2.13 Establishing HACCP Documents and Records

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Step Five: Training and Implementation

A significant part of the implementation process is training. Job

Descriptions should be available for all staff and they should be briefed
and aware of their food safety responsibilities.

A training matrix and plans should be drawn up for all staff and the
relevant training given based on responsibility and authority.

We have provided a Staff Training Matrix Template in Microsoft Excel

Format.

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Project Plan

The Steering Group use the Excel Project Plan developed by Senior Management as a step by step guide to
implementing the Food Safety Management System.

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Step Six: Internal Auditing Training

Internal Auditor Training - An interactive and illustrated Internal Audit

training presentation to train your Internal Audit procedure.

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Stage Seven: Final Steps to BRCGS Certification

There a few final steps to achieving BRCGS Certification:

✓ Carry out a Senior Management Review

✓ Carry out an assessment of your system to make sure that it
meets the requirements of the BRCGS Global Standard for Food
Safety using our Checklist and a copy of the standard
✓ Ensure any areas requiring corrective action are addressed
✓ Choose your Certification Body
✓ Agree a Contract with a Certification Body
✓ On-Site Audit
✓ Audit & Corrective Action Review
✓ Certification & Issuing of the Audit Report
✓ Celebrate!
✓ Communicate your success!

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Our system is supplied with QM 1.2 Management Review Procedure

and QMR 001 Management Review Meeting Minutes which should be
used as a template.

Senior Management Review Meeting Notification

Date/Time

Venue

Agenda

1. Review of the Food Safety and Quality Policy

2. Review of the Food Safety and Quality Objectives*
3. Review of Management Changes
4. Minutes and Follow-up actions and timescales from previous
review meetings
5. Food Safety Culture performance review
6. Outstanding Non-conformances as a result of internal and
external audits
7. Results of external second and third-party audits
8. Trend analysis of Customer and Supplier complaints
9. Analysis of the results of verification activities including internal
audits, GMP and HACCP plan verification audits
10. Food Safety and Quality Key Performance Indicators Review and
trend analysis
11. Emergencies and Accidents
12. Process performance and product conformity
13. Corrective and preventive action status
14. Food Safety incidents including allergen control and labelling
non-conformances, recalls, withdrawals, safety or legal issues
15. Review of HACCP systems
16. Review of changes which could affect food safety and the Food
Safety HACCP Plan (including legislation changes and food
safety related scientific information)
17. Review of food defense measures
18. Review of ingredient and product authenticity
19. Communication activities and effectiveness of communication
20. Review of Resources and effectiveness of Training
21. Recommended improvements
22. Customer Feedback and Sales levels are reviewed to give an
indication of trends
23. A.O.B

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The senior management team implement actions to continually improve

the FSQMS

Senior Management should implement actions to improve the Food

Safety Management System. This will normally be as outputs from the
Management Review:

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Self-Assessment

A final assessment should be made by the most senior technical member of the management team to decide if the Site
Food Safety Management System in its current form meets the Requirements in Sections 1 to 9 of the BRCGS Standard.
The nominated manager should read through the requirements in Section 1 to 9 of the BRCGS Global Standard for Food
Safety and assess for compliance using the checklist below to record their findings.

BRCGS Global Standard for Food Safety F804a: Issue 9 Auditor Checklist and Site Self-Assessment Tool can be used for
this task and can be downloaded here: https://BRCGSglobalstandards.com/media/1055370/f804a-issue-8-checklist-
english.docx

Findings can be summarized below.

BRCGS Global Standard for Food Safety Issue 9 Gap Analysis

Relevant Documentation Requirements Compliant

Comments
Section 1 Senior Management Commitment Yes No
1.1 Senior management commitment and
continual improvement
1.2 Organizational structure, responsibilities
and management authority
Relevant Documentation Requirements Compliant
Comments
Section 2 The Food Safety Plan – HACCP Yes No

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Self-Assessment

An assessment should be made by the most senior technical member of the management team to decide if the Site Food
Safety Management System meets the Requirements of BRCGS Module 13 MEETING FSMA REQUIREMENTS FOR
FOOD

Findings can be summarized below.

FSMA Module Additional Requirements Yes No

117.20 Lighting handwashing areas

117.20(b)(3). Precautions taken to protect
food in installed outdoor bulk vessels
117.37 Water distribution system backflow or
cross-connection between piping systems
that discharge waste water or sewage
117.40 Food contact surfaces

117.80 Ice used in contact with food

117.80 Raw materials and other ingredients
inspected, segregated or otherwise handled
117.80 (c)(9) Food, raw materials, and other
ingredients that are adulterated must be
disposition requirements

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Ensure any areas requiring corrective action are addressed

The non-compliances identified in the assessment of compliance with the BRCGS Standard should be logged by
the Food Safety Team Leader and the appropriate corrective action allocated and taken:

Target
Details of Non- Identified Corrective Action Date
Date BRCGS Reference Responsibility completion
Conformance by: Required Completed
Date

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