We have completed the first four months of audits under BRC Issue 8 and have seen two areas that require some additional clarification.
Food safety and quality culture requirements were added to BRC Issue 8. The first step that each site must take regarding food safety and quality culture is to develop a plan to measure the culture. Once the baseline is established the site must then determine how the information will be used to drive continual improvement of the food safety and quality culture. These measured activities must cover all departments and employees of the facility that have an impact on food safety and quality not just management or not just operations. While developing activities it is important to keep in mind that the effectiveness of the activities must be measured to determine the overall effectiveness of the efforts to improve food safety and quality culture.
Another area that requires some clarification is in the section on Corrective and Preventive Actions. Issue 8 now requires a documented procedure for the completion of root cause analysis. The intent around this addition was to have sites identify one or several methods used to undertake root cause analysis, such as 5 Whys or Fishbone diagram, in their programs and then implement the use of the tools. One common issue observed during third party audits is poor root cause analysis and root causes that are not that actual cause of the problem or issue. Failure to complete an effective root cause analysis will not allow implementation of an effective preventive measure.