We quite often receive a question from the food or food packaging storage and distribution industry – especially from those considering certification to the BRC Global Storage and Distribution Standard. That question is “do we need a full blown HACCP Plan like those of our food customers?” The answer to that question partly lies in the BRC Global Storage and Distribution Standard itself, or within COMMISSION NOTICE 2016/C 278/01 on the implementation of food safety management systems covering prerequisite programs (PRPs) and procedures based on the HACCP principles, including the facilitation/flexibility of the implementation in certain food businesses. The principles in regard of a HACCP based food safety management system, within these two key documents is summarised below:
BRC Global Storage & Distribution Standard
Section 2 within this Standard really gives the game away in that the reader will note that it is not entitled “HACCP” but “Hazard and Risk Analysis”. This section requires that hazards are identified from all of the food handling and storage steps (goods intake, storage, picking, replenishment, goods marshalling, goods out, vehicle loading, transport etc), that hazard likelihood and severity is assessed and control measures considered and implemented. Where this standard diverges a little from the BRC Global Food Safety Standard (for processors) is the simplicity with which the BRC Global Storage and Distribution standard then considers the identification and management of CCP’s and, before this CCP clause (clause 2.11) actually specifies that control may be by prerequisite control and documentation alone (clause 2.10). In so doing, the BRC Global Storage and Distribution Standard nods an acknowledgement to Commission Notice 2016/C278/01, the purpose of which is to describe permitted flexibility in the HACCP based food safety management procedures for some businesses.
Commission Notice 2016/C278/01
This notice, within section 2 (Purpose) states that one of the purposes of the Notice is to provide practical guidance on the flexibility provided for certain food establishments by EU legislation related to the implementation of PRPs and HACCP-based procedures (Annex III of the Notice). Whilst mainly being directed at competent authorities for food business inspection, it also provides invaluable guidance to food businesses for which flexibility may be required (and this includes FBO’s engaged purely in storage and distribution, retail, very small food manufacturers etc). For instance section 4.2 of Annex III of the Commission Notice states “Recital 15 of Regulation (EC) No 852/2004 clearly recognises that not in all cases CCPs might be identified. In such
cases the application of procedures based on the HACCP principles is limited to the first principle i.e. a hazard analysis required to justify in a risk-based manner why no CCP needs to be considered and to demonstrate that PRPs are sufficient to control the hazards.” By the way Appendix 2 of the Notice also illustrates a simply way to assess hazard risk, based on the use of a logic table (probability versus severity) and gives very good guidance on identifying and managing PRP (prerequisite programmes) and oPRP (operational prerequisite programmes). oPRP is the subject of a forthcoming post. Watch this space!
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