In Part 7 of the BRCGS Issue 9 series, we discuss the major changes under Requirement 7 (Personnel).
The Personnel requirement consists of 4 clauses (sections) and has 1 fundamental requirement.
The following clause is a fundamental requirement:
7.1 Training: raw material-handling, preparation, processing, packing and storage areas
A complete list of the clauses under Requirement 7 (Personnel). The clauses marked with * are discussed in this article:
7.1 Training: raw material handling, preparation, processing, packing and storage areas*
7.2 Personal hygiene: raw material handling, preparation, processing, packing and
storage areas*
7.3 Medical screening*
7.4 Protective clothing: staff or visitors to production areas*
7.1 Training: Raw Material Handling, Preparation, Processing, Packing and Storage Areas
Clause 7.1.1 – The training of ALL personnel
Clause 7.1.1 now requires that ALL personnel be trained and adequately supervised throughout the working period. The requirement now reads as follows:
“All personnel, including agency-supplied staff, temporary staff and contractors shall be appropriately trained prior to commencing work and adequately supervised throughout their working period.”
Clause 7.1.2 – Training relating to CONTROL MEASURES
Clause 7.1.2 requires that employees involved and engaged in activities relating to CCP’s and CONTROL MEASURES (new addition) should receive relevant training and their competency assessment shall also be in place.
Clause 7.1.4 – Allergen awareness and allergen procedures training of ALL personnel
Clause 7.1.4 now requires that ALL staff must receive training in allergen awareness, as well as training in the site’s allergen handling procedures.
This includes engineers, agency-supplied staff, temporary staff and contractors.
Previously it was only required to train “relevant” staff.
7.2 Personal Hygiene: Raw Material Handling, Preparation, Processing, Packing and Storage Areas.
Clause 7.2.1 – Personal hygiene practices – wearing of jewellery
The only change in Clause 7.2 is under Clause 7.2.1.
There are additional requirements under personal hygiene practices.
The first change is the requirement that wearable devices similar to watches shall not be worn.
The second change is the requirement that personnel is only permitted to wear a single, plain wedding ring, wedding wristband, or medical alert jewellery.
7.3 Medical Screening
Clause 7.3 – Medical screening – transmission of infections, diseases or other conditions
Clause 7.3 covers medical screening.
There are changes to the statement of intent and it now reads as follows:
“The company shall have procedures in place to ensure that staff, agency staff, contractors or visitors are not a source of transmission of infections, diseases (including food-borne diseases) or conditions to products.”
Clause 7.3.1 – Contractors and visitors to be included in the medical screening procedure
Under Clause 7.3.1, the term ‘employees’ changed to ‘STAFF’.
There is also an addition where contractors and visitors to the site must be included as part of the procedure which enables them to notify the site if they show any relevant symptoms, infection, disease, or condition which they may have been in contact with or may be suffering from.
Clause 7.3.3 – Addition of “temporary staff” to the clause
Under Clause 7.3.3 the term “employees” has been changed to “STAFF”.
Temporary staff has been added as part of the list. The clause now reads as follows:
“There shall be procedures for staff (including temporary employees), contractors and visitors relating to action to be taken where they may be suffering from or have been in contact with an infectious disease.”
7.4 Protective Clothing: Staff or Visitors to Production Areas
Clause 7.4.3 – Washing of protective clothing by the employee
Clause 7.4.3 provides better clarification when employees are allowed to wash their own PPE.
The first condition is that the PPE is not used for product safety purposes. For example, PPE used for health and safety purposes (to protect the employee).
AND
The second condition is the PPE is worn in enclosed product or low-risk areas only.
Clause 7.4.5 – Use of gloves
There are slight changes under Clause 7.4.5 where there is an addition of the term ‘shall’ and ‘and’ in the following requirement.
“If gloves are used, they shall be replaced regularly. Where appropriate, gloves shall be suitable for food use, of a disposable type, of a distinctive colour (blue where possible) and intact; and shall not shed loose fibers.”
Clause 7.4.6 – Disinfection of protective clothing unsuitable for laundering
Clause 7.4.6 now requires that protective clothing which is not suitable for laundering shall be cleaned and disinfected (new addition) at a frequency based on risk.
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Key facts
- Requirement 7 (Personnel) has four clauses, with 7.1 Training remaining a fundamental requirement covering raw material handling, preparation, processing, packing and storage areas.
- Clause 7.1.1 now requires ALL personnel, including agency-supplied staff, temporary staff and contractors, to be appropriately trained before starting work and adequately supervised, and 7.1.2 extends training to those engaged with control measures.
- Clause 7.1.4 expands allergen awareness training from 'relevant' staff to ALL staff, including engineers, contractors and temporary workers.
- Clause 7.2.1 tightens personal hygiene rules, prohibiting wearable devices similar to watches and permitting only a single plain wedding ring, wedding wristband or medical alert jewellery.
- Medical screening (7.3) is broadened to include contractors and visitors, and 7.3.3 explicitly adds temporary staff to infectious disease notification procedures.
- Protective clothing rules (7.4) are clarified, with 7.4.6 requiring non-launderable clothing to be cleaned and disinfected at a risk-based frequency.
Frequently asked questions
What changed for personnel (Requirement 7) in BRCGS Issue 9?
BRCGS Issue 9 broadens who must be trained and screened under Requirement 7. Clause 7.1.1 now covers all personnel, including agency-supplied staff, temporary staff and contractors, while training is extended to those engaged with control measures. The changes also tighten personal hygiene, medical screening and protective clothing rules across the four clauses in Requirement 7.
Who must receive allergen awareness training under BRCGS Issue 9?
Under clause 7.1.4, ALL staff must now receive allergen awareness training and training in the site's allergen handling procedures. This is an expansion from the previous requirement that only covered 'relevant' staff, and it explicitly includes engineers, agency-supplied staff, temporary staff and contractors.
What are the new jewellery and wearable device rules in BRCGS Issue 9?
Clause 7.2.1 now prohibits wearable devices similar to watches. Personnel may only wear a single plain wedding ring, wedding wristband, or medical alert jewellery. This tightens the personal hygiene requirements for raw material handling, preparation, processing, packing and storage areas.
Does BRCGS Issue 9 medical screening now cover visitors and contractors?
Yes. Clause 7.3.1 expands the scope of medical screening to include contractors and visitors, not just employees. The statement of intent is broadened to address infections, diseases (including food-borne diseases) and conditions, and clause 7.3.3 explicitly adds temporary staff to the procedures for notifying infectious disease.
How did the protective clothing requirements change in BRCGS Issue 9?
Clause 7.4.3 clarifies that personal PPE may only be washed at home when it serves a non-product-safety purpose and is worn in enclosed or low-risk areas. Clause 7.4.5 adds grammatical precision to the glove specifications, and clause 7.4.6 now requires protective clothing that cannot be laundered to be cleaned and disinfected at a risk-based frequency.
Is 7.1 Training still a fundamental requirement in BRCGS Issue 9?
Yes. Requirement 7 (Personnel) consists of four clauses, and 7.1 Training remains the single fundamental requirement within it. It covers training for raw material handling, preparation, processing, packing and storage areas.