BRCGS for Food Safety Issue 9 Changes – Part 9: Requirements for Traded Products (R9)

In Part 9 of the BRCGS Issue 9 series, we discuss the major changes under Requirement 9 (Requirements for Traded Products).

The Requirements for Traded Products consist of 6 clauses (sections).

There are no fundamental requirements under the requirements for traded products.

A complete list of the clauses under Requirement 9 (Requirements for Traded Products). The clauses marked with * are discussed in this article:

9.1 The food safety plan – HACCP*

9.2 Approval and performance monitoring of manufacturers/packers of traded food
products

9.3 Specifications

9.4 Product inspection and laboratory testing

9.5 Product legality

9.6 Traceability*

9.1 The Food Safety Plan – HACCP

Clause 9.1 – Food safety / HACCP plan for traded products

Clause 9.1 is a new requirement where the site is now required to have the Food Safety plan or HACCP plan for traded goods, which could either be a separate document or incorporated into the existing HACCP study or HACCP plan as per Requirement 2.

The scope of trade products’ HACCP for food safety plan shall include the products and the processes for which the site is responsible.

At a minimum, this shall include receipt, storage and dispatch.

9.6 Traceability

Clause 9.6.1 – Traceability requirements for traded products

Clause 9.6 deals with traceability.

The changes are under Clause 9.6.1. The first change relates to the site ensuring that its traceability procedure includes details of the system used for the transferability of traded products. The site can make reference to the traceability of traded products as per Clause 3.9.1.

The second change is to the second paragraph of the requirement under Clause 9.6.1. It now reads as follows:

“The traceability system shall ensure that, for all batches of product, the site can identify the last manufacturer or, in the case of primary agricultural products, the packer or place of last significant change to the product.”

Key facts

  • Requirement 9 (Requirements for Traded Products) in BRCGS for Food Safety Issue 9 contains six clauses, with no fundamental requirements designated.
  • New clause 9.1 requires sites to hold a food safety or HACCP plan for traded goods, either as a separate document or within the existing HACCP study, covering at least receipt, storage and dispatch.
  • Clause 9.6.1 was updated so traceability procedures must detail the system for transferring traded products, with reference permitted to Clause 3.9.1.
  • The traceability system must ensure that, for all batches of product, the site can identify the last manufacturer, or for primary agricultural products the packer or place of last significant change.
  • The article is Part 9 of ASC Food Safety Consultants' series explaining the BRCGS for Food Safety Issue 9 changes.

Frequently asked questions

What is Requirement 9 in BRCGS for Food Safety Issue 9?

Requirement 9 covers Requirements for Traded Products under the BRC Global Standard for Food Safety Issue 9. It is made up of six clauses and has no fundamental requirements designated. The article highlights two clauses in particular, 9.1 and 9.6, which carry changes under Issue 9.

What does the new clause 9.1 require for traded products?

Clause 9.1 is a new requirement that sites maintain a food safety or HACCP plan specifically for traded goods. This can be a separate document or integrated into the existing HACCP study. As a minimum the plan must cover receipt, storage and dispatch, along with the products and processes under the site's responsibility.

How did the traceability requirement (clause 9.6.1) change under Issue 9?

Clause 9.6.1 introduced two changes. Sites must now detail the system used for transferring traded products, and reference to Clause 3.9.1 is permitted. The updated standard also requires that, for all batches of product, the traceability system lets the site identify the last manufacturer, or for primary agricultural products the packer or place of last significant change to the product.

How many clauses are in the traded products requirement, and are any fundamental?

The Requirements for Traded Products section (Requirement 9) contains six clauses, numbered 9.1 through 9.6. According to the article, none of these clauses are designated as fundamental requirements. The changes discussed focus on clauses 9.1 and 9.6.1.

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