In Part 4 of the BRCGS Issue 9 series, we discuss the major changes under Requirement 4 (Site Standards).
The Site Standards requirement consists of 16 clauses (sections) and has 2 fundamental requirements.
The following clauses are fundamental requirements:
4.3 Layout, product flow and segregation
4.11 Housekeeping and hygiene
A complete list of the clauses under Requirement 4 (Site Standards). The clauses marked with * are discussed in this article:
4.1 External standards and site security*
4.2 Food defence*
4.3 Layout, product flow and segregation*
4.4 Building fabric, raw material handling, preparation, processing, packing and storage areas*
4.5 Utilities – water, ice, air and other gases*
4.6 Equipment*
4.7 Maintenance
4.8 Staff facilities
4.9 Chemical and physical product contamination control*
4.10 Foreign-body detection and removal equipment*
4.11 Housekeeping and hygiene*
4.12 Waste and waste disposal*
4.13 Management of surplus food and products for animal feed*
4.14 Pest management*
4.15 Storage facilities
4.16 Dispatch and transport*
Clause 4.1 – External Standards and Site Security
Clause 4.1.4 – External standards and site security
Clause 4.1 deals with external standards and site security.
The major revision is under Clause 4.1.4 where policies and systems shall be in place to ensure that access to the site by staff, contractors and visitors is controlled.
Contractors and visitors, including drivers, shall be made aware of the procedures for access to the site.
Only authorised personnel shall have access to the production and storage areas, and staff shall be trained in site security procedures.
Clause 4.2 – Food Defence
Clause 4.2 – Emphasis is placed on Food Defence
Under Clause 4.2 in Issue 9, “site security” is now called “FOOD DEFENCE”.
The emphasis is on:
- Complying with the country of sale or intended use’s Food Defence requirements
- Training of staff in Food Defence procedures
The Food Defence team must be adequately informed about all Food Defence risks. The team should have knowledge about the site and Food Defence principles.
Clause 4.3 – Layout, Product Flow and Segregation
Clause 4.3 – Layout, Product Flow and Segregation
Under Clause 4.3, production risk zones shall be included in the site layout diagram.
Clause 4.4. – Building Fabric, Raw Material Handling, Preparation, Processing, Packaging and Storage Areas
Clause 4.4.6 – Access steps and mezzanine floors
There is an addition for requirements of access steps and mezzanine floors under Clause 4.4.6.
Clause 4.4.11 – Maintenance and cleaning of strip curtains
Clause 4.4.11 is a new clause dedicated to the maintenance and cleaning of strip curtains.
Clause 4.5 – Utilities – Water, Ice, Air and Other Gases
Clause 4.5.1 – Management of water stored on site
Clause 4.5.1 requires that water stored on site shall be managed to prevent food safety risks.
Clause 4.5.2 – The water source as part of the water distribution schematic diagram
Clause 4.5.2 requires that the water source be included as part of the water distribution schematic diagram.
Clause 4.6 – Equipment
Clause 4.6 – Requirements for equipment
This clause has been completely revised and now refers to “production and product handling” equipment. Here is a summary of some of the requirements:
- Purchase specifications
- Authorisation
- Suitability of the equipment (design, location, easy to clean, etc.)
- Maintaining food safety and integrity during installation and operation
- Inspections prior to operation
- Storage of equipment not in operation or out of service
- Mobile equipment
- Battery charging equipment
- Etc.
Clause 4.9 – Chemical and Physical Product Contamination Control
Clause 4.9.1.1 – Chemical control
Clause 4.9.1 has a change under Clause 4.9.1.1 where it requires that procedures to manage any spills and procedures for the safe, legal disposal or return of obsolete or out-of-date chemicals, and empty chemical containers must be in place.
There is also clarification that chemicals used for raw materials must be stored away from other chemicals.
Clause 4.9.6.2 – The control of portable handheld items
In Clause 4.9.6, there is a change under Clause 4.9.6.2 where it is a requirement to control the use of portable handheld items such as pens, pencils, phones, etc. in open product areas to minimize the risk of contamination.
Clause 4.9.6.3 – Control of other types of foreign materials
Clause 4.9.6.3 requires procedures (based on risk) for the control of other types of foreign materials not explicitly addressed by the standard.
Clause 4.10 – Foreign Body Detection and Removal Equipment
Clause 4.10.3.5 – X-ray equipment testing procedures and the use of test pieces
Under Clause 4.10.3 (metal detectors and x-ray equipment), Clause 4.10.3.5 is specifically dedicated to X-ray equipment testing procedures, including how the test pieces should be used.
Clause 4.10.7 – Other foreign-body detection and removal equipment
Clause 4.10.7 is completely new and focuses on the need to ensure that checks on other foreign-body detection and removal equipment are documented.
Clause 4.11 – Housekeeping and Hygiene
Clause 4.11.2 – Addition of disinfection and records for completion and sign-off
Clause 4.11.2 now refers to documented cleaning and disinfection procedures. “Disinfection” has been added.
Cleaning records should now also include records for completion and sign-off.
Clause 4.11.8 – Relevant pathogens and spoilage organisms
Under Clause 4.11.8 the word “relevant” was added when referring to pathogens and spoilage organisms.
Clause 4.12 – Waste and Waste Disposal
Clause 4.12.3 – Relevant pathogens and spoilage organisms
Waste removal from open product areas:
Clause 4.12.3 (new) requires the following:
“Waste removal from open product areas shall be managed to ensure that it does not compromise product safety.”
Clause 4.13 – Management of Surplus Food and Products for Animal Feed
Clause 4.13.2 – Products given to staff and charities
Clause 4.13.2 requires that products that are given to staff, or charity must maintain traceability and be safe for human consumption.
Clause 4.14 – Pest Management
Clause 4.14.10 – Change of wording from “survey” to “assessment”
Under Clause 4.14.10, the word “survey” is replaced by “assessment”.
Clause 4.16 – Dispatch and Transport
Clause 4.16.6 – Approval of contractors
No major changes except in Clause 4.16.6 where the approval of contractors can be based on two things:
- A valid certification to the applicable BRCGS Standard (e.g., Global Standard for Storage and Distribution), or GFSI-benchmarked standard, or
- a completed contract or terms and conditions.
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Key facts
- Requirement 4 (Site Standards) of BRCGS Issue 9 contains 16 clauses, two of which are fundamental requirements: clause 4.3 (layout, product flow and segregation) and clause 4.11 (housekeeping and hygiene).
- Site security now uses 'food defence' terminology, requiring staff training and contractor awareness of access control policies, and production risk zones must appear on site layout diagrams.
- Equipment standards were fully revised to cover purchase specifications, installation inspections and mobile equipment storage, while chemical management now requires spill procedures and control of portable handheld items like pens and phones in open product areas.
- Cleaning procedures now include 'disinfection' and require records with completion and sign-off, and a new clause 4.10.7 addresses documenting checks of other foreign-body detection equipment.
- Pest management wording changed from 'survey' to 'assessment' (clause 4.14), and contractor approval (clause 4.16) may be based on valid GFSI-benchmarked certification or completed contract terms.
Frequently asked questions
What is Requirement 4 in the BRCGS Issue 9 Standard?
Requirement 4 is the Site Standards section of the BRC Global Standard for Food Safety Issue 9. It comprises 16 clauses in total and includes two fundamental requirements: clause 4.3 (layout, product flow and segregation) and clause 4.11 (housekeeping and hygiene).
What changed around site security in BRCGS Issue 9?
Site security procedures now emphasise 'food defence' terminology under clauses 4.1 and 4.2. The updated requirements call for staff training and for contractors to be aware of access control policies.
How did equipment and chemical requirements change in Issue 9?
Equipment standards (clause 4.6) were completely revised to cover purchase specifications, installation inspections and mobile equipment storage. Chemical management (clause 4.9) now requires spill procedures and proper disposal protocols, and portable handheld items such as pens and phones must be controlled in open product areas.
What are the cleaning and foreign-body detection updates in BRCGS Issue 9?
Clause 4.11 adds 'disinfection' to cleaning procedures and requires cleaning records to include completion and sign-off documentation. Clause 4.10 formalises X-ray equipment testing procedures, and a new clause 4.10.7 addresses documenting checks of other foreign-body detection equipment.
How did the pest management and contractor requirements change?
For pest management, clause 4.14 replaces the term 'survey' with 'assessment'. For contractors, clause 4.16 allows approval based on valid GFSI-benchmarked certification or on completed contract terms.