BRCGS position statements: one clause if you make food, eight if you store it

Something changed in your BRCGS audit this month and there was no new issue to tell you about it.

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On 26 May, BRCGS confirmed it had applied to the Global Food Safety Initiative for benchmarking against the 2024 Benchmarking Requirements, covering Food Safety Issue 9, Packaging Materials Issue 7, Storage and Distribution Issue 4, and Agents and Brokers Issue 3. Getting those four standards into line with the 2024 requirements meant amending them. Rather than issue new versions, BRCGS did it through position statements, which took effect for all audits conducted from 10 August after an eleven-week transition.

If you have been audited in the last fortnight, you were audited against these. If you have not, you will be.

What a position statement actually is

BRCGS defines it plainly enough. During the life of a published standard the Technical Advisory Committee may be asked to review the wording of a clause, or to interpret a requirement or a detail of the protocol. Its decision is a position statement. They are binding, and they are considered an extension of the Standard.

Binding, and an extension of the Standard. Not commentary, not guidance, not a blog post from your certification body. The clause number stays the same while the text or its interpretation moves underneath it, which is precisely why they get missed. There is no new issue, so nothing arrives in the post to prompt you, and the version of the standard on your shelf still reads the way it always did.

They also accumulate. Alongside the four documents amended this month sit standing statements that apply across every standard, covering unannounced audit protocol, blended audits using information and communications technology, and remote audits during extraordinary events, each with its own effective date. The full set lives on one page on the BRCGS site, and that page, rather than any newsletter, is the thing to check.

Food Safety Issue 9: one clause

If you make food, the entire change to your standard is clause 7.4.2.

Protective clothing must now explicitly include, where necessary, snoods for facial hair and suitable protective footwear. The interpretation puts particular weight on the footwear, confirming it must be issued and worn where required to prevent product contamination.

That is it. That is the whole Food Safety Issue 9 amendment.

Most of the coverage of this update has led on prerequisite programmes and risk analysis, which is a real change and a significant one, but it belongs to Agents and Brokers. If you have read a summary telling you to go and rework your hazard analysis because of an August deadline, the summary was describing a different standard.

Which does not make 7.4.2 trivial. Beard snoods and dedicated footwear are the kind of requirement that is either embedded in your site rules or it is not, and if it is not, it is visible to an auditor within ninety seconds of walking onto the floor. Check your policy says it, check your visitor and contractor rules say it, and check that what happens at the changing room actually matches both.

Storage and Distribution Issue 4: the real workload

Eight changes, and one of them is a new obligation rather than a clarification.

Section 17 now covers irradiation. The scope of contract processing operations previously ran to chilling, freezing, tempering, defrosting and high pressure processing. Irradiation has been added. Where it is carried out on pre-packaged product it must follow the product owner's specification and be monitored so that safety, legality and quality are not compromised. If you perform contract irradiation under this standard, you have picked up a requirement that did not exist in July.

Clause 17.3 broadens what you monitor. The old wording asked for temperature recording equipment. The new wording asks for adequate process parameters, naming real time temperature, pressure and irradiation, monitored through recording equipment linked to an automatic failure alarm, or through manual checks where appropriate. Sites running high pressure processing were arguably already caught by this in spirit. Now they are caught in text.

The rest tighten familiar ground. Clause 3.5.1.2 requires supplier specifications to carry relevant technical parameters, chemical, microbiological, physical or allergen, where applicable, and to be based on sound scientific principles and reviewed regularly. Clause 3.5.2.1 pushes the same rigour into subcontractor agreements, requiring product handling conditions and safety related parameters to be defined contractually so that outsourced work is controlled to the same level as work you do yourself. Clause 6.1 adds storage to the equipment requirement, so equipment must be suitable for purpose and stored so it does not become a contamination or pest harbourage risk, with movement between areas controlled. Clause 6.4.5 does the same for cleaning equipment: hygienically designed, clearly identified for its intended use, cleaned and stored hygienically. Colour coding is named in the interpretation as an example of identification.

Clauses 3.5.3.1 and 4.2.1 are competence requirements, which is the theme running underneath all of this.

Agents and Brokers Issue 3: the change everyone attributed elsewhere

Four changes, and clause 2.7.1 is the one worth your attention even if you are not certificated to this standard, because it tells you where the Global Food Safety Initiative is pushing.

Appropriate prerequisite programmes must now be in place before the risk analysis is conducted. Any existing control measures or monitoring within those programmes must be documented and taken into account when the plan is developed and reviewed. The interpretation states plainly that prerequisite programmes form the basis of the hazard and risk management system, and that while not everything needs formal validation, they should be effective and verified where appropriate.

The principle is that a risk analysis built in isolation from your foundational controls is not a risk analysis. Anyone who has watched a hazard analysis get written in a meeting room by someone working from a template will recognise why this needed saying.

Clause 3.6.1 defines what "key data" means in a product specification, naming chemical, microbiological, physical and allergen parameters, and requiring that anything used for food safety purposes rests on legislation or sound science. Clauses 4.3.1 and 4.8.2 are competence again.

Packaging Materials Issue 7: a brand new document

P708 did not exist before. Three changes.

Clause 4.4.1 requires that personnel engaged in threat assessments and product defence plans are appropriately trained in line with clause 6.1. BRCGS describes this as confirming an expectation that was already implicit, which is a polite way of saying it was being missed.

Clause 4.8.2 is the substantive one. Disinfection procedures must now be implemented and maintained alongside cleaning where appropriate, and cleaning procedures must be validated and verified against the risks associated with the intended use of the finished product. Cleaning activities must not themselves pose a risk to product safety.

Validated and verified are doing real work in that sentence. Validation is evidence the method achieves the standard. Verification is evidence it did so on the day. A visual check and a signature is verification of a sort and validation of nothing. If your cleaning procedures have never been validated, this is a piece of work, not a paperwork tweak.

Appendix 8 now defines disinfection, which it previously did not. It is defined as destroying pathogenic microorganisms and removing most organisms present on surfaces.

The thread: competence stopped being assumed

Four clauses across three standards now require named competence for threat assessment, product defence and vulnerability assessment work. Agents and Brokers 4.3.1 and 4.8.2, Storage and Distribution 3.5.3.1 and 4.2.1, Packaging Materials 4.4.1.

The intent is consistent and it is stated openly: these assessments should be meaningful rather than procedural, and carried out by people who understand the risks and the principles, not filled in because the system generates them annually.

BRCGS has been deliberately undogmatic about how you evidence it. Competence is not defined by a single route and may rest on training, experience, or the demonstrated effectiveness of the assessments themselves. A multi-disciplinary approach is encouraged, with technical, purchasing and supply chain all bringing something. Where internal expertise is thin, external specialists are explicitly acceptable.

Which is generous, and also means the burden of proof sits with you. There is no certificate that closes this out. If your food fraud vulnerability assessment is done by one person who inherited the spreadsheet, "competent" is going to be a difficult word to defend in an audit.

Two things worth noticing in the documents themselves

The Key Changes summary opens by saying amendments have been made across three position statements, then documents four. P708 is introduced separately further down as a new document, which is presumably the explanation, but the count in the opening line is wrong as written.

And the Agents and Brokers file is published as version 4 dated 27 April, with a filename that says 2025 while the document inside says 2026. The link on the position statements page carries the same wrong year. A transposition, not a substantive problem, but if you keep controlled copies it is worth renaming yours, so that nobody in eighteen months concludes you were working from something a year out of date.

The Monday morning list

1. Work out which of the four standards you actually hold. Most of the noise about this update is aimed at a standard you may not be certificated to.
2. If you are Food Safety Issue 9, read clause 7.4.2, then go and look at your changing room rather than your policy.
3. If you are Storage and Distribution and you carry out contract irradiation or high pressure processing, treat Section 17 and clause 17.3 as new requirements and check what you are recording against what the clause now names.
4. Pull the names of everyone who contributes to your threat assessment, product defence plan and vulnerability assessment. Write down what makes each of them competent. If you cannot, that is the finding, and you have found it before your auditor did.
5. For Packaging Materials, ask whether your cleaning procedures have ever been validated, as distinct from verified. If the answer is unclear, it is no.
6. Bookmark the BRCGS position statements page and check it on a schedule. It is the single place every statement appears, it carries the standing ones on unannounced and remote audits as well as these, and it is the only reliable way to notice the next set. They will arrive the same way: binding, effective on a date, and with no new issue to announce them.
7. File whatever you download with the standard, not next to it. A position statement stored separately from the clause it amends is a position statement nobody reads.