BRC Voluntary Modules
A. BRC-FSMA Readiness Module
Background: BRC has created the FSMA Readiness Module (AVM 15 for Food 7) based on most up to date interpretations of the preventative controls rule for human food, the actual regulation and wherever possible, guidance produced by the FDA. The module represents those prescriptive elements identified as not exactly matching the requirements (or being more prescriptive) than BRC Food 7. The intent of the module is to provide sites the opportunity for an independent, qualified individual to assess suitability and evidence supporting programs designed to meet preventative controls. Additionally, it provides a documented, traceable evidence set to importers of record – who are ultimately liable for compliance verification.
Module Timing, NC Impact and Regulatory Compliance: The FDA has established a schedule for implementation based on several factors, this schedule is available via the FDA website. Note that some importers of record, or customers may require evidence of compliance prior to, after, ongoing or regardless of potential exemptions. Once a site is under mandatory compliance based on FDA guidelines, any non-conformities will be additionally identified in the main audit report, and scored accordingly. The site may continue to use the module as auditor and audit guidance, and as evidence for importers of record.
Reporting of Results: Auditor will use the document, VM006 to record positive evidence, and non-conformities. This report, on completion will be uploaded as a pdf to the BRC Directory.
Closing of Nonconformities: it is expected that the sites close non-conformities identified within the typical 28-day period. When non-conformities are closed, the FSMA module may be identified as having been successfully completed on the main audit report.
Certificate: A certificate of completion may be issued by the certification body where non-conformities have been successfully closed. If site choses to leave non-conformities open (and they are not under regulatory compliance timelines) the report may be uploaded to the BRC Directory. If non-conformities are not closed, no certificate may be issued, nor can the module be identified on the main audit report.
Alternate uses of the module:
- The module is not to be used by auditors or certification bodies outside of the BRC audit, and the results must be uploaded to the BRC Directory.
- The module may not be used with other non-BRC Food 7 audits, in its current, or altered format.
- The module may be used along with a BRC Food 7 pre-assessment, providing the results of both the audit, and AVM are uploaded to the Directory.
- Module use outside of recertification audit: If a site currently certified to the BRC Global Standard for Food 7 wishes to incorporate the FSMA AVM into their existing certification, they may request the certification body perform the AVM audit separately.
- Exemptions from FSMA Preventative Controls: based on the site size, sales, product type or other measure some facilities may be partially or wholly exempt under FDA requirements. It is entirely up to the site, importer of record, customer and FDA to validate and accept such determination. BRC Global Standards makes the module available for use by sites and specifiers.
B. Food Safety Culture Module
Background: Many organizations are beginning to realize that despite investment in food safety training, system implementation and auditing, something is still missing. This ‘something’ is the assessment of their food safety culture, which until now has been very difficult to measure. BRC has developed an assessment of food safety culture, which demonstrates:
- the role company culture plays in creating an effective and responsive food safety and manufacturing environment
- the link between culture and audit success.
Demand for the BRC Global Standards Food Safety Culture Module was driven by retailers and manufacturers. Exclusively available for BRC Global Standards certificated sites, the Food Safety Culture Module is an assessment offered as an addition to the annual food safety audit, and provides manufacturers with insight into the culture of their organization.
- Determines strengths and weaknesses in food safety capability
- Provides real insight into staff opinion, attitude, and behavior
- Provides multi-site businesses with a benchmarking tool to compare sites to each other
- Reveals the ‘unseen’ culture that goes beyond the day of audit
- Complements the existing audit program with a behavior-based approach
- Strengthens your company reputation through a proactive approach to food safety culture
- Offers significant return for a low cost and hassle-free module added to annual audit
- Measures the impact of training, systems, and other initiatives
- Evaluates return on investment of budget and identifies the most important targets for resource allocation
- Develops supply chain awareness and supports site-specifier partnerships built on increased confidence
- Adds value to BRC food safety certification as a product exclusive to BRC Global Standards
Results of Assessment: An Assessment Report is provided with the site’s overall score, grades and a basic explanation of what these mean.
Frequency of Assessment: Once a year, alongside the annual BRC Global Standards audit.