This podcast episode addresses frequently asked questions about the BRCGS Food version 9 standard, released in August 2022. Marife Montes discusses common uncertainties and interpretations of the standard's requirements, focusing on key chapters and providing practical advice for implementation.
Here's an outline structure you could use to develop your podcast, based on the provided transcript:
I. Introduction (0:00-1:39)
II. Chapter 1: Commitment of Top Management (1:39-7:55)
III. Chapter 2: Hazard Analysis and Critical Control Points (HACCP) (7:55-13:21)
IV. Chapter 3: Quality and Food Safety Management Systems (13:21-18:02)
V. Chapter 3: Root Cause Analysis (18:02-22:45)
VI. Chapter 3: Traceability (22:45-25:26)
VII. Chapter 4: Premises and Equipment (25:26-31:34)
VIII. Chapter 4: Management of Food Surplus (31:34-32:11)
IX. Chapter 4: Pest Control (32:11-33:13)
X. Chapter 5: Product Control: Allergens & Fraud (33:13-34:22)
XI. Chapter 6: Process Control: Calibration & Protective Clothing (34:22-41:26)
XII. Conclusion (41:26-41:45)
This outline helps break down the podcast into manageable sections, making it easier to create a coherent and engaging episode. Remember to use transitions between sections for smoother flow.
Let's develop each point of the podcast outline, drawing heavily from the provided transcript's content and style:
I. Introduction (0:00-1:39)
(0:00-0:07) Opening with Applause and Hook: "[Applause] Every time a new version of any standard is published, doubts and uncertainties arise. Different opinions emerge on how to interpret the requirements..." This immediately establishes the common problem the podcast solves.
(0:07-0:32) Problem Statement: Continue by elaborating on the confusion surrounding BRCGS Food version 9, highlighting the differing interpretations and challenges in implementation. Mention the release date (August 2022) and the audit commencement (January 2023). "…a difference of opinions on how we’re going to interpret the requirements of this new version of the standard… doubts on how to face these changes and how to implement them."
(0:32-1:00) Podcast Value Proposition: Introduce yourself as Marife Montes and clearly state the episode's purpose – to answer frequently asked questions about BRCGS Food version 9. "…a compilation of doubts and queries that you’ve been asking me repeatedly regarding the requirements of the BRC Food standard, version 9… In this episode, I intend to resolve these doubts for you. So let’s get to it! Hello! How are you? I'm Marife Montes, and I'm here again with you in a new episode of my podcast..."
(1:00-1:18) Channel Promotion: Briefly mention the podcast's regular schedule and its focus on food safety. Include a clear call to action, directing listeners to your website, MarifeMontes.com, for subscriptions and show notes. "...where every week, punctually, we’re talking about tools, tricks, tips and much more to get the most out of your food safety management system. I invite you to visit my website, MarifeMontes.com, where you’ll be able to subscribe to listen to each episode punctually, and where you’ll also be able to download the notes for each episode..."
(1:18-1:39) Episode-Specific Promotion: Reiterate that the show notes for this specific episode are also available for download on MarifeMontes.com. Conclude the introduction by stating you'll cover frequently asked questions across different chapters of the standard. "...and of course, these notes from today’s episode you’ll also be able to download at MarifeMontes.com. So, let’s begin with this new episode…a journey through the entire standard, in this case, the BRC Food standard, version 9…we're going to be looking at the most frequent doubts we have in some of these requirements…"
II. Chapter 1: Commitment of Top Management (1:39-7:55)
(1:39-2:05) Setting the Stage: Begin by explicitly mentioning Chapter 1 and the recurring question about the cultural plan and the qualifications of the management team.
(2:05-2:52) Addressing the Qualification Question: Clearly state that the standard doesn't dictate specific training requirements. Emphasize that the focus is on demonstrable competency. "...there’s a fairly recurring question they ask me regarding the development of the cultural plan...they ask, what would be the qualification, or what would be the necessary competencies that management should have in order to meet the requirement regarding measurement, monitoring, or changes that are required in the cultural plan. The standard doesn’t establish any specific training requirement regarding the people who lead...in this case, it would be management leading the strategic plan to implement this culture. It’s true that, since the standard doesn’t require it, there isn’t any specific course that can provide those competencies..."
(2:52-4:08) Competency Discussion: Explain that food safety culture is a transversal strategy needing leadership competencies relevant to strategic planning, communication, data analysis, and overall organizational management. "...food safety culture is a strategy that has to be implemented transversally throughout the organization of your company...the competencies that the person who leads this cultural plan must have are logically competencies based on the strategic plans themselves…" Transition into the second question about management responsibility.
(4:08-5:30) Addressing Management Responsibility: Clearly state that while top management leads, the responsibility for maintaining food safety culture falls on everyone in the company. Emphasize the importance of a company-wide commitment. "...is it the manager’s responsibility to maintain the culture? Logically, we’ve said that there will always be a figure from upper management, the person who is going to lead this strategic project of implementing the culture. But of course, they are not the only responsible party; they are responsible for leadership, but the responsibility will fall on all members of the company because culture…we’ve said in previous episodes of this podcast, and I talk about it a lot in all my food safety impulses, that logically the most responsible person will direct, design, promote, and launch this entire strategic plan, but if it isn’t with the responsibility of all the members who make up the company, it wouldn’t be possible to obtain continuous improvement in our company derived from a firm culture in food safety…”
(5:30-7:55) Auditor Expectations: Explain what auditors look for in relation to cultural implementation— evidence spread across multiple sources rather than a single document. "What does the auditor expect? What is the auditor looking for to be able to demonstrate that we have a culture implemented? Because as such, it’s true that it sounds a little ambiguous, and what the auditor is going to look for is the representation or the implementation of this requirement; it’s not going to be reflected in a single document or a work format as happens in other records or other requirements that we have in the standard… we can see it reflected in all the other requirements of implementing the standard…we’re going to see it through the interviews we have with both management and department heads…”
III. Chapter 2: Hazard Analysis and Critical Control Points (HACCP) (7:55-13:21)
(7:55-8:22) Introduction to Chapter 2: Begin by introducing Chapter 2 (HACCP) and highlighting that this chapter has seen the least modification.
(8:22-9:13) Key Change: Validation: Clearly explain the key change—the requirement for prior validation of the HACCP plan. Connect this to the Codex Alimentarius. "...the clause 2.1.1, where it talks about validation, is perhaps the most significant change we’ve had from previous versions. This change is reflected…motivated by the change we also had in the Codex Alimentarius…it asks that, of course, our APPCC plan is previously validated before its implementation…"
(9:13-10:39) Validation Steps: Detail the steps involved in validation, referencing the guidance provided in the BRCGS standard and the Codex Alimentarius. Emphasize that this ensures the effectiveness of preventive measures. "...the BRC standard establishes quite a few points…aspects previous to the implementation…it’s helping us understand the validation of the entire APPCC plan…previously, you must verify your flow chart…review all the hazard analysis…identification of critical control points…establish activities for monitoring and verification…review that all the critical limits and all the corrective actions that are implemented…"
(10:39-11:57) Subcontracted Processes: Address the frequently asked question about incorporating subcontracted processes into the HACCP plan. Clearly answer affirmatively and explain why. "...one of the doubts that arises is whether or not we have to integrate the process that we have outsourced into our APPCC plan…if we are carrying out outsourced activities with a third party, of course, all the hazards that could originate in this process that we are outsourcing…have to evaluate all the hazards that could appear…"
(11:57-13:21) Supplier Services: Answer the question regarding the inclusion of supplier services in the HACCP plan. "…we’re also asked many times if we also have to include, in our APPCC plan, the hazards related to service providers…we must include all those hazards that may be generated when contracting services…" Provide examples of services to be considered.
IV. Chapter 3: Quality and Food Safety Management Systems (13:21-18:02)
(13:21-14:02) Introduction to Chapter 3: Start by transitioning to Chapter 3 and introducing the recurring questions about supplier management.
(14:02-14:28) Intermediaries and Manufacturer Identity: Address the question regarding knowing the identity of the final manufacturer when buying through intermediaries. "...I’m often asked, ‘Do I have to know if I’m buying a raw material through an agent or an intermediary…do I have to know the identity of the ultimate manufacturer of that raw material?’ Yes, we have to know what the identity of the last manufacturer or the last handler, packer, or processor of that raw material is…"
(14:28-15:16) Certification Impact: Explain how the need to trace back to the final manufacturer is affected by whether the intermediary is certified to a relevant standard (e.g., BRC broker). "...we can differentiate in two aspects; one is as a function of the type of agent we are contracting…if this intermediary is already certified…we simply…we have to be clear about what the last manufacturer is, but we already trust that our intermediary is ensuring compliance with all the requirements with respect to this manufacturer. What happens if our agent or intermediary is not certified?"
(15:16-17:08) Non-Certified Intermediaries: Explain the actions needed if the intermediary is not certified. Explain the need for more stringent traceability measures. "...we have to take a step back and be able to ensure that we comply with all the traceability requirements…our intention is not to bypass the agent or intermediary, but it’s true that the standard obliges us…to provide that last processor, manufacturer, packer…all the information related to the product it is supplying us…"
(17:08-18:02) Complex Traceability: Discuss situations where intermediaries blend or mix products from multiple sources, emphasizing the need to obtain thorough traceability information from the broker. "...sometimes these intermediaries are compiling products…imagine that we are buying a product in bulk, it could be wheat…this broker is collecting all the wheat from its suppliers…it's making important traceability mixtures…"
V. Chapter 3: Root Cause Analysis (18:02-22:45)
(18:02-18:15) Introduction to Root Cause Analysis: Transition to the topic of root cause analysis, highlighting the frequency of questions related to this requirement (clause 3.7).
(18:15-20:56) Mandatory vs. Recommended: Clearly state the situations where root cause analysis is mandatory and the situations where it is highly suggested. Emphasize the preventative aspect. "…a requirement that we find in clause 3.7, where the standard asks that we do a root cause analysis when problems arise…demonstrate that our corrective and preventive actions correctly identify the problem to avoid its recurrence…we see that when non-conformities occur and we have to apply corrective and preventive actions, then this goes through an intermediate step, which is to analyze the cause…"
(20:56-22:45) Implementing Root Cause Analysis: Offer practical advice and suggest prioritizing root cause analysis for all non-conformities to improve efficiency. "...if we are advancing in our requirements…first, it’s asking us to have a procedure to manage and correct all the problems; this procedure must already include the root cause…do I always have to do a root cause analysis? Yes, of course…we have to have our procedure to evaluate what has happened, through a root cause analysis tool…"
VI. Chapter 3: Traceability (22:45-25:26)
(22:45-23:32) Introduction to Traceability: Transition to the discussion on traceability (clause 3.9.3), highlighting its clarity despite some recurring questions.
(23:32-24:20) Scope of Traceability: Clearly define what must be included in traceability exercises, emphasizing the all-encompassing nature of the requirement. "...for all food raw materials and finished products, and it also includes in parenthesis those that are printed packaging or labels that have legal information…we have to do traceability tests, including the verification of that mass balance…"
(24:20-25:26) Exclusions and Clarifications: Explain which items are specifically excluded from traceability requirements (e.g., blank labels, unmarked packaging). "...if we’re talking about labels that don’t have legal information…but if we’re talking about labels or stickers that we use to print labels…that are on the box…we don’t have to keep any traceability on that type of blank label…"
VII. Chapter 4: Premises and Equipment (25:26-31:34)
(25:26-25:37) Introduction to Chapter 4: Transition to Chapter 4, focusing on the food defense plan and required competencies.
(25:37-26:20) Food Defense Competencies: Explain that while competency is required, the standard doesn't specify training hours or methods. The auditor will assess this during the audit. "...there’s a new requirement that appears in version 9 of the BRC standard…all the personnel participating in the evaluation of our food defense plan must have competencies…the standard doesn’t say what type of training it has to give…each industry has to evaluate the training needs…"
(26:20-27:51) Country-Specific Regulations: Explain that country-specific regulations might exist (e.g., FSMA in the US), and highlight the additional training required in those cases. Then, transition to the next topic. "...depending on the destination countries of your product, like the case of the United States, there, due to FSMA regulations, they do ask that we have specific training with respect to the personnel in charge of the food defense of the facilities…if we’re in Spain, for example, and we’re only selling our products in Spain, there’s no specific requirement for the training of these people…"
VIII. Chapter 4: Management of Food Surplus (27:51-32:11)
(27:51-28:25) Introduction to Food Surplus Management: Transition into the topic of managing food surpluses, highlighting the common situations where this arises.
(28:25-29:17) Clarifying Requirements: Distinguish between producing food for human vs. animal consumption and highlight the relevant requirements in each case. Clearly state that these are distinct requirements, not mutually exclusive or substitutable. "...what would you differentiate with respect to whether in our certification scope we’re manufacturing products for animal feed? These are two totally different requirements…analyze well what your scope is in your food safety system…if in this case what we have is waste that we’re diverting to feed manufacturing…"
(29:17-32:11) Practical Application: Explain how to apply the correct requirements depending on the situation (surplus from human food vs. direct production of animal feed).
IX. Chapter 4: Pest Control (32:11-33:13)
(32:11-29:40) Introduction to Pest Control: Transition to the topic of pest control (clause 4.1.4.10), highlighting its importance and the frequent questions it generates.
(29:40-31:34) Requirements for Pest Control Evaluation: Clearly explain the requirement for an annual pest control evaluation by a qualified specialist. Emphasize that this is not just a trend report but a comprehensive evaluation. "...we have to have an evaluation of our pest control system issued by a specialist…it’s not just managing the trends…we have to…if we already have a pest control company contracted, ask them that annually, a specialist, a biologist, a technician, competent with a higher qualification in pest management…”
X. Chapter 5: Product Control: Allergens & Fraud (33:13-34:22)
(33:13-33:25) Introduction to Allergens and Fraud: Transition to Chapter 5, focusing on the questions around allergen management and fraud vulnerability assessments.
(33:25-34:22) Allergens in Pet Food: Address the question on allergen management in pet food, explaining that while specific legislation may be lacking, following general guidelines (FDA, EU) is important. "...the management of allergens for that type of product…there’s not a clear and specific regulation for the identification of allergens in pet food…but if we adjust a little to the legislation that we have from the FDA or the European Union…" Then, move on to the question of fraud.
XI. Chapter 6: Process Control: Calibration & Protective Clothing (34:22-41:26)
(34:22-35:00) Calibration Requirements: Transition to Chapter 6 and address the questions related to calibration. Emphasize the importance of prioritizing equipment used to monitor critical control points. "...questions arise about what equipment we have to list…we have to include in our list all the measuring equipment…we have to give priority to the monitoring equipment of the critical control points…"
(35:00-36:12) Calibration Best Practices: Provide further guidance on calibration procedures, emphasizing the need to ensure that equipment is adequate and properly identified, and that calibrations and verifications are done according to standards. "...remember that we have to have everything planned as a function of the type of equipment…that the equipment is always adequate for the measurement we are needing…perfectly identified…carried out according to national or international standards…"
(36:12-37:01) Protective Clothing Laundering: Transition to the discussion on the laundering of protective clothing, highlighting the resistance some companies show to fully complying with this requirement. "...and there is a resistance to wanting to comply with the requirement…the standard is very clear…"
(37:01-41:26) Protective Clothing Requirements: Clearly state the rules for laundering protective clothing. Emphasize the distinctions between high-risk and low-risk products/areas, and the circumstances under which home laundering is permitted. "...all that clothing used in an industry that’s a product with risk…it has to be either by laundry or by an external company…the clothing can only be washed by the employee at home only and exclusively when this protective clothing is not used to protect the safety of the product…only and exclusively when these two cases occur: that the clothing is not to protect the product, but to protect the employee, or because we have it as corporate clothing, and as long as we’re in an industry that is low risk or closed areas…"
XII. Conclusion (41:26-41:45)
(41:26-41:39) Summary and Call to Action: Briefly summarize the key topics discussed and encourage listeners to contact you with further questions or for assistance.
(41:39-41:45) Final Thanks and Promotion: Thank the listeners, provide a final promotion of your website and courses, and conclude with a friendly farewell.
This expanded outline provides a more detailed script framework, incorporating the tone and style from the original transcript while providing a more structured and engaging podcast episode. Remember to use natural language and transitions to create a smooth listening experience.
In her podcast episode, Marife Montes addresses common questions and uncertainties surrounding the implementation of the BRCGS Food version 9 standard. She focuses on clarifying several key areas within the standard, offering practical advice and interpretations based on her experience auditing companies over the two years since the standard's release.
The podcast's main points revolve around these themes:
Food Safety Culture: She emphasizes that a strong food safety culture is a shared responsibility across all company levels, not solely management's responsibility, and that auditors look for evidence of its integration across many areas of the business, not simply a single document.
HACCP Plan Validation: Marife stresses the new requirement of validating the HACCP plan before implementation, ensuring that the planned preventive measures are effective. She details several aspects of the HACCP plan that need validation to meet the requirements.
Supplier Management and Traceability: The podcast delves into the complexities of managing suppliers, particularly when working with intermediaries. She explains how traceability requirements depend on whether the intermediary holds a relevant certification. She also clarifies how to deal with situations involving mixed or blended products from several suppliers.
Root Cause Analysis: Marife explains the situations where conducting a root cause analysis is mandatory (e.g., when non-conformities risk product safety or demonstrate a negative trend) and offers a practical approach to consistently applying it.
Food Defense and Personnel Competency: She discusses the importance of competent personnel in food defense plans, while pointing out that BRCGS doesn't stipulate specific training, but competency must be shown. She highlights that regulations may vary internationally (e.g., FSMA in the US).
Product Control and Allergens: The podcast clarifies how allergen management applies to pet food production even though there might not be specific legislation and also explains the scope of fraud vulnerability assessments.
Calibration and Protective Clothing: Finally, she details requirements related to calibration of measuring equipment, prioritizing those used to monitor critical control points, and she addresses the stringent rules surrounding the cleaning and maintenance of protective clothing in different working environments.
In general, Marife's podcast aims to provide practical guidance and clear explanations of the BRCGS Food version 9 standard, helping listeners to understand and effectively implement its requirements. She uses a conversational tone, drawing from her experience to make complex topics more accessible.
In conclusion, Marife's podcast episode summarizes the key points discussed regarding the BRCGS Food version 9 standard, reiterating the importance of understanding and implementing the requirements correctly. She emphasizes the need for a holistic approach to food safety, encompassing not just adherence to specific clauses but also the cultivation of a robust food safety culture across the entire organization.
She encourages listeners who still have questions or uncertainties to contact her through her website (MarifeMontes.com) or other means for further assistance. The overall message is one of practical support and empowerment, enabling listeners to navigate the complexities of the BRCGS standard with more confidence. She ends with a thank you to the listeners and a reminder of her website and courses, showcasing her expertise and offering further resources.
