IN Brief:
- BRCGS received more than 570 applications for participation in the Food Safety Issue 10 rewrite.
- The selected technical group spans manufacturing, certification, science, retail, consultancy, and other disciplines.
- No final Issue 10 clauses have been published, making the current development update procedural rather than a new compliance requirement.
BRCGS has detailed the technical process behind the development of Food Safety Issue 10, revealing that more than 570 food-safety professionals applied to participate in the revision of its manufacturing standard.
The selected Technical Working Group brings together manufacturers and processors, certification and accreditation bodies, trade associations, consultants, scientific and technical organisations, retailers, brand owners, and specifiers. BRCGS says the group spans all 18 product categories covered by the Food Safety programme.
Members collectively bring almost 1,000 years of food-safety experience, according to the organisation, with selection intended to balance professional expertise, industry sector, company size, geography, and practical experience.
The working group is reviewing proposed requirements alongside emerging risks, technical developments, regulatory change, commercial expectations, and feedback from across the industry. BRCGS has not, however, published final Issue 10 clauses in the 11 August update, leaving manufacturers with a development milestone rather than a new set of audit requirements.
The revision has to work across very different factories
That distinction matters because the Food Safety standard is applied across manufacturing environments whose hazards and process controls can differ substantially. A dry-ingredient operation, dairy plant, bakery, slaughter site, beverage factory, and high-care chilled-food plant may share the same overarching standard while using very different zoning, cleaning, temperature, allergen, microbiological, and foreign-body controls.
A technical requirement that is too broad can become difficult to audit consistently; one that is too prescriptive can fail to recognise legitimate differences between products and processes. The working group’s task is therefore not only to identify new risks but to translate them into requirements that remain measurable and practical across those settings.
Factories also have to connect written systems to plant-level execution. A procedure can be technically complete while maintenance access, cleaning practice, operator behaviour, product flow, inspection frequency, or record quality creates a gap in normal production.
That is particularly visible where food safety intersects with engineering. Hygienic design decisions affect access for cleaning and inspection; maintenance work can introduce contamination if controls are weak; temporary repairs can become permanent; and ageing equipment may create harbourage points that were not present when a line was commissioned.
The next issue also arrives in a manufacturing environment that is becoming more digital. Inspection equipment increasingly records results centrally, remote support has become routine, and automated vision, predictive maintenance, and data-driven process controls are moving further into food plants.
Those systems can strengthen verification but introduce their own questions. Automated inspection still needs validation against the hazard and product, software changes require control, alarm limits need technical justification, and operators must understand what to do when a system identifies a deviation. A digital record does not make a control effective simply because it is easier to retrieve during an audit.
Supply-chain evidence is becoming more complicated
Supplier assurance presents a parallel challenge. Manufacturers may depend on ingredients, processing aids, packaging, cleaning chemicals, outsourced services, and contract processors supplied through increasingly complex networks. Documents can move electronically and quickly while the underlying evidence remains incomplete or difficult to verify.
Food-safety standards therefore have to address both the presence of procedures and the quality of the decisions those procedures produce. Supplier approval, vulnerability assessment, traceability, specifications, change control, and corrective action all depend on information that can deteriorate if responsibility between businesses is unclear.
The same principle applies to food-safety culture. Training records may demonstrate that an operator attended a course, but the more important test is whether the behaviour on the line reflects the control required. Standards increasingly have to examine how management systems translate into routine practice rather than relying on documents in isolation.
BRCGS says its Issue 10 meetings are reviewing proposed changes through a structured process designed around clarity, consistency, and relevance. Industry feedback and developments in the regulatory and commercial landscape form part of that review alongside scientific and technical input.
For certified manufacturers, the present update is therefore useful mainly because it establishes how the next standard is being built and how broad the contributor base is. It does not justify factories redesigning controls around speculative requirements that have not yet been published.
The sensible preparation remains more prosaic: keep the existing system functioning, examine recurring non-conformities, maintain current hazard analysis and supplier evidence, and follow the formal revision and consultation process as proposed clauses emerge.
More than 570 applications to participate suggest considerable industry interest in shaping Issue 10. The harder part starts once draft requirements leave the working group. At that point, manufacturers will have to decide whether the revised standard can be absorbed through documentation and training or whether it creates real plant-level requirements for validation, engineering, software, supplier controls, or capital expenditure.
