Comparison with JFS-C Standard Document (ver. 2.3 and ver. 3.0) and overview of revisions
BR2020.1: GFSI Benchmark Requirements ver. 2020.1
JFS-C v2.3: JFS-C Standard Document ver.2.3
JFS-C v3.0: JFS-C Standard Document ver.3.0

JFS-C v. 2.3

Green Fill: NEW ELEMENTS in BR2020.1
Yellow Fill: STRENGTHENED ELEMENTS in BR2020.1

JFS-C v. 3.0

Number
FSM 5

Clause NameTop
Management
Commitment

Requirements
Top management shall provide evidence of their commitment toestablish, implement, maintain and improve the food safety
management system.

FSM 19

Utilization of
Suggestions for
Improvementfrom Workers

The organization shall establish and implement a system to properly
utilize suggestions from workers to improve food safety.

FSM 8

Document andRecord Control

FSM 24

Traceability

Number
FSM 2

Clause NameTop
Management
Commitment
and Food
Safety Culture

Requirements
Top management shall show evidence of its commitment tobuilding,
implementing, maintaining and continually improving its food safety
management systems.
This commitment shall include elements of a food safety culture,andthis means, at a minimum, communicating with employees,
responding to Kaizen suggestions, training to improve food safety,
andassessing the performance of food safety activities. In addition,these
efforts shall be incorporated and implemented in the food safety
management systems of the entire organization.

Summary of Revisions
・This Standard requires that anelement of food safety culture be
included in the top management
commitment.
・This standard also requires top
management to respond to Kaizen
suggestions to improve food safety
as required in FSM 26, as an elementof this commitment.

The organization shall prepare documents and keep records to
FSM 9.2
demonstrate that the organization's operations and activities comply
with the requirements of this Standard.
The organization shall have a written procedure to control and securely
maintain the documents and records and make the documents andrecords readily accessible when needed.
In order to ensure effective operations and control of food safety
processes and management, the retention period of the documents andrecords shall be set complying with, if any, the regulatory and customer
requirements.

Control andstorage of
documented
information

The organization shall provide the documented information requiredtodemonstrate its effective operation of the food safety management
system and control of processes. Documented information shall be
stored for the period required by the customer or legal andregulatory
requirements, or if there are no applicable requirements, for aperiodexceeding the shelf life of the food. In addition, the documented
information shall be effectively controlled so that it is always
available
when it is required.

・The requirements of FSM 8 in JFS-C
v2.3 have been split and aligned with
the numbering structure of BR2020.
・In the absence of a customer orlegal requirement for the retention
period of a document, this standard
requires organizations to retain the
document for a period of time thatexceeds the shelf life of the fooditem.

The organization shall establish, implement and maintain appropriate
procedures and systems to ensure:a) identification of any outsourced raw materials and ingredients(including packaging materials), products, services and outsourced
processes;b) product identification that includes, as a minimum, the name andlocation of the producer;c) identification of batches, partially processed products, work inprogress, products being reprocessed, reworks, finished products, andpackaging materials throughout the production process;d) records of purchaser and delivery destination for all products
supplied.
The procedures and systems shall be verified at least once a year, andthe results shall be recorded.

Traceability

The organization shall establish, implement and maintain
・The standard requires thatappropriateorganizations perform at least annual
tracing procedures covering all processes from supplier (at least one trace testing based on a documented
step before) to recipient (at least one step after) to ensure product traceability procedure andidentification.
verification that the procedure isDocumented procedures shall be verified at least one a year by trace working effectively.
testing to ensure that they are working effectively, and theverification
results shall also be recorded.

FSM 14

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JFS-C v. 2.3
NumberClause Name

FSM 23

FSM 25

JFS-C v. 3.0
Requirements

NumberFSM 15

Clause Name
Product
development

Requirements
Summary of Revisions
The organization shall establish, implement and maintain product・This standard requires organizations
design and development procedures to ensure that new products or to establish product design andproducts whose specifications and manufacturing processes havedevelopment procedures and tochanged are manufactured safely and in accordance with legal and include reviews to ensure food safety
regulatory requirements.
in those procedures.
These development procedures shall clearly confirm that the
products
and services provided conform to specifications, and after identifying
all the hazards of food safety, shall include a review to evaluate andapprove the adequacy of food safety assurance in the design anddevelopment.

Product Labeling The organization shall ensure that all product bears or is accompanied
FSM 18.2
by information to enable the safe handling, display, storage, preparation
and use of the product including allergens in the food supply chain or by
consumer. The finished product shall be labelled according to theapplicable food regulations in the intended country of sale.
Procedures to ensure the correct information on the product shall beestablished and implemented.

Product labeling(B-to-B
products, workin progress,
semi-finishedproducts)

The organization shall define and implement procedures to provide
information, such as on primary processed foods, commercial
ingredients, or intermediates in the processing process, so that
customers or consumers can be informed about product safety,
even
if the information is not labeled on or attached to the product.

Analysis of Input The organization shall establish and implement a system to ensure
Materials
analysis of input raw materials and ingredients (including water) thathave an effect on food safety. The inspection shall be conducted by acompetent laboratory.

Analysis andInspection

The organization shall establish, implement, and maintain・This standard requires thatprocedures
inspections conducted by
to ensure the analysis of raw materials, semi-finished products,
organizations that have a significant
finished products, manufacturing environments, etc. that affect food impact on food safety be conductedsafety.
in accordance with ISO/IEC 17025.
The inspection shall be conducted by a competent inspection
department or analysis institution using appropriate sampling andanalytical methods.
Inspections that have a significant effect on food safety shall be
conducted in accordance with ISO/IEC 17025.

FSM 19.1

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・This standard requires organizations
to establish and implement
procedures to provide information
about the safety of their products tocustomers or consumers, even if theinformation is not labeled or attachedto the product.

JFS-C v. 2.3

JFS-C v. 3.0

Number
GMP 3

Clause Name
Requirements
NumberDesign,Site, building, and facility and equipment in the plant shall be designed, GMP 3
Construction and laid out, constructed and maintained to enable controlling the risk of
Layout ofproduct contamination caused by external and internal environment andFacilities,
manufacturing flow.
Equipment andProduction

Clause Name
Design,construction,layout ofbusiness site
and work andproduct
flow lines

Requirements
The organization shall design, construct and maintain thefactory buildings and facilities (storage area, raw material andproduct handling area, preparation area, packaging andstorage area, etc.) of the business site both outside and inside
the plant to minimize food safety risks.
In addition, the equipment layout and the flow lines of people,
goods, and work shall be designed to meet the intended
purpose and minimize food safety risks.

Summary of Revisions
・This standard requires organizations
to design, construct, and maintaintheir workplace facilities, both off-siteand on-site, in a manner thatminimizes food safety risks, and toanalyze the facility layout and flow ofpeople, goods, and operations toensure that they minimize foodsafety risks.

GMP 8

Physical,Chemical andBiological
Product
Contamination
Risks

GMP 4

GMP 9

Segregation and Procedures to prevent contamination and cross-contamination shall be
Crossestablished for raw materials and ingredients (including packaging
contaminationmaterials), partially processed products, work in progress, products
being reprocessed, reworks, and finished products, covering all aspectsof food safety including micro-organisms, chemicals and allergens.

Physical,chemicaland biologicalproduct
contaminationrisks
and isolation

The organization shall clarify that all hazard factors (physical,
chemical (including allergens), and biological) for eachprocess have been identified based on consistency checks
between the process flow created by the HACCP team andthe site. The frequency of occurrence and the magnitude of
the consequences of the identified hazards shall be evaluatedand appropriate control measures shall be set for each.
Procedures shall be established and documented to control
identified hazards other than critical control points (CCPs) thatare difficult to manage effectively with a general hygiene
control program to prevent contamination of raw materials(including packaging materials), semi-finished products, workinprocess, rework and finished products, and crosscontamination.
The organization shall regularly review these procedures andkeep them in effect.

・This standard requires organizations
to establish appropriate control
measures for all hazards from theperspective of the manufacturing
environment, although they may not
be applicable to the HACCP CriticalControl Points (CCPs), and to ensurethat these hazards and raw materials
and products are not crosscontaminated.
・Although this clause is an enhanced
element in BR2020.1, it is included in
JFS-C v2.3 and the requirements
remain unchanged.

GMP 17

Training

A system shall be in place to ensure all workers are adequately trainedon food safety principles (including HACCP) and practices,
commensurate with the worker’s activity.
A system shall be established to ensure all workers are adequately
instructed and supervised.
Training shall ensure all workers to be aware of the roles in food safety
and the significance of the activities.

GMP 7

Training

All personnel shall be trained in their appropriate language onfood safety (including management, culture, HACCP, GMP),and there shall be a system for each personnel to deepen theirunderstanding, implement, and maintain food safety in theirrespective work.
In addition, there shall be a system to improve comprehension
by repeating the training as necessary after evaluatingcompetence.

・This standard requires organizations
to establish a system to educate andtrain all employees on food safety,
and to evaluate their competence
and repeat the training as necessary
to enhance their understanding.

GMP 11

Housekeeping,
Cleaning andHygieneHousekeeping and cleaning shall be carried out following theGMP 8documented criteria throughout all the process steps and stages, and an
appropriate hygiene level shall be maintained at all times by disinfecting
where necessary. Cleaning tools, cleaning agents and disinfectants
shall be suitable for their intended use and stored appropriately.

Housekeeping,cleaning,
sterilizationand disinfection

The organization shall identify product-specific risks based ona hazard analysis and establish, implement and maintaindocumented organization, cleaning, sterilization anddisinfection procedures.
In addition, the organization shall also verify that proceduresthat can minimize product-specific risks are working
effectively.
Cleaning tools, cleaning agents and disinfectants shall besuitable for their intended use and stored appropriately.
Food safety information on potentially harmful chemicals shallbe obtained and confirmed.

・This standard requires organizations
to document and verify theeffectiveness of their tidiness,disinfection and disinfection
procedures, in accordance with therisks involved.

Appropriate facilities and procedures shall be established to control therisks of physical, chemical (including allergens) and biologicalcontamination of product.

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JFS-C v. 2.3

JFS-C v. 3.0

NumberClause Name

Requirements

Number
GMP 10Clause Name
Patrol andinspectionof the site

Requirements
The organization shall establish a patrol plan and regularly
inspect the environment, facilities, and process design(people, things, work flow lines) of the entire site.
Records shall be maintained as evidence of the inspection.
The patrol plan shall ensure that the workplace is maintainedin an appropriate state according to its activities and that foodsafety is ensured.

Summary of Revisions
・This standard requires organizations
to establish and regularly implementa patrol plan for environment,
equipment, and flow of people,
goods and works in the site.

GMP 12

Water and Ice
Management

Required quality criteria shall be defined for waters (including steam
and ice; the same applies hereinafter) used in food manufacturing,depending upon the intended use, and the quality of water shall be
regularly monitored and recorded.

GMP 11

Air and water
management

The organization shall define the required quality criteria
according to the application, and regularly monitor and record
the air, high-pressure gas, and water (including ice and steam)used in food production in order to minimize the effect on foodsafety.
If any water that is not used for food production (including
wastewater) and is not suitable for food production is used, it
must be managed to prevent contamination of the water used
for food production.

・This clause requires the organization
to regularly monitor air, highpressure gas, and water used in foodproduction, and to control it toensure that water unsuitable for foodproduction does not contaminate
water for production.

GMP 14

Pest Control

A system shall be established to control or eliminate the food safety
risks caused by pests in the site or in the facilities.
In case where chemicals are used, a handling procedure shall beestablished not to affect food.

GMP 13

Pest control

・This standard requires organizations
to establish procedures to prevent,control and remove the risk of pest
outbreaks at their sites.

GMP 6

MaintenanceA system shall be established to control or eliminate the food safety
risks caused by pests in the site or in the facilities.
In case where chemicals are used, a handling procedure shall beestablished not to affect food.

GMP 19Maintenance

The organization shall establish, implement and maintainprocedures to control or eliminate food safety risks caused bypests (pests and vermin) on the premises and in the facilities.
These procedures shall be implemented using the following
cycle.
1．Understanding of the pest outbreak situation andformulation of monitoring plans.
2. Implementation of pest control and invasion prevention.
3. Pest monitoring and dissemination of results to personnel.
The organization shall establish pest control procedures asnecessary.
A system of planned maintenance covering all items ofequipment which are critical to product safety shall beestablished.

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・This standard requires organizations
to establish a maintenance system
for all plant facilities and equipmentthat are critical to the safety of theirproducts.
・This clause is an enhanced elementin BR2020.1, but is included in JFS-C
v2.3 and the requirements remainunchanged.