Best Practices in Preparing for a BRCGS Issue 9 Audit

Tiffany M. Donica
Contributing Writer

Certification against Issue 9 standards began on Feb 1, 2023. Recently, SafetyChain covered changes in BRCGS Issue 9 from BRCGS Issue 8. If you haven’t yet, read our previous blog to learn what is the BRCGS Food Safety standard, because in this blog, we’re going to hit the ground running and tell you how to prepare for your audit against Issue 9 standards.

Table of Contents:

  1. Conduct a Pre-Audit — Last!

  2. Train Personnel

  3. Maintain Documentation

  4. Conduct Regular Internal Audits

  5. Address Non-Conformities
    The Top 10 Nonconformities of 2021, and How They’ve Evolved in Issue 9

    4.11.1 — Premises and equipment hygiene

    4.6.1 — Equipment construction & maintenance

    4.4.8 — Doors

    4.9.1.1 — Chemical controls

    4.4.1 — Walls

    2.7.1 — Hazard identification

    4.15.1 — Storage facilities

    1.1.2 — Food Safety Culture

    3.4.1 — Internal Audits

    4.11.2 — Cleaning procedures

  6. Are You Ready For Your Next BRCGS Audit? 

Conduct a Pre-Audit — Last!

Let’s be clear: a pre-audit should not be your first line of defense when preparing for an audit. A pre-audit is the final step in ensuring your organization is ready to pass the audit with flying colors.

A pre-audit is your last chance to tie up any loose ends and address non-conformities and gaps in training before the actual audit. While this is absolutely a necessary step to prepare for the actual BRCGS audit, we cannot emphasize enough that this is the last self-audit you should perform before your real audit, as you should be conducting audits regularly. More on this below.

Train Personnel

Every employee — regardless of station or role — should be able to provide consistent responses to questions or clarifications asked by the auditor.

Remember, this isn’t a man-hunt to catch employees in the wrong. If employees are skipping steps, then management hasn’t done a sufficient job of communicating why rules and procedures are in place.

A 2022 Global Food Safety Training Report surveyed over 2,000 manufacturing and food processing industry professionals and there was a major difference between how management views food safety compared to how it’s implemented in practice on their factory floors.

Not only does the “why” need to be effectively communicated, but employees need frequent and regular reminders to keep critical information top-of-mind. Keep visual reminders in break rooms and consider holding monthly or even weekly short food safety highlights to help ensure employees have a well-rounded understanding of what is expected of them and why.

Maintain Documentation

During a BRCGS audit, an auditor from an accredited certifying body will thoroughly review your records and process across the nine core areas of operations stipulated in BRCGS Issue 9:

  • Senior management commitment

  • Food Safety Plan (HACCP)

  • Food Safety and quality management

  • Site standards

  • Product control

  • Process control

  • Personnel

  • High-risk, high-care, and ambient high-care production risk zones

  • Requirements for traded products

This documentation should be stored in a central repository so that it’s easily accessible across organizational levels and departments.

Technology is a lifesaver when it comes to documentation. The right tech can even automate some of the documentation process, in addition to making it easy to find, search, etc. You don’t necessarily need to go all-out with artificial intelligence (Although AI for food safety applications is available if you’re ready to tackle tech’s latest competitive advantage!), but digitizing helps minimize human error and keep the right information easily accessible to the right people at the right time.

BRC Audits and Certification: The Ultimate Guide to BRC Issue 9

Conduct Regular Internal Audits

That pre-audit is a good start but it’s also more of a reactive check. Lean manufacturing principles dictate that manufacturers should be consistently proactive in their operations efforts.

One of the worst mistakes is starting to prepare for your audit too late. Not only does it not give you adequate time to correct non-conformities and train staff, but you may also find yourself running into a wall if you haven’t yet secured leadership buy-in to dedicate sufficient time and resources to prepare.

Dr. Inderjit Arora, President and CEO of Quality Management International, Inc., said it best: “The only bad non-conformity is the one you do not know about.” — and the only way to discover non-conformities is through regular, effective internal audits.

When conducting an internal audit, remember the following:

  • Use identified nonconformities as opportunities to improve your products and processes.

  • Design your own internal audit checklist that’s unique to your business and integrates feedback from previous audits. Certainly use the BRC’s provided checklist as a template for designing your own audit, but be sure to tailor it to your business’s history and risks.

  • Capitalize on digital solutions to collect data and identify historical trends, but avoid point solutions: one size never fits all.

Address Non-Conformities

A study across 22,000 BRCGS audits performed in 2021 showed that 5.6% of clauses in the Food Standard account for 30% of raised non-conformities. While the standards have been updated for Issue 9, manufacturers should use these “lessons learned” from Issue 8 mistakes and ensure they’re up to par for Issue 9.

The Top 10 Nonconformities of 2021, and How They’ve Evolved in Issue 9

Let’s go into each of the top 10 non-conformities for the BRCGS in detail, as provided in the BRCGS Issue 9 Auditor Checklist. In particular, we advise management to pay particular attention to the sections on chemical controls, food safety culture, internal audits, and cleaning procedures, which have been updated since Issue 8. For convenience, these critical updates are highlighted in yellow.

4.11.1 Premises and equipment hygiene

“The premises and equipment shall be maintained in a clean and hygienic condition”

No changes between Issue 8 and Issue 9.

4.6.1 Equipment construction & maintenance

“There shall be a documented purchase specification for any new equipment detailing the site requirements for the equipment. This may, for example, include:

  • any relevant legislation

  • where applicable, requirements for food contact surfaces to meet legal requirements

  • details of intended use of the equipment and the type of materials it will be handling.

Depending on its intended use, new equipment to site (including second-hand equipment) may require authorization from a multi-disciplinary team. The supplier should provide evidence that equipment meets these site requirements prior to supply.”

The BRCGS significantly increased the level of detail in this section between Issue 8 and Issue 9, which shows BRCGS Audits based on Issue 9 will likely be looking at this requirement more strictly than in previous years.

In Issue 8, Clause 4.6.1 simply read, “All equipment shall be constructed of appropriate materials. The design and placement of equipment shall ensure it can be effectively cleaned and maintained.

4.4.8 Doors

“Doors (both internal and external) shall be maintained in good condition. At a minimum:

  • external doors and dock levelers shall be close fitting or adequately proofed

  • external doors to open product areas shall not be opened during production periods except in emergencies

  • where external doors to enclosed product areas are opened, suitable precautions shall be taken to prevent pest ingress.”

No changes between Issue 8 and Issue 9.

4.9.1.1 Chemical controls

“Processes shall be in place to manage the use, storage and handling of non-food chemicals to prevent chemical contamination. These shall include, at a minimum:

  • an approved list of chemicals for purchase

  • availability of material safety data sheets and specifications

  • confirmation of suitability for use in a food-processing environment

  • avoidance of strongly scented products

  • the labelling and/or identification of containers of chemicals at all times

  • a designated storage area (separate from chemicals used as raw materials in products) with access restricted to authorized personnel

  • use by trained personnel only

  • procedures to manage any spills

  • procedures for the safe, legal disposal or return of obsolete or out-of-date chemicals and empty chemical containers.”

The highlighted sections above feature additions to Issue 9 that were not present in Issue 8. Again, this should be regarded as a response to the audits conducted against Issue 8 requirements, and should therefore be taken into careful consideration when preparing your BRCGS audit.

4.4.1 Walls

“Walls shall be finished and maintained to prevent the accumulation of dirt, minimize condensation and mold growth, and facilitate cleaning.”

No changes between Issue 8 and Issue 9.

2.7.1 Hazard identification

“The HACCP food safety team shall identify and record all the potential hazards that are reasonably expected to occur at each step in relation to product, process and facilities. This shall include hazards present in raw materials, those introduced during the process or surviving the process steps, and consideration of the following types of hazards:

  • microbiological

  • physical contamination

  • chemical and radiological contamination

  • fraud (e.g. substitution or deliberate/intentional adulteration)

  • malicious contamination of products

  • allergen risks (see section 5.3).

It shall also take account of the preceding and following steps in the process chain.”

No changes between Issue 8 and Issue 9.

4.15.1 Storage facilities

“Procedures to maintain product safety and quality during storage shall be developed on the basis of risk assessment, understood by relevant staff and implemented accordingly. These may include, as appropriate:

  • managing chilled and frozen product transfer between temperature-controlled areas

  • segregation of products where necessary to avoid cross-contamination (physical, microbiological or allergens) or taint uptake

  • storing materials off the floor and away from walls

  • specific handling or stacking requirements to prevent product damage.”

No changes between Issue 8 and Issue 9.

1.1.2 Food safety culture

“The site’s senior management shall define and maintain a clear plan for the development and continuing improvement of a food safety and quality culture. The plan shall include measures needed to achieve a positive culture change.

This shall include:

  • defined activities involving all sections of the site that have an impact on product safety. As a minimum, these activities shall be designed around:

    • clear and open communication on product safety

    • training

    • feedback from employees

    • the behaviors required to maintain and improve product safety processes

    • performance measurement of activities related to the safety, authenticity, legality and quality of products

  • an action plan indicating how the activities will be undertaken and measured, and the intended timescales

  • a review of the effectiveness of completed activities.

  • The plan shall be reviewed and updated at least annually, at a minimum.”

As discussed in our previous blog in this series, food safety culture is a major component of Issue 9. Unsurprisingly, there were many updates to Section 1.1.2. Management is advised to pay extra attention to Section 1.1.2 for Issue 9 BRCGS audits.

3.4.1 Internal audits

“There shall be a scheduled program of internal audits.

At a minimum, the program shall include at least four different audit dates spread throughout the year. The frequency at which each activity is audited shall be established in relation to the risks associated with the activity and previous audit performance. All activities that form a part of the site’s food safety and quality systems, including those relevant to food safety, authenticity, legality and quality, shall be covered at least once each year.

The scope of the internal audit program shall include, although this is not an exhaustive list:

  • HACCP or food safety plan, including the activities to implement it (e.g. supplier approval, corrective actions and verification)

  • prerequisite programs (e.g. hygiene, pest management)

  • food defense and food fraud prevention plans

  • procedures implemented to achieve the Standard.

Each internal audit within the program shall have a defined scope and consider a specific activity or a section of the HACCP or food safety plan.”

The highlighted sections above feature additions to Issue 9 that were not present in Issue 8.

4.11.2 Cleaning procedures

“Documented cleaning and disinfection procedures shall be in place and maintained for the building, plant and all equipment. Cleaning procedures for the processing equipment and food contact surfaces shall, at a minimum, include:

  • responsibility for cleaning

  • item/area to be cleaned

  • frequency of cleaning

  • method of cleaning, including dismantling equipment for cleaning purposes where required

  • cleaning chemicals and concentrations

  • cleaning materials to be used

  • cleaning records (including records for completion and sign-off) and responsibility for verification.

The frequency and methods of cleaning shall be based on risk. The procedures shall be implemented to ensure appropriate standards of cleaning are achieved.”

The highlighted sections above feature additions to Issue 9 that were not present in Issue 8. There are minor but very specific introductions in this area that suggest where plants were falling short of Issue 8 expectations that will be expected in audits subject to Issue 9 regulations.

Are you ready for your next BRCGS audit?

Download our e-guide, The Ultimate Guide to BRC Audits and Certifications: Issue 9, to learn more about what you need to know for BRCGS Issue 9 audits.

BRC Audits and Certification: The Ultimate Guide to BRC Issue 9