Top 10 Things to Look Out For in the New BRCGS Issue 9 Audits

So, we have finally experienced the BRCGS Issue 9 audit, and we have compiled the top 10 list of the requirements that we found are catching auditees off guard:

1. Food Safety and Product Quality Culture Plan, Activities and Review

We have found that most sites still need to fully incorporate the above in their food safety culture plans, especially “performance measurement of activities related to the safety, authenticity, legality and quality of products” and employee feedback.

Food safety and product quality culture plan, activities and review. This requirement under clause 1.1.2 has defined activities and requirements e.g.

“The plan shall include measures needed to achieve a positive culture change. This shall include:

  • Defined activities involving all sections of the site that impact product safety.
  • As a minimum, these activities shall be designed around the following:
    • clear and open communication on product safety
    • training
    • feedback from employees
    • the behaviours required to maintain and improve product safety processes
    • performance measurement of activities related to the safety, authenticity, legality and quality of products.”

2. Communication of Objectives

Communication of objectives to all staff and ensuring they are monitored and results reported at least quarterly to senior site management and ALL staff. Most sites still need to implement this requirement. (Clause 1.1.3)

3. Designated Manager for Reporting

A requirement under clause 1.2.3. Allocating a designated manager so that staff can report any risks or evidence of unsafe or out-of-specification products, equipment, packaging or raw materials and ensuring the team is aware of this. Please note this is not the same as Whistle-blowing!

4. Corrective Actions for Fabrication and Hygiene Inspections

A new requirement under Clause 3.4.4.

Writing up corrective actions for fabrication and hygiene inspections and reporting the results to the personnel responsible for the activity or area audited. We have found that many sites still need to implement this and are only recording what has gone wrong under the comment sections. Please take note of this requirement.

5. Low-risk Suppliers Questionnaire

Clause requires that low-risk suppliers that do not have GFSI-recognized certifications complete a questionnaire. The standard stipulates the minimum scope requirements for the questionnaire, which shall include, at a minimum, “product safety, product security and food defence, product authenticity, traceability, HACCP review and good manufacturing practices.”


6. Food Defence Training

The requirements for knowledge of food defence as per clause 4.2.1. Although most sites had food defence procedures and threat assessments in place, the personnel engaged in threat assessments needed adequate knowledge of food defence principles beyond site security procedures.

7. Food Defence Legal Requirements

Clause 4.2.2 requires that “where applicable, the food defence plan shall meet the legal requirements in the country of sale or intended use”, many sites exporting to countries besides the EU were found wanting, especially those Exporting to North America and the United Kingdom.

8. Purchase Specifications for New Equipment

Then there is Clause 4.6.1. Here, a lot of sites audited against version 9 struggled. One of the requirements is that “there shall be a documented purchase specification for any new equipment detailing the site requirements for the equipment” most sites could not understand what this means or overlooked this requirement. The standard is very specific that there shall be a procedure, and one could also supplement the procedure with a checklist to ensure that all the requirements, as indicated in clause 4.6.1, have been met.

9. Risk-based Commissioning Procedure

Clause 4.6.2 was also a big challenge as there is a requirement that a “documented, risk-based commissioning procedure shall be in place to ensure that food safety and integrity is maintained during the installation of new equipment to the site.” Most sites did not have it at all.

10. Reconciliation of Labels

The last clause we found a lot of confusion about is clause 6.2.1. This clause relates to the reconciliation of labels and investigating the cause of any inconsistencies if there are any. Most sites would either not do any reconciliation or indicate that some labels could have been destroyed or damaged without elaboration. The standard requires that there must be an investigation, which most sites were not.


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