FSNS Certification & Audit performs hundreds of food safety certification audits each year, including for BRC certification. Our auditors have compiled a list of the top 10 reasons for a BRC version 9 audit non-conformity to help you prepare for your next audit.
Below, we provide the appropriate clause and item from the BRCGS Food Safety code for each of the top 10 non-conformities. Here’s the full list:
10) Cleaning and Sanitation Procedures – 4.11.2
Our list of top 10 reasons for a BRC audit non-conformity begins with overall cleaning and sanitation. The clause states:
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.
Common Problems:
- Cleaning and sanitation chemical concentrations are not compliant with documented procedures.
- Failure to establish or follow a master sanitation schedule.
- Recordkeeping errors:
- Documenting pre-op inspections
- Titration records
- Master sanitation records
Facilities often neglect to adhere to documented procedures when preparing chemical concentrations, which will lead to a non-conformity. Make sure you have established a master sanitation schedule and, of course, follow it.
Auditors also observe NCs because of poor cleaning and sanitation recordkeeping, so make sure your team understands what to document and the importance of carrying it out. Our sanitation education courses can help ensure you’re meeting the requirements of the standard.
9) Procedures for Managing Static Equipment – 4.6.4
The ninth item on our list of top 10 reasons for a BRC audit non-conformity involves the management of static equipment. This includes equipment that is not ordinarily moved or moved only in exceptional circumstances. The clause states:
A procedure shall be in place to manage the movement of static equipment in production areas, to ensure that food safety is managed and the integrity of the equipment is maintained.
Common Problems:
- Failure to develop defined procedures for managing the movement of static equipment.
- Procedures were not implemented.
Our auditors have noticed two main issues with facilities: Some facilities have not developed procedures at all, while others have created procedures but have not successfully implemented them. As the old adage goes, “Say what you’re going to do, do it, and document that you did it.”
In this case, a procedure may include the type of equipment to be moved; how it shall be moved, reinstalled, and calibrated; who is responsible for its movement; staff training on the procedure, etc.
8) Internal Audit and Corrective Actions – 3.4.3
The internal audit program shall be fully implemented. Internal audit reports shall identify conformity as well as non-conformity and include objective evidence of the findings. The results shall be reported to the personnel responsible for the activity audited. Corrective and preventive actions, and timescales for their implementation, shall be agreed and their completion verified.
Common Problems:
- Failure to properly document corrective actions for deviations identified during internal audits.
- Failure to properly document the results of internal audits.
“Failure to document” summarizes the common issue causing many facilities to receive a non-compliance for their internal audits and corrective actions. Conducting internal audits is an excellent initial step, but it’s crucial that your team properly records both the audit results and the subsequent corrective measures.
Check out our internal audit education courses for guidance.
7) Doors – 4.4.8
Doors (both internal and external) shall be maintained in good condition. At a minimum:
- External doors and dock levellers 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.
Common Problems:
- Dock doors/man doors not properly sealed to prevent pest ingress.
- Damaged doors.
Pest management is a big component of any food safety certification, including BRCGS Food Safety. Unsealed or damaged doors provide pests a golden opportunity to infiltrate your facility and cause bigger problems.
Ensure your maintenance team takes the necessary precautions to prevent receiving this non-conformity on your next BRCGS Food Safety audit.
6) Ceilings and Overheads – 4.4.4
Ceilings and overheads shall be constructed, finished, and maintained to prevent the risk of product contamination.
Common Problems:
- Potential foreign material – rust, peeling paint, caulking, etc.
- Overheads not properly cleaned.
- Holes around conduits.
Potential contamination can come from just about anywhere, including directly above your production areas. Auditors often identify peeling paint, loose caulk, rust flakes, peeling tape, and other contaminants on ceilings and overheads that must be addressed.
Make sure your team includes the cleaning of these areas in your SOPs, too.
5) Food Safety Objectives – 1.1.3
The site’s senior management shall ensure that clear objectives are defined to maintain and improve the safety, authenticity, legality, and quality of products manufactured, in accordance with the food safety and quality policy and this Standard. These objectives shall be:
- Documented and include targets or clear measures of success.
- Clearly communicated to all staff.
- Monitored and results reported at least quarterly to site senior management and all staff.
Common Problems:
- Facility has not demonstrated that it communicates the results of its quarterly performance evaluations, compared against set objectives, to all staff members.
The most common problem we see in facilities that receive a non-conformity in this area isn’t a failure to set food safety objectives, it’s a failure to share results of quarterly evaluations.
Personnel need to know how the organization is faring with respect to food safety objectives so they can continue to improve. This communication also helps promote food safety standards in your company.
Our BRCGS Food Safety Audit Checklist can help ensure your facility doesn’t receive any of the non-conformities on this list.
4) Management Commitment Policy – 1.1.1
The #4 item on our list of top 10 reasons for a BRC audit non-conformity comes from the very first clause in the BRC edition 9 code, which states:
The site’s senior management shall demonstrate that they are fully committed to the implementation of the requirements of the Global Standard Food Safety and the processes which facilitate continual improvement of food safety, quality management, and the site’s food safety and quality culture.
Common Problems:
- Commitment policy does not include processes for continual improvement.
- Commitment policy does not include a commitment to food safety culture.
Granted, this clause covers a lot of ground, making it a challenge to meet its requirements. Our top observances can help you focus your efforts. Ensure your policy includes a process for continual improvement and a commitment to promoting a culture of food safety throughout your organization.
3) Ventilation/Condensation – 4.4.10
Adequate ventilation and extraction shall be provided in product storage and processing environments to prevent condensation or excessive dust.
Common Problems:
- Poor or no ventilation.
- Restricted or non-functional exhaust/intake vents.
- Condensation buildup in cold storage.
Number 3 on our list of top 10 reasons for a BRC audit non-conformity is related to the next entry on the list, namely Facility Cleanliness.
Our auditors often observe dust in storage areas, and it is usually a consequence of poor ventilation. Condensation can also be problematic without adequate ventilation, which will also result in an NC. Ensure your facility has good ventilation to help promote food safety.
2) Facility Cleanliness – 4.11.1
Number 2 on our list of top 10 reasons for a BRC audit non-conformity is as important as it is direct:
The premises and equipment shall be maintained in a clean and hygienic condition.
Common Problems:
- Equipment observed not clean following pre-operational inspection.
- Storage/warehouse areas observed with dust or cobwebs.
Every food safety professional knows the importance of clean, sanitary operations. The most common observances our auditors see is unclean equipment following a pre-op inspection; and dust, spiderwebs, dirt, and other contaminants in warehouses and storage areas.
While it might seem less critical to maintain non-production areas or surfaces that do not come into direct contact with food, cleanliness across the entire premises is essential as per the BRCGS Food Safety standard. If all areas of your facility aren’t clean and hygienic, you risk a non-conformity notice in your next BRC audit.
1) Equipment Design and Construction – 4.6.2
We have arrived at #1 on our list of the top 10 reasons for a BRC audit non-conformity – Equipment Design and Construction. The BRC code (edition 9) states:
The design and construction of equipment shall be based on risk, to prevent product contamination. For example, the use of the correct seals, impervious surfaces or smooth welds and joints, where they are exposed to product and could otherwise result in foreign-body, microbiological or allergen contamination of the product.
Equipment that is in direct contact with food shall be suitable for food contact and meet legal requirements where applicable.
Common Problems:
- Broken welds.
- Damaged equipment.
- Equipment and utensil storage.
We have seen pathogens find harborage in all kinds of easy-to-miss cracks and crevices, such as a broken weld that may be difficult to see at first glance. It’s important to root out and fix broken welds and other damaged areas where microorganisms can take refuge and contaminate your products.
Proper equipment and utensil storage is another major reason our auditors find for a BRC audit non-conformity, so ensure your personnel are following proper procedures.
The Top 10 Reasons for a BRC Audit Non-Conformity: Recap
Being aware of these top 10 reasons for a BRC audit non-conformity can be invaluable in preparing for your next audit. Ensure proper cleanliness, effective equipment management, and comprehensive documentation of audits and corrective actions. Furthermore, it’s critical to maintain safe and suitable premises and demonstrate management’s commitment to food safety.
Remember, these insights are drawn from common problems we’ve observed during audits, and each facility has unique challenges. Continually striving for improvements and fostering a culture of food safety is key. Use this information to achieve higher standards and avoid non-conformities in future BRC audits.
Reach out to our certification and audit experts with questions or to schedule your next BRC audit.
