Learning from the Top 5 BRCGS Food Safety Certification Audit Non-Conformities
LRQA has recently published the top five non-conformities (NCs) identified during their BRCGS Food Safety Audits between 2019 and 2023 which gives us an insight into key areas where sites let themselves down during BRCGS Global Standard for Food Safety Certification Audits.
Top was Clause 4.6.1 which requires that: ‘All equipment shall be constructed of appropriate materials. The design and placement of equipment shall ensure it can be effectively cleaned and maintained.’ This had 454 NCs raised by LRQA. Note that Issue 9 changes included the need for a documented purchase specification for any new equipment detailing the site requirements for the equipment and this is an area where sites may fall short. Also that the design and construction of equipment now needs to be based on risk, to prevent product contamination, a procedure needs to be in place to manage the movement of static equipment in production areas, equipment that is not used or is taken out of service needs to be managed and a documented, risk-based commissioning procedure needs to be in place to ensure that food safety and integrity is maintained during the installation of new equipment. Clearly it is essential to ensure that these changes have been considered in your food safety management system.
Next was Clause 4.11.1 which requires that the premises and equipment are maintained in a clean and hygienic condition. This had 430 NCs raised by LRQA. As this is a fundamental requirement, appropriate standards of hygiene should be a given and there should be cleaning procedures for the processing equipment and food contact surfaces including:
- Responsibility for cleaning
- Item/area to be cleaned
- Frequency of cleaning —
- Cleaning chemicals and concentrations-
- Cleaning materials to be used-
- Method of cleaning-
- Instructions for dismantling equipment for cleaning purposes if applicable-
- Cleaning records
Joint 3rd was Clause 1.1.2 which requires the site’s senior management to define and maintain a clear plan for developing and continuing improvement of a food safety and quality culture. Sites were required to have an action plan indicating how the activities would be undertaken and measured, the intended timescales and to review of the effectiveness of completed activities. This had 296 NCs raised and was a new requirement in BRCGS Food 8. There were major revisions in Issue 9 which specified extended expectations regarding the adaption of a Food Safety Culture on site, sites need to have incorporated specific additional elements into their Food Safety Management System including as a minimum:
- Clear and open communication on product safety
- Training
- Feedback from employees
- The behaviours required to maintain and improve product safety processes
- Performance measurement on activities related to the safety, authenticity, legality and quality of products
Also Joint 3rd was Clause 2.7.1 which requires that the HACCP food safety team need to identify and record all the potential hazards that are reasonably expected to occur at each step, in relation to product, process and facilities. This had 296 NCs raised by LRQA. Again, this is a fundamental requirement, sites need to have a fully implemented and effective food safety plan incorporating the Codex Alimentarius HACCP principles. Hazard analysis must include identify hazards present in raw materials, those introduced during the process or surviving the process steps, considering microbiological, physical, chemical and radiological contamination, allergen risks and potential fraud or malicious contamination of products.
At number 5 was Clause 4.4.8 a requirement for Doors (both internal and external) to be maintained in good condition. This had 283 NCs raised by LRQA. Sites are often let down by inadequate proofing or damage to proofing measures/doors that allow ingress of pests. This is something that should be picked up in hygiene and housekeeping inspections.
By Tony Connor
Source of Data – Preparing you for your audit – Top 5 non-conformities in BRCGS Food Safety
‘Lloyds To help businesses prepare for their BRCGS Food Safety, our experts have identified the top five non-conformities identified during BRCGS Food Safety audits between 2019 and 2023.’
https://www.lrqa.com/en-gb/resources/brcgs-non-conformities-guide/
