ISO Compliance Insights & Best Practices
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ISO Compliance Insights & Best Practices
A BRCGS audit checklist is only useful if it tests what the auditor tests. Copying clause headings into a spreadsheet and ticking them is not enough. That only checks that a document exists. It does not check that the site does what the document says.
This guide sets out a better approach: a self-assessment that scores every clause, and a split between records and the factory floor that mirrors how the audit is built. It is independent of BRCGS. The Standard, with a free PDF listed on the BRCGS site, is at brcgs.com. For the scheme as a whole, see BRCGS certification.
Part II of the Standard marks every requirement with a colour code. In our words, each requirement is for records and documents, or for production facilities and good manufacturing practice, or for both. Part III uses the same marking to decide what is audited where.
Two consequences follow:
Whatever the marking, three things are always examined on site: a walk-round for good manufacturing practice, how the food safety system and the HACCP activities are implemented, and the traceability challenge. Build your checklist around those three.
The colours are printed in the PDF of the Standard. Mark your own copy as you read it, and keep the clause-by-clause mapping with your checklist.
The Standard has 328 clauses with requirements and 57 statements of intent. A useful self-assessment scores all of them. Use three scores:
Then add the three columns that make the checklist yours: owner, evidence reference and date last tested. A tick without an evidence reference is an opinion.
Score the statements of intent separately. They are audited in their own right, and twelve are fundamental. A group of clauses that are each partly met can add up to a failed intent. For that reason, read the twelve before you start the rest. See BRCGS fundamental clauses.
Finally, translate the counts into a likely grade using BRCGS audit grades. Fifteen partly met clauses is not a crisis, and six majors is.
These are the questions that can be answered at a desk. For each one, check the record exists and that the date shows the activity actually took place when it should.
| Area | Clause | What the record must show |
|---|---|---|
| Culture plan | 1.1.2 | Reviewed and updated annually, with activities, action plan and effectiveness review |
| Objectives | 1.1.3 | Results reported to senior management and all staff each quarter |
| Management review | 1.1.4, 1.1.5 | Annual review, and a monthly meeting programme to senior management |
| Flow diagram | 2.6.1 | Verified on site annually and at process change |
| HACCP and prerequisites | 2.12.3 | Reviewed annually and before relevant change |
| Record retention | 3.3.2 | Shelf life plus 12 months |
| Internal audit | 3.4.1 | At least four dates in the year, and each activity audited once a year |
| Raw material risk assessment | 3.5.1.1 | Updated at least every three years and on triggers |
| Specifications | 3.6.4 | Reviewed at least every three years |
| Traceability test | 3.9.3 | Done at least annually, with mass balance and a summary of linked documents |
| Incident and recall test | 3.11.3 | Tested at least annually |
| Food defence | 4.2.2, 4.2.3 | Plan and controls reviewed annually |
| Water analysis | 4.5.1 | As the law requires, or annually |
| Pest management | 4.14.10, 4.14.11 | Expert assessment annually, and trend analysis annually or on infestation |
| Fraud vulnerability | 5.4.3 | Assessment plan reviewed annually and on triggers |
Two traps catch sites here. First, the internal audit clause holds two tests, not one. Second, monthly hygiene and fabrication inspections (3.4.4) are a separate programme and do not substitute for internal audit.
Where a clause says the site sets the frequency, the auditor will expect a defined, documented rate. The phrase “regularly” in your procedure is not a rate. Give each activity a stated interval.
Walk the site as an auditor would, at a working time, in each area. Take the checklist with you and a second person to challenge your marks.
| Area | Clause | What to see and test |
|---|---|---|
| Site map and flow | 4.3 | People and product move as the map says |
| Metal detection or x-ray | 4.10.3.4, 4.10.3.5 | Moving test packs and failsafe checks; in-line units tested at start-up and end of production, others at your set frequency |
| Container cleaning equipment | 4.10.6.2 | Checked each production |
| Cleaning | 4.11 | Equipment and areas clean at the time of the walk, not after a clean-up |
| Storage temperature | 4.15.3 | Manual temperature checks, typically four-hourly, or often enough to intervene |
| Allergen controls | 5.3 | Segregation and changeover as described in the procedure |
| Pack and label checks | 6.2.3 | Checks at start, during the run, at batch change and at end of run |
| Online verification equipment | 6.2.4 | Tested at run start and end, and between at a risk-based rate |
| Plasters | 7.2.4 | Each batch tested through the detector |
| Footwear and clothing | 7.4.2 | Appropriate footwear issued and worn |
| Zone clothing change | 8.7.3 | High-risk and high-care clothing changed daily |
Ask operators, not only supervisors. Why do you take this reading? What do you do if it is out of limit? Where is the record? An operator who can answer in their own words is better evidence than a perfect log.
Look also for the unglamorous items: any snap-off knife in use, since 4.9.2.1 bars them everywhere, a record missing where no breakage occurred (4.9.4.3 still wants one), a pest report that is a list of visits with no trend. They are easy to overlook in a self-assessment.
The best test of the whole system sits between the two halves. Pick a finished batch and follow it back through the records and the floor.
Our posts on the traceability system and the product recall procedure cover the generic side. The same discipline applies to a food defence and fraud check: see food fraud and food defence.
Treat each gap as a non-conformity from the day you find it. Give it a level (critical, major or minor in the Standard’s terms), an owner, a due date and a verification step. Log it in the same place you will log the certification body’s findings, so the habit is already built when the real audit arrives.
Keep the old versions of the checklist. The change from one run to the next shows an auditor that the system learns, and it shows you which areas keep slipping. If the same clause is partly met three runs in a row, the fix is not working.
Run the full assessment once, at least a few months before the audit window. Then repeat the high-risk parts as you close gaps. A site that opens a new unit should wait: Part III warns that under three months of operation is unlikely to show compliance.
For an unannounced audit, treat the checklist as permanent. You will not know the day, and on the voluntary programme the facility inspection is expected to start within 30 minutes of the auditor arriving. Read our guide to the BRCGS unannounced audit.
The BRCGS Food Safety Toolkit has 123 templates, 78 in Word and 45 in Excel, for $149. For this work you want the Issue 9 Self-Assessment and Implementation Roadmap, the Internal Audit Programme, Report and Checklist, the Hygiene and Fabrication Inspection Programme and the Audit Preparation and Audit Day Procedure.
Sample pages from the toolkit: Issue 9 self assessment; Competency matrix and training; Cleaning and disinfection procedure.
The Standard itself is the reference, and BRCGS lists a free PDF on its website. Any checklist you use should be built from the clauses and marked with your own evidence.
That depends on the size of the site and the state of its records. The reliable measure is whether every clause has an owner, a score and an evidence reference.
No. Internal audit has its own requirements: at least four dates in the year and every activity covered annually. A checklist run helps, but it does not replace the programme.
Only if they apply. Section 8 applies when your assessment finds that any of the three kinds of controlled zone are needed. Section 9 applies when traded products are in scope.
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