Discover practical guidance from leading industry voices as we explore the requirements outlined in Section 4, Issue 9 of the BRCGS Global Food Safety Standard.

Auditable since February 2023, Issue 9 of the Global Food Safety Standard from BRCGS has dominated conversations surrounding food production and safety all year.

Engaging with such a large number of requirements and regulations can be overwhelming, especially if you are also dealing with the daily demands of factory life.

With this in mind, we decided to take a closer look at one key area: Section 4, Site Standards. Early BRCGS audit data suggests a number of sites are already struggling with compliance in this regard, so we have pulled together advice from industry experts to help you tackle some of the most common non-conformities.

From suitable equipment and temperature alarms to hygiene testing and cleaning validation, there is something to be gleaned from each expert. Alternatively, you can navigate the menu below and skip straight to the clause most relevant to your needs… 

Clause 4.6.2 – Katie Satterthwaite

As the Factory Standards Manager for Marks and Spencer, Katie is perfectly positioned to address the topic of finding the right equipment for your site.

Clause 4.11.3 – Phil May

Technical Support and Hygiene Manager for Greencore, Phil May shares his top tips for recording a validated clean.

Clause 4.11.3 – Nigel Church

Ensure acceptable levels of cleaning are carried out across your site with help from Nigel Church, Hygiene Manager for McCain Foods.

Clause 4.11.6 – Alex Carlyon and Foram Mehta

As the Global Standards Technical Manager at BRCGS, Foram Mehta is an expert in the latest standards and specifications. Joined by Klipspringer Director, Alex Carlyon, the two share their advice on finding hygienically designed equipment that is fit for purpose.

Clause 4.15.3 – Kenny Edwards

Quality Manager at Quorn Foods, Kenny Edwards draws on his experience working with the WatchmanOne wireless monitoring system. Find out how this system can help you to secure audit compliance.

Clause 4.6.2

This clause states that “equipment that is in direct contact with food shall be suitable for food contact and meet legal requirements where applicable.” The design and construction of this equipment must also be based on the risk of foreign-body, microbiological, or allergen contamination. 

Advice from Katie Satterthwaite:

Katie Satterthwaite is the Factory Standards Manager for Marks and Spencer. In September, she delivered a hugely successful talk on Hygienic Design at the Food Safety Innovation Conference 2023. In this talk she outlined the best approach to identifying and maintaining the hygienic design of your equipment – ensuring you are complying with the latest standards and specifications.

  • Design: proactive consideration of what the equipment is going to be used for. It needs to be fit for purpose. 
  • Build: the original manufacturer of your equipment needs to make sure they are following the relevant specifications.  
  • Validation: you need to make sure the equipment you have been supplied with is reflective of the latest guidelines and requirements.  
  • Installation: it’s important that the equipment is used in the way in which it was intended. It should also be easily accessible so that it can be cleaned on a regular basis. 
  • Factory Validations: you will need to carry out Cleaning and Process Validations. This will act as a record of your equipment consistently meeting the relevant standards. 
  • Operate and maintain: even if your equipment has been hygienically designed, you could still be at risk of non-conformity if your workforce has made inappropriate alterations. 
  • Change Control: any amends throughout the lifespan of your equipment need to be carefully considered and well documented.  

Clause 4.11.3

This clause states that “cleaning and disinfection procedures and their frequency shall be validated and records maintained.”

Advice from Phil May:

Technical Support and Hygiene Manager at leading manufacturer Greencore, Phil May has over twenty years of experience working in food factories. In the premiere episode of his podcast The Hygiene Hustle, Phil discussed the importance of hygiene operatives, the process of creating Cleaning Instruction Cards, and the best way to record a Validated Clean. 

  • Your Cleaning Instruction Cards need to have a record of the Validated Clean, otherwise your hygiene operatives won’t know the best way to manage the equipment at your site and it will be impossible for you to secure consistent results. 
  • If a piece of equipment is new to your site and you are trying to establish a Validated Clean, you should find a version of the equipment that is already in existence and already has a Cleaning Instruction Card. Perhaps a sister site started using the equipment before you, or maybe the supplier could source this information on your behalf. 
  • Most cleaning processes involve the same six steps, so it is likely that your Validated Clean will follow a similar pattern. In chronological order, the process is typically: rinse, chemical foam, manual agitation, second rinse, disinfection, and final rinse. 
  • If you are unsure about the details surrounding your Validated Clean, you should reach out to your cleaning supplier, as a lot of the major chemical companies employ application specialists. You could also speak to the manufacturer of your machine, as there might be a cleaning section in the manual or, at least, a very basic guide to stripping down and reassembling the relevant parts. 

Clause 4.11.3

This clause states that  “acceptable levels of cleaning may be defined by visual appearance, ATP bioluminescence techniques, microbiological testing, allergen testing, or chemical testing as appropriate.”

Advice from Nigel Church:

With nearly 40 years of industry experience, Nigel Church is a Hygiene Manager for McCain Foods. Working at the company’s Scarborough site, Nigel oversaw the move from ATP swabs to A3 technology. McCain Foods have used this new technology to ensure acceptable levels of cleaning have been carried out, achieving more accurate results and eliminating the possibility of false-positive readings.

  • When it comes to ensuring acceptable levels of cleaning have been reached across your site, it's important that you use the best methods available. In the interest of brand protection and customer satisfaction, McCain Foods switched from ATP swabs to an A3 meter.
  • Unlike traditional ATP swabs, the A3 meter detects ATP, ADP, and AMP. This means that even if ATP degrades to ADP or AMP during processes like fermentation or blanching, the A3 meter will still detect it. The presence of any of the three adenosine molecules directly correlates with the growth of bacteria and can be used as a clear indication of how well a surface has been cleaned.
  • You could also use A3 technology to reduce the cost of allergen testing at your site. Although A3 does not test for allergens, it does detect the presence or absence of organic residue. McCain Foods carried out a six-to-eight month trial and, in that time, if a surface passed an A3 test it would always pass a gluten swab or an ELISA test. This allowed the site to reduce the amount of allergen tests carried out, saving a significant amount of time and money.

Clause 4.11.6

A key requirement of this clause is that the cleaning equipment at your site needs to be “hygienically designed and fit for purpose.”

Advice from Alex Carlyon and Foram Mehta:

Cleaning Equipment Disinfectant

Foram Mehta is the Global Standards Technical Manager at BRCGS. Foram recently hosted a webinar in collaboration with Klipspringer, and in this webinar, she used early audit data to explore the root causes of the most common hygiene non-conformities. She also provided practical guidance for the best ways to avoid them. Cleaning Equipment was raised as an important topic of discussion, but one that is often overlooked.  

Cleaning Equipment Disinfectant

A proud partner in the webinar, Alex Carlyon is the Key Account Director at Klipspringer. Drawing on his years of experience supplying food and beverage factories across the UK and Ireland, Alex shared a series of top tips relating to the cleaning and maintenance of cleaning equipment, along with the importance of hygienic design.  

  • Cleaning your cleaning equipment is essential to audit compliance. Maintenance is also key, so you should be on the lookout for damage and scuffs on your brushes and squeegees, along with loose or missing bristles on your brushes. Leaving chemicals on your utensils, instead of rinsing them, can also have a detrimental effect. 
  • Don’t be afraid to challenge the supplier of your equipment when it comes to hygienic design. Most equipment will have been hygienically designed, but if you notice crevices or unnecessary small parts, you should find out why and push for them to be eliminated. 
  • Conduct an equipment review. Don’t wait for an audit to ask yourself if the equipment at your site is fit for purpose. Use the equipment review as an opportunity to engage with your supplier about any challenges currently impacting your cleaning processes. 
  • Don’t forget hard-to-reach areas. Auditors will be searching for hard-to-reach, inaccessible places, so you need to ensure your Hygiene Team has the right equipment to carry out a comprehensive clean. Whether that’s a flexible brush head for reaching around pipes or an extendable handle for your factory ceilings, your equipment needs to be fit for purpose. 
  • Take a step back and assess the different types of cleaning equipment available. You should be carrying out research to ensure you have the best options available for your site and that your equipment is in line with the latest industry standards.  

Clause 4.15.3

This clause states that “temperature alarms shall be fitted to all storage facilities or there shall be a system of recorded manual temperature checks, typically on at least a 4-hourly basis or at a frequency which allows for intervention before product temperatures exceed defined limits for the safety, legality or quality of products.”

Advice from Kenny Edwards:

Kenny Edwards is the Quality Manager at Quorn Foods. He recently managed the company’s transition to a WatchmanOne wireless monitoring system. Able to track factors such as energy, door contact, concentration, and humidity, the WatchmanOne system is also able to monitor temperature – setting off an automatic alarm if temperature falls or rises above your set parameters. 

  • To avoid confusion and promote accountability, you need to make sure any alerts are sent to the correct departments instead of everyone at your site. At the Quorn site, if an alarm is triggered, the system sends an email alert to two designated accounts: Quality Assurance and Engineering. 
  • Although Clause 4.15.3 allows for manual temperature checks, you should consider making the transition from paper checklists to a wireless system, as this will eliminate the hassle of paperwork, saving you time and money in the long run.
  • When it comes to monitoring factors like temperature, it's important that you have a clear and easily-accessible record for your customers and auditors. It's also vital that your operatives feel a sense of responsibility and any issues are resolved immediately. The WatchmanOne system requires your operatives to record any actions taken following an alarm. These records are retrievable, making it easier for you to prepare for auditors and deal with any customer complaints.  

With so many voices in the industry willing to share their expertise, there has never been a better time to engage with informative content such as the webinars and talks listed above. Instead of panicking about new standards and specifications, you should continue to seek out experts that have already resolved the issues you are facing or have identified opportunities to comply with some of the more challenging guidelines. 

Here at Klipspringer, we have spent over 20 years working with food and beverage production sites, so we are well placed to support you in your efforts to raise standards at your site and secure that all important audit compliance. If you would like any help in finding the right equipment, exploring a Wireless Monitoring System, or discovering the benefits of A3 testing, you can contact us on 01473 461800 or You can also fill out the contact form below.     

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