BRCGS has released its data on the most common non-conformities issued against Issue 9 of the Global Food Safety Standard. In this article, we take a look at some of the key takeaways so far.

In a recent BRCGS webinar, Foram Mehta, the organisation’s Technical Manager, provided an in depth review of the most common non-conformities to be issued so far against Issue 9 of the BRCGS Global Food Safety Standard. Foram revealed that, since the issue’s release in February 2023, there have already been more than 100,000 non-conformities raised. This shows there is still plenty of room for improvement, with a lot of sites falling down at the same five hurdles.

In this article we will be providing a rundown of the data and guidance shared by Foram – covering one of the most popular major non-conformities, along with all five of the top minor non-conformities presenting so far. We will also be exploring the importance of root cause analysis and explaining what you should do if you are issued with a non-conformity. As you can imagine, there is valuable information in each of these sections, but if you would like to skip ahead to a specific subject, you can do that using the links below.

What are the top major non-conformities for Issue 9 so far?

To provide accurate feedback on the most common major non-conformities for Issue 9, BRCGS would need access to at least a year’s worth of data. Major non-conformities (NCs) are less regular than minor non-conformities, so it is a lot harder to make predictions.

However, it is worth noting that the top major NC so far is Clause 1.1.10 – a clause with wording that hasn’t changed between Issues 8 and 9 of the Global Food Safety Standard.

The clause states that:

"Where the site is certificated to the Standard, it shall ensure that announced recertification audits occur on or before the audit due date indicated on the certificate."

This means that sites are still struggling with one of the most fundamental aspects of the auditing process. If you are determined to avoid this issue, you should start by working through the following points:

  • Remember: it is a site’s responsibility to ensure the recertification audit is scheduled before the due date. Everyone involved in the audit should be aware of this date – especially your admin team.
  • Keep a record of the paperwork submitted and the steps taken to arrange your audit. This could be evidence if a query is raised.
  • If there is an error on the side of the Certification Body, your site should not be penalised. However, it is still a good idea to check in with your auditors if you believe your visit has been overlooked.

What are the top minor non-conformities for Issue 9 so far?

It is easier to predict the trends surrounding minor non-conformities as they occur on a more regular basis. This has allowed BRCGS to share the top five minor NCs so far:

Interestingly, three out of the five clauses feature the same wording as they did in Issue 8 of the Global Food Safety Standard. It is just Clause 4.6.2 where the wording has changed substantially, and Clause 4.9.1.1 where the wording has received slight alterations. As with the most common major NC, this trend suggests that sites are still struggling with the same issues as they were when Issue 8 was first released.

1. Clause 4.11.1

"The premises and equipment shall be maintained in a clean and hygienic condition."

It is fairly unsurprising that the top minor non-conformity relates to hygiene, as a similar trend has been found with the BRCGS Standards for Packaging Materials and Storage and Distribution. The second highest NC for storage relates to hygiene, as does the very top NC for packaging. Essentially, hygiene is trending across the board.

Another noticeable trend is that there is a fairly even balance between non-conformities relating to the hygiene of equipment and the hygiene of premises. Sites appear to be struggling in both areas, rather than just one.

So why is this?

  • Increased production demands
  • Staff shortages
  • Non-production areas are going overlooked
  • Hard-to-reach areas are going overlooked
  • Sites are taking the basics for granted
  • An increased number of unannounced audits. Sites are preparing the relevant documentation, but are getting caught out by day-to-day activities

So what’s the solution?

The clauses in the BRCGS standard usually inform one another – it is unlikely that you will excel or fail in one area without this having a noticeable impact on the other aspects of your operation.

With this in mind, you should draw on the guidance provided in other clauses when tackling the expectations of Clause 4.11.1:

Clause 1.1.2: “The site’s senior management shall define and maintain a clear plan for the development and continuing improvement of a good safety and quality culture.” 

Clause 4.11.2: The frequency of methods of cleaning shall be based on risk. 

Clause 4.11.4: “Cleaning staff shall be adequately trained.”

Clause 3.4.4: “There shall be a separate programme of document inspections to ensure that the factory environment and processing equipment are maintained in a suitable condition for food production.”

Using these guidelines, it is possible to establish the following action-points:

  • A positive culture comes from the top down. Your Hygiene Team needs to have a voice at the table and should have a say in important decisions.
  • Risk assessment should play a starring role in your site management. With every new piece of equipment and every new process, you should be thinking about the risks involved, along with the best strategies for minimising them.
  • Make sure your staff have received the relevant training. This should be an ongoing process.
  • Carry out regular inspections of your site. The official guidance for this is once a month or on a risk-based schedule.

If you haven’t already, you should also make use of the BRCGS Interpretation Guideline, as this resource contains a lot of guidance relating to the development of an effective cleaning procedure. It will also help you to turn the specifications within Issue 9 into a fail-proof plan.

2. Clause 4.9.1.1

"Processes shall be in place to manage the use, storage, and handling of non-food chemicals to prevent chemical contamination."

As previously mentioned, the wording of this clause has remained almost entirely the same since Issue 8. However, there have been two new examples added to the list of processes that need to be in place:

  • Procedures to manage any spills
  • Procedures for the safe, legal disposal or return of obsolete or out-of-date chemicals and empty chemical containers

So, if the wording of this clause is so similar to the wording of Issue 8, why are sites still receiving non-conformities in this areas?

As it stands so far, a lot of the NCs in this area relate to:

  • A failure to keep the doors to the chemical storage locked
  • Operatives without authorised access entering the areas where the chemicals are stored
  • The inadequate training of operatives handling these chemicals
  • The inadequate labelling of non-food chemicals
  • Inappropriate or inadequate storage
  • Sites struggling to understand how to properly dispose of empty chemical containers

When it comes to tackling this issue, the first place to look is at the Material Safety Data Sheets (MSDS) that come with the non-food chemicals delivered to your site. Here you should find a lot of guidance relating to the proper storage of your chemicals and the best way to dispose of your empty containers.

You should also consider contacting your suppliers directly to see if they have any training resources available or any suggestions in regards to storage and labelling. Another idea is to reach out to your local authorities, as they will be able to warn you against any issues surrounding the disposal of your containers.

Finally, you should consider adding this point to the regular hygiene checks mentioned in the previous section. This will prevent it from going overlooked. The same could be said for a root cause analysis, something that should be carried out if your internal inspections detect any issues that are yet to be resolved.

3. Clause 4.6.2

"The design and construction of equipment shall be based on risk, to prevent product contamination."

As the only new requirement featured in the top five minor non-conformities, Clause 4.6.2 is an important one to understand.

It’s quite normal for a clause that has received significant changes between issues to appear as one of the more common non-conformities. Until the next issue of the Food Safety Standard is released and enough data becomes available, it will be hard to tell if this is an ongoing area of concern or just teething problems as sites adjust to the new expectations.

Common non-conformities in this area include:

  • Rust
  • Flaking paint
  • Broken parts
  • Unsuitable welds and joints

There are a number of ways for you to avoid this non-conformity:

  • Clause 4.6.2 places particular emphasis on the equipment that comes into direct contact with food. You should make this equipment your priority – evaluating its design to make sure there are no trap points, harbourages, or foreign body risks. It should also be made from smooth, non-porous materials. Finally, your equipment needs to be fit for purpose and easy to clean.
  • It’s important that you schedule in regular inspections of your equipment and encourage your operatives to take care over its maintenance. This should reduce the risk of an auditor spotting broken or damaged parts.
  • An auditor won’t have time to look at all the equipment on site. Instead, they will inspect a small sample, and direct most of their attention towards your factory’s processes. They will want to find out your approach to evaluating equipment before it is introduced and will be interested in how it is maintained. Make sure your HACCP team is involved in this process.
  • The design and construction of your equipment could be another point to add to the hygiene and housekeeping inspections referenced under Clause 3.4.4. This will make it easier for you to keep an eye on this essential aspect of your operation.

4. Clause 4.4.8

"Doors (both internal and external) shall be maintained in good condition."

Despite being a clear sign of a site’s standards, doors are an ongoing issue in terms of audit compliance. As a primary point of access and an external barrier to the outside world, this is a real oversight. The doors at your factory need to be:

  • Close fitting
  • Pest proof
  • Well maintained
  • In good working order
  • Closed during production

Instead, audits since February 2023 have found that a concerning number of doors are:

  • Damaged
  • Not sealed properly
  • In need of maintenance that is yet to be carried out
  • Left open during production

If you are concerned about the doors at your site, it’s important that you:

  • Make sure any repairs are addressed promptly. Speak with your maintenance team and establish a plan of action. You should also consider introducing a Wireless Monitoring System to your site, as this can be used to automatically track door contact – sending alerts if any incidents occur.
  • Preventative maintenance is equally important. Instead of your maintenance team waiting for issues to occur, they should be working to protect the integrity of your doors from day one.
  • Once again, you can add this point to your hygiene and housekeeping inspections. You should try to ensure these inspections are carried out by a variety of team members from different departments, as mixing up the inspectors will introduce a fresh set of eyes each time.

5. Clause 4.4.1

"Walls shall be finished and maintained to prevent the accumulation of dirt, minimise condensation and mould growth, and facilitate cleaning."

Perhaps even more so than the doors of your factory, the walls of your site are impossible to overlook. Even so, a number of sites have been struggling with this issue across both Issues 8 and 9 of the BRCGS Global Food Safety Standard.

When it comes to the walls themselves, you could avoid this non-conformity by evaluating their design. The structure and materials need to be hygienic and suited to the demands of a working factory. As with all of the previous points, regular inspections will be a valuable tool – helping you to identify any areas where the walls are damaged or degraded.

It is also vital that you consider what is hanging on your walls, as this is an area where a lot of sites are getting caught out. From shelves and shadow boards to signage and PPE dispensers, these additions need to be hygienically designed and inspected on a regular basis.

Collaborating with your Hygiene Team is another vital step, as they will be tasked with cleaning these wall hangings and should be alerted to the tricky spaces behind them. As a common hiding spot for pests, condensation, and mould, these spaces need to be dealt with by your team before they are uncovered by an auditor.

The role of root cause analysis

The term root cause analysis appears throughout Version 9 of the Global Food Safety Standard. In fact, it is such an important topic that BRCGS has published its own guideline to carrying out this process. If you are a certificated site, you will have access to the Participate Platform where this guideline is hosted.

In the meantime, a good place to start is The Five Whys Technique, with this technique encouraging you to move past common mistakes such as blaming your operatives and to keep asking ‘why?’ until you have figured out exactly what caused an issue to occur and what needs to be done to prevent it from happening again. Here is an example of this principle at work:

A brush bristle made its way into a product.

Why?

An operative was using the brush and a bristle came loose.

Why?

The brush was old and had degraded over time.

Why?

The last equipment inspection was missed and the brush had been stored incorrectly.

Why?

It’s not clear who is responsible for the inspections and there are no suitable storage solutions present on site.

Why?

A chain of command needs to be established and the site needs to invest in proper storage.

It might not always be necessary to ask ‘why?’ the full five times, especially if you develop a talent for identifying the true root cause of a situation. However, pushing your team to keep asking questions until a suitable solution is found, should prove invaluable when preparing for an audit.

What should you do if you receive a non-conformity?

You need to establish a positive relationship with your auditing body – welcoming feedback and any suggestions for the enhancement of your site. This open-minded approach will become especially important if your factory is faced with a non-conformity. Instead of losing momentum, it’s important to remember that there is still plenty that you can do to resolve the situation. You can start by working your way through the following points:

  • If your site receives a non-conformity, you have 28 days to successfully resolve it. If you are able to do this within the given time period and the evidence you provide is accepted by your auditor, you will be able to close the non-conformity.
  • During these 28 days, you will need to submit a root cause analysis, along with a record of the preventative action that has occurred.
  • If you are unsure, you can reach out to your certification body. But, it’s important to note that you are expected to be an expert in your own operation and should be able to carry out your own root cause analysis.
  • If you are unable to close a non-conformity within the 28 days, you should expect it to be raised at your next audit. Your inspector will want to go over your root cause analysis and see evidence of your preventative action.

Preparing for an audit can be extremely intimidating. However, thanks to guidance provided by BRCGS and its transparent approach to sharing early trends, this doesn’t have to be the case. Instead, you have an opportunity to learn from the data provided – using the top non-conformities to inform your strategy.

From taking a closer look at your walls and doors to scheduling in regular inspections for your premises, equipment, and non-food chemicals, there are a number of ways to avoid the most common issues. Even a quick chat with your admin team to remind them of your audit due date could make all the difference, so why not add that to the top of your to-do list?

Here at Klipspringer, we have been helping sites to secure audit-compliance for over 20 years. Our friendly team is always on hand to provide support and guidance, so you are welcome to contact us on  01473 461800 or sales@klipspringer.com. Alternatively, you can fill out the form below.  

If you would like further guidance relating to the solutions outlined in this article, the Klipspringer team would be happy to help. Share your details below to arrange a free consultation.