Auditable since February 2023, Issue 9 of the Global Food Safety Standard from BRCGS has already had a huge impact on the industry of food and beverage production. In a bid to secure audit compliance, along with customer satisfaction from the leading retailers, sites have displayed a growing interest in the most common non-conformities relating to this standard. 

When it comes to establishing these trends, it is relatively early days, with predictions based on just 40/50% of the expected data. Even so, it is still possible to create a tentative picture of the most common non-conformities and to establish the best methods for avoiding them. 

This was the key purpose of a BRCGS Webinar hosted on 8th November. Klipspringer was proud to partner in this webinar, with Foram Mehta, Global Standards Technical Manager at BRCGS, joined by our Key Account Director, Alex Carlyon. 

Together, Foram and Alex used BRCGS data to explore the root causes of each non-conformity, offering practical tips and techniques for overcoming them. 

You can scroll down to read our key takeaways from this webinar. Alternatively, you can navigate the menu below to skip straight to the section most relevant to your needs… 

What are the top hygiene non-conformities issued against BRCGS Food Safety Issue 9? 

The following requirement appears in Section 4.11 in Issue 9 of the BRCGS Global Food Safety Standard. It is also listed in Section 4.8 for the Packaging Materials Standard, and Section 6.4 for the Storage and Distribution Standard: 

Housekeeping and cleaning systems shall be in place which ensure appropriate standards of hygiene are maintained at all times and the risk of product contamination is minimised. 

Out of all the minor non-conformities raised so far, there have been more than 7,000 relating to Section 4.11. It is not only the top non-conformity for hygiene, but also the top non-conformity for Issue 9 overall.  

The top five non-conformities for hygiene relate to the following clauses:





Cleanliness of premises and equipment

Documented cleaning procedures

Cleaning equipment

Risk-based environmental monitoring programme

Cleaning performance limits

Clause 4.81 also shows up as one of the top non-conformities for Packaging, with Clause 6.41 the second most popular non-conformity for Storage and Distribution. 

These results are especially surprising because the wording of this clause hasn’t changed between Issue 8 and Issue 9 of the Food Safety Standard. This means that despite having plenty of time to meet this specification, sites are still struggling. 

“As an industry we’re so evolved, but we’re still getting something as basic as hygiene and housekeeping wrong.”  – Foram Mehta 

What are the root causes of the most common non-conformities? 

There are a number of explanations for the most common non-conformities, with ‘training’ being one of the most pertinent examples:

  • Training
  • Cleaning frequency
  • Incomplete records
  • Unclear work instructions
  • Incomplete checklists
  • Unsuitable cleaning equipment
  • Misinterpretation of the BRCGS standard
  • Inaccessible areas
  • Inadequate cleaning plans
  • Subpar risk assessments
  • Inadequate sampling plans
  • Incorrect storage of hygiene equipment

What can we learn from the most common non-conformities? 

As previously mentioned, these findings are based on just 40/50% of the relevant data, so there is still time for the trends surrounding non-conformities to change. But, as it currently stands, we can learn from the following takeaways: 

  • Despite the fact that the wording of Clause 4.11.1 hasn’t changed between Issue 8 and 9, hygiene continues to be a key area of non-conformance.
  • Hygiene Teams need to be more involved in the decision-making at your site. A lot of factories are currently failing to deliver on this point.
  • Basic hygiene standards are being overlooked. Emphasis needs to be returned to essential practices such as scrubbing floors, wiping down surfaces, and cleaning under machines. 
  • Instead of focusing on short-term factors like budget and deadlines, more emphasis needs to be placed on hygienic design, equipment choice, and driving hygiene standards.
  • People and culture need to be made a priorityYour team needs to be trained to identify and manage risk. 

So, how do I avoid these non-conformities?

Now that we’ve addressed the most common non-conformities raised by Issue 9, along with the possible root causes, it is time to offer some practical guidance on how best to avoid them. Drawing on Alex and Foram’s expert advice, below are six ways that you can ensure your site is meeting the standards outlined in the BRCGS Global Food Safety Standard.

1. Training, team engagement, and culture 

Culture can have a huge impact on the hygiene and housekeeping practices at your site. A positive culture will inspire your operatives – encouraging them to take accountability, engage with training, and strive for success. A negative culture will result in an unmotivated workforce that has no real incentive to care about good hygiene and the avoidance of non-conformities. 

If you are determined to nurture a positive culture at your site, you should work through the following steps: 

  • Don’t forget the ‘why’ behind everything you are doing. Every time you charge your operatives with a new instruction or expectation, explain the thought process behind each request.
  • Keep your processes as simple as possible. If your operatives judge it impossible to understand or keep up with your expectations, they are far more likely to dismiss them.  
  • Embrace the benefits of Visual Management. Use signs, videos, and even digital Cleaning Instruction Cards to ensure your operatives know what they should be aiming for. 
  • Equip your team with the right tools. Failing to do this could result in a number of non-conformities, with your hygiene team unable to carry out a thorough clean and production more likely to cut corners.
  • Carry out an internal Root Cause Analysis. This will allow you to treat the cause of any problems instead of the symptoms.  
  • Promote open and honest communication. Ask questions, welcome feedback, and adopt a curious mindset. It is also incredibly important that you listen to your Hygiene Team. 

2. Give Hygiene a voice at the table

It’s incredibly important that you are listening to your Hygiene Team and welcoming their feedback. If you are waiting until the team is already onsite to complete a clean, then you are leaving it too late. Your hygiene operatives should be involved through every step of the process, alerting you to any potential problems while there is still time to resolve them. 

Here are two ways that you can collaborate with your Hygiene Team:

First, you need to generate engagement at a senior level – encouraging your Senior Leadership Team to factor in the perspective of your Hygiene Team when they are making important decisions. This should have a trickle-down effect, with operatives at all levels picking up on the way in which hygiene has been prioritised.  

Second, it’s important that hygiene is involved in the scheduling and decision making at your site. From new equipment and the length of the hygiene window to the positioning of your production lines and the development of new products, a hygiene representative should be able to make suggestions and raise concerns from the very early stages.  

3. Make sure you get the basics right

One of the main takeaways from Issue 9 of the BRCGS Global Food Safety Standard is that sites are still struggling to master the basics in hygiene. As Foram explained, the wording of clause 4.11.1 hasn’t changed between issue 8 and 9, yet the highest number of non-conformities relates to the ‘cleanliness of premises and equipment’. That is why, before all else, you need to make sure that you are getting the basics right. 

Here are four ways for you to do just that: 

  • Make sure you have the right equipment for each task or process. Failing to cover off this basic point will make it so much harder for your operatives to work effectively. This is also an area that an auditor is going to notice immediately. 
  • Pay attention to hard-to-reach areas. Don’t be afraid to get down on your hands and knees to search under machines. You should also think about any voids behind the signs and boards mounted on your walls. 
  • Evaluate your colour-coding policy. Colour-coding is a subject that keeps coming up, a sign that it should be one of your top priorities and a key starting point for anyone looking to master the basic principles of running a site.
  • With labour becoming more expensive, there is a growing pressure to save money and speed up processes wherever possible. Even so, you need to ensure your hygiene team has enough time to do their job. 

4. Consider your Cleaning Equipment

With poor hygiene playing such a huge role in sites struggling with their audits, there has never been a better time for you to raise standards surrounding your cleaning equipment. Instead of relying on the same old utensils, you should be on the lookout for any opportunity to upgrade your processes and better support your Hygiene Team. 

Here are six ways for you to start this process: 

  • Clean your cleaning equipment. You should be training your operatives to correctly clean and maintain their utensils. Say you notice a brush with loose bristles – of course it will need to be replaced, but you should also update your training to make sure the brushes at your site aren’t being misused.
  • Embrace Hygienic Design. Most cleaning equipment will have been hygienically designed, but don’t be afraid to question your suppliers if you spot any crevices or harborages.  
  • Conduct an equipment review. Look over all the equipment at your site and identify any challenges or areas where you could be at risk of a non-conformance.  
  • Think about inaccessible and hard-to-reach areas. Auditors will be on the lookout for them, so you should be too. There will be a solution for every problem e.g. flexible high reach brushware for cleaning around pipes. 
  • Don’t pass the buck. If you are unsatisfied with the cleans at your sight, don’t just jump to blaming your operatives. First, you need to make sure they are working with the right equipment. 
  • Do your research. Stay abreast of industry standards and make sure you are aware of any new solutions that are worth exploring.  

5. Prioritise your Walls and Ceilings

Walls and ceilings are highly visible. In fact, they are likely to be noticed by your auditor the second they enter your site. If you are going to make a good first impression, this aspect of your factory can’t be overlooked. Instead, the effective cleaning of your walls and ceilings should be a priority. After all, some of the top non-conformities raised by Issue 9 relate to the cleaning of inaccessible areas and the frequency of these cleans.  

Here are two points for you to consider as you assess your walls and ceilings:  

Firstly, you need to evaluate your wall fixtures. Everything you fix to a wall creates a void behind it that needs to be cleaned. Depending on the fixtures you use, you could also be penetrating the wall and creating an additional harborage point. If you then move your sign or board, these harborages will need to be dealt with appropriately. A great solution to this is magnetic mounting – suited to Shadow Boards, PPE dispensers, shelves, and signage. A wall hanging with a magnetic mounting can be easily moved for every clean and relocated if you move one of your lines. 

Secondly, you need to use equipment that has been designed with ceilings and walls in mind. The angles and ergonomics of a traditional brush aren’t suited to walls and ceilings, so it’s important that your hygiene team isn’t using them across the board. Instead, they should have access to high reach equipment that is specifically suited to this task.  

6. Maintain and Sustain Good Practice

Finally, you need to make sure that the good practice at your site is maintained. There is no point in temporarily raising standards, just for them to drop as soon as you step away from the factory floor or enter a particularly busy production period.  

If you are determined to make long lasting, positive changes, you should work your way through the following four steps: 

  • Make it easy to do the right thing. From Shadow Boards and brightly coloured signage to regular training and ergonomic equipment, make sure you are supporting your team at every turn. 
  • Remember: this isn’t a tick box exercise. Only make changes to your site if you have an in depth understanding of the steps you are taking and genuinely believe they are suited to your site.  
  • Introduce visuals to your site. Don’t be too text heavy in your approach – it will be easier and quicker for your operatives to retain information if they have access to helpful photos and videos. 
  • Keep your records up to date. This will make things so much easier when it comes to providing your auditors with evidence. It will also help you to hold your operatives accountable.  

Frequently Asked Questions

If you still have questions surrounding the non-conformities raised by Issue 9 of the BRCGS Global Food Safety Standard, it is possible they were answered by Foram and Alex in the recent webinar.

Below are the queries that were raised, along with some practical advice for each point:

How do I get the Senior Leadership Team to recognise the importance of hygiene?

  • Open and honest communication
  • Make sure Senior Leadership Team understands what takes place during a typical hygiene shift
  • Develop a positive culture on site and make sure any small wins are celebrated

A lot of the weaker areas of hygiene could be helped by more investment, but budget is directed elsewhere. How do I secure the funds I need?

  • Katie Sattherthwaite delivered a compelling argument for investing in Hygienic Design at the Food Safety Innovation Conference 2023. Click here to discover her key points.
  • Make sure those in charge of the budget are aware of the consequences of poor hygiene. Exploring what could go wrong is often the most effective way to justify investment.
  • Explain that there will be a return on this investment, as the business will need fewer hygiene operatives or require their services for less time. The site will also be more likely to achieve a consistently good result.

We have a lot of agency staff at our site, along with people who don’t have English as their first language. What is the quickest and easiest way to train them?

  • Make it visual – from highly visual signs and instruction boards to step-by-step photos on your Cleaning Instruction Cards, you should introduce visual aids as much as possible.
  • Try to view the time you take to train your staff as an investment rather than a drain. In the long-term it will save you a significant amount of time and money.

I’m worried that my operatives won’t use Shadow Boards. How can I overcome this?

  • Engage with your staff throughout the process. Ask for input when commissioning the Shadow Boards and explain the ‘why’ behind this new introduction to your site.
  • Don’t get Shadow Boards for the sake of it, make sure they are the perfect fit for your site.
  • Make sure your Shadow Boards have the right products in the right place. If they make life easier for your operatives, they are much more likely to get used.

Is magnetic mounting only for lightweight items?

  • A typical magnet on a board will hold around thirty kilos, so it is rare for us to come across something that can’t be held in this way. Magnetic mounting can be used for Shadow Boards, cable trays, shelves, notice boards, KPI boards, and more.

You highlighted the importance of cleaning my cleaning equipment. What is the best approach?

  • This will be different depending on the equipment you’re trying to clean.
  • Reach out to your supplier for advice.
  • Make sure your equipment isn’t worn or broken, as this will make it impossible for you to achieve a good clean.
  • The cleaning of your cleaning equipment is just as important as the cleaning of your food contact equipment.

Is it good practice to keep cleaning equipment in disinfectant?

  • No, a static disinfectant in a pot is going to attract debris. It will also raise questions about how often it is replaced, what conditions it is kept in ect…
  • Alkaline chemicals could reduce the lifespan of your equipment and increase the risk of foreign body contamination.

What is the best way to give Hygiene a voice at the table?

  • Make the most of their knowledge e.g. for the writing of Cleaning Instruction Cards.
  • Ensure they are part of the decision making process e.g. investment in new equipment and length of hygiene window.
  • Hygiene Managers are experts in keeping up with regulations, so use their input when establishing your HACCP plan.
  • Invite hygiene representative to HACCP team meetings, Production huddles ect… to encourage collaboration.

Will allowing my floor cleaning equipment to touch the floor during storage raise a non-conformance even if it is segregated and colour-coded?

  • Allowing any cleaning equipment to touch the floor creates a harbourage point for insects and even rodents.
  • Anything touching the floor is likely to raise a non-conformance.
  • Although BRCGS doesn’t insist on Shadow Boards, this storage solution is becoming more and more popular.

So there you have it, the most common non-conformities raised by Issue 9 of the BRCGS Global Food Safety Standard, the possible root causes behind these non-conformities, and the best ways to avoid them. We hope this has provided a strong starting point for you in terms of establishing a plan for your site. We will, of course, be updating our content to reflect any new data, so don’t forget to check in with the Klipspringer Content Hub. Our team is also available to answer any of your queries surrounding the best solutions for common, or even those slightly more unusual non-conformities, so please do contact us on 01473 461800 or Alternatively, you can fill out the contact form below and one of our friendly team members will be in touch.

If you would like any further guidance relating to the solutions mentioned in this article, the Klipspringer team would be happy to help. Simply enter your details below for a free consultation.