Top 5 BRCGS Food Safety Non-Conformities and How to Avoid Them
BRCGS food safety requirements are stringent and extensive, so it can be challenging to ensure total compliance. One strategy to avoid non-conformities is learning from common mistakes. The BRCGS 2022 Compliance Report identifies the non-conformities found most frequently during over 22,000 audits. This article will cover the top 5 most common non-conformities, provide insights into each, and offer practical tips to help you maintain compliance and avoid these common pitfalls.
Top 5 BRCGS Non-Conformities
The top 5 most common areas of non-conformity (in order of most common to least) with the BRCGS Food Safety Standard are:
Clause 4.11.1 Premises and Equipment Hygiene
Clause 4.6.2 Equipment Construction and Maintenance
Clause 4.4.8 Door Condition
Clause 4.9.1.1: Non-Food Chemical Management
Clause 4.4.1: Wall Condition
By understanding these common issues, you can proactively address potential weaknesses in your operations.
Clause 4.11.1 Premises and Equipment Hygiene
"The premises and equipment shall be maintained in a clean and hygienic condition."
Requirements: Clause 4.11.1 mandates that both the premises and equipment within a food processing facility must be kept clean and hygienic at all times. This includes regular cleaning schedules, proper sanitation practices, and maintenance routines to prevent contamination by pathogenic microorganisms.
Examples of Non-Compliance:
Inadequate cleaning schedules leading to dirty equipment and premises.
Poor maintenance of non-production areas resulting in neglect and hygiene issues.
Overlooked hard-to-reach spots where dirt and contaminants can accumulate.
Compliance Strategies:
Regular Cleaning: Establish and adhere to a strict cleaning schedule based on risk assessments. Ensure that all areas, including non-production spaces and hard-to-reach spots, are regularly cleaned.
Hygiene Training: Provide continuous training for all staff members on proper hygiene practices and the importance of maintaining cleanliness.
Inspections: Conduct frequent inspections to monitor hygiene standards and identify areas needing attention. Document these inspections and any corrective actions taken.
Risk Assessment: Prioritize areas and equipment based on contamination risk. Implement cleaning methods that effectively address these risks.
Culture of Cleanliness: Promote a positive hygiene culture starting from top management. Engage the hygiene team in decision-making processes to emphasize the importance of cleanliness throughout the facility.
Clause 4.6.2 Equipment Construction and Maintenance
"The design and construction of equipment shall be based on risk, to prevent product contamination."
Requirements: Clause 4.6.2 requires that both new and existing equipment in a food processing facility be designed and constructed with a focus on minimizing contamination risk. This involves evaluating the design of equipment to ensure it can be easily cleaned, preventing the accumulation of contaminants, and selecting appropriate materials.
Examples of Non-Compliance:
Presence of rust, flaking paint, and broken parts on equipment.
Inadequate welds and joints that are not easily cleanable.
Equipment made from materials that are not suitable for food contact.
Compliance Strategies:
Risk-Based Design: Prioritize the design of equipment that minimizes contamination risk, ensuring that surfaces are smooth, non-porous, and easy to clean.
Regular Inspections: Conduct routine inspections to identify and address potential issues such as rust, peeling paint, broken parts, and improper welds.
Maintenance Plans: Implement a proactive maintenance schedule to prevent equipment deterioration and ensure that all repairs are carried out promptly and effectively.
Sanitation Integration: Involve the sanitation team in equipment design and maintenance decisions to ensure that cleaning requirements are fully considered.
Training: Provide training for staff on proper equipment maintenance and the importance of adhering to cleaning procedures to prevent contamination.
Clause 4.4.8 Door Condition
"Doors (both internal and external) shall be maintained in good condition."
Requirements: Clause 4.4.8 mandates that all doors in a food processing facility, both internal and external, must be well-maintained. This includes ensuring doors are properly sealed, free from damage, and in optimal working condition to maintain a clean environment and prevent pest entry.
Examples of Non-Compliance:
Doors that are poorly sealed, damaged, or not maintained.
Doors left open during production hours, compromising the clean environment.
Lack of regular inspections and repairs for doors.
Compliance Strategies:
Preventative Maintenance: For dock doors, implement a schedule for regular maintenance to ensure seals are replaced if required as a result of normal wear and tear, and doors are adjusted if they do not close properly'.
Prompt Repairs: Address any damage or maintenance needs immediately to prevent further deterioration and potential non-compliance.
Monitoring Systems: Consider installing a Wireless Monitoring System to automatically track door activity and receive alerts for any issues, such as an outside door not closing properly.
Team Training: Ensure the maintenance team is aware they hold primary responsibility for identifying non-compliant doors, and is trained to recognize defective doors. Train staff using pictures that clearly define what is acceptable / compliant.
Clause 4.9.1.1: Non-Food Chemical Management
"Processes shall be in place to manage the use, storage, and handling of non-food chemicals to prevent chemical contamination."
Requirements: Clause 4.9.1.1 requires that food processing facilities establish and maintain processes to manage non-food chemicals properly. This includes safe use, storage, and handling to prevent contamination of food products. Proper procedures must also be in place for the disposal or return of outdated chemicals and empty containers.
Examples of Non-Compliance:
Unlocked chemical storage doors allowing unauthorized access.
Incorrect or missing labels on non-food chemical containers.
Improper disposal of empty chemical containers and outdated chemicals.
Compliance Strategies:
Safe Storage: Ensure all non-food chemicals are stored in designated areas.
Proper Labeling: Label all chemical containers clearly and accurately to avoid misuse and contamination.
Training Programs: Provide comprehensive training for all personnel handling chemicals to ensure they understand proper procedures and safety measures.
Disposal Procedures: Establish and follow protocols for the safe and lawful disposal of outdated chemicals and empty containers, complying with local regulations.
Spill Management: Implement protocols for managing chemical spills, including immediate clean-up and reporting procedures.
Regular Audits: Conduct regular audits to verify compliance with chemical management procedures and address any identified issues promptly.
Clause 4.4.1: Wall Condition
"Walls shall be finished and maintained to prevent the accumulation of dirt, minimize condensation and mold growth, and facilitate cleaning."
Requirements: Clause 4.4.1 requires that walls in food processing facilities be properly finished and maintained. This includes ensuring walls are clean, free from dirt and condensation, and constructed to minimize mold growth. Proper maintenance of wall surfaces is crucial to support hygiene standards and prevent contamination.
Examples of Non-Compliance:
Accumulation of dirt and debris on walls.
Condensation and mold growth due to inadequate moisture control.
Damage to wall surfaces that is not promptly repaired.
Compliance Strategies:
Regular Cleaning: Implement a cleaning schedule to ensure walls are regularly cleaned and free from dirt and debris.
Moisture Control: Use materials and finishes that minimize condensation and mold growth. Ensure proper ventilation and humidity control in the facility.
Routine Inspections: Conduct regular inspections to identify areas where dirt, mold, or moisture might accumulate. Address any issues promptly.
Repair and Maintenance: Repair any damage to walls immediately to prevent further deterioration. Use appropriate materials that are easy to clean and maintain.
Employee Training: Train staff on known potential issues with wall maintenance and sanitation so they can be the 'eyes' of the company and support the efforts of the sanitation and maintenance teams.
Partner with QIMA/WQS for BRCGS Certification
Partnering with QIMA/WQS for your BRCGS certification provides you with expert guidance and support throughout the certification process. Our auditing services help you navigate the complexities of BRCGS standards, ensuring your operations meet the highest food safety and quality requirements – and avoid common non-conformities.
Contact us to learn more about BRCGS certification or book an audit today.
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