BRCGS Global Standard Food Safety: What Issue 9 Requires

If you supply a UK or Irish retailer with manufactured product, this is probably the standard you are audited against. It is also the standard most often referred to by the wrong name.

It is BRCGS, not BRC. The organisation was the British Retail Consortium when the standard launched in 1998, but it was sold in 2016 and rebranded to BRCGS, meaning Brand Reputation Compliance Global Standards, in 2019. Buyer specifications still say BRC out of habit. The certificate says BRCGS.

What the standard actually is

The BRCGS Global Standard Food Safety is a certification scheme for food manufacturers. It was the first scheme to be recognised by the Global Food Safety Initiative (GFSI) as meeting its benchmarking requirements, which is why it carries weight with buyers who never audit you themselves.

At its core it requires an effective HACCP based food safety plan built on Codex Alimentarius principles. Around that it wraps a quality management system, site standards, process controls and personnel requirements, so the audit covers the whole operation rather than just the plan.

The commercial reality is simpler than the technical description. Certification is how a retailer satisfies itself about a supplier it has never visited, and it is how you get listed.

What the audit covers

Issue 9 is organised into nine sections. A common mistake in supplier preparation is treating the first two as the whole standard, because the HACCP plan is the part people already understand.

1. Senior management commitment. Resources, accountability, food safety culture, corrective and preventive action. Auditors start here, and a weak answer sets the tone for the rest of the visit.
2. The food safety plan, HACCP based. Hazard analysis, critical control points, critical limits, monitoring, corrective action and verification. See our guide to identifying and monitoring CCPs.
3. Food safety and quality management system. Specifications, allergen management, product authenticity, traceability and mass balance, incident management, withdrawal and recall procedures.
4. Site standards. Layout, product flow, segregation, building fabric, maintenance, utilities, pest management, housekeeping.
5. Product control. Product design, packaging and labelling, allergen management, product release.
6. Process control. Control of operations, calibration, change control, weight and volume control.
7. Personnel. Training and competency, personal hygiene, protective clothing, medical screening.
8. Production risk zones. High care and high risk zone requirements, which apply where you handle ready to eat product.
9. Requirements for traded products. Applies where you sell product you did not manufacture yourself.

Sections 8 and 9 are the ones suppliers most often overlook, because they only apply to some sites. If they apply to yours, they are audited like everything else. Production risk zoning matters most in butchery and deli operations handling both raw and ready to eat product.

Grading and audit frequency

The audit is an announced or unannounced onsite assessment by an accredited third party certification body. The auditor examines documentation, observes operations, interviews staff across departments, and runs a timed traceability and mass balance exercise.

Non conformities are graded, and the number and severity of them determine your overall grade, which runs from AA down to D. A plus symbol after the grade indicates the audit was unannounced. Higher grades earn a twelve month audit cycle. Lower grades require more frequent auditing, and at the bottom of the scale a certificate is not issued at all.

Why buyers ask for it

Tesco, Sainsbury’s, Marks and Spencer and Waitrose all require food safety certification from suppliers, and BRCGS is the scheme most commonly named for manufactured product. Many also run their own additional programmes covering packaging, storage and distribution, and agents and brokers.

Two things follow from that:

• Ask before you certify. Confirm which scheme your target customer accepts. Certifying against the wrong one is an expensive lesson, and BRCGS is not always the answer. SALSA is designed for smaller producers supplying regional and independent retail, and is more proportionate for a small operation.
• Certification is not a legal requirement. Your legal obligation in Ireland and the UK is a HACCP based procedure under Regulation (EC) 852/2004. BRCGS is a commercial requirement imposed by customers. See HACCP certification for Irish food businesses for the difference.

Where sites actually lose marks

Not on hygiene. On records.

The traceability exercise is timed, and it is the moment paper systems come apart. An auditor picks a batch and asks you to trace it back to supplier lot and forward to customer, with quantities that reconcile. On paper that means delivery dockets, production diaries and dispatch notes on a table, cross referenced by hand, while somebody watches the clock.

The other recurring finding is gaps. An auditor selects a date at random and asks for the monitoring records for it. A folder with three unexplained empty weeks in March is a non conformity whatever the factory looks like on the day of the audit. Digital check sheets cannot have unexplained gaps, because every entry carries the time it was made and the person who made it.

Preparing for Issue 10

Until BRCGS publishes the final text, nobody outside the process knows what Issue 10 requires clause by clause. Commentary in circulation points towards more emphasis on food safety culture, environmental monitoring, digitalisation and audit transparency, but that is direction of travel rather than detail.

The practical position is straightforward. Prepare against Issue 9, because that is what you are audited against today. The work that pays off whatever the final text says is the same work either way: complete records with no gaps, a traceability exercise you can run inside the time allowed, and a food safety culture somebody can describe without reading from a folder.

See how three food businesses got there, or what it costs.

Frequently asked questions