Site Standards: Utilities – Water, Air, and Energy

Aligned with BRCGS Food Safety Issue 9 – Clause 4.5

Requirement Overview

BRCGS Clause 4.5 requires that all utilities (including water, compressed air, gases, and energy sources) which come into direct or indirect contact with food or food contact surfaces must be monitored, maintained, and controlled to prevent contamination and ensure food safety.

Clause 4.5.1: “Utilities used within the production and storage areas shall be constructed, located and maintained to minimize the risk of product contamination.”

Clause 4.5.2: “The quality of air or other gases (including steam and compressed air) that come into contact with food or food-contact surfaces shall be monitored to ensure it does not pose a contamination risk.”

Utilities are often overlooked in routine maintenance, but failures in utility safety can introduce foreign materials, chemical residues, or microbial contaminants into your product or environment.

Aligned with BRCGS for Storage & Distribution Issue 4 – Clause 4.3.1 & 4.3.3

Requirement Overview

BRCGS for Storage & Distribution requires that products moved via cross-docking are traceable and controlled at all times, even when they are not held in storage for extended periods.

Clause 4.3.1: “The company shall ensure that traceability is maintained at all stages, including during cross-docking operations.”
Clause 4.3.3: “Procedures shall be in place to ensure that all products handled, including those not stored on-site, remain under control and are not subject to contamination or substitution.”

Cross-docking operations must not compromise product traceability, safety, or integrity. Even with minimal handling and temporary presence, each product must be accurately identified, documented, and protected.

Key Compliance Objectives

  • Prevent utility-based contamination of product or packaging

    Ensure food-grade quality standards for water, air, and steam

    Maintain utility infrastructure to prevent equipment failure and leaks

    Monitor, test, and document utility performance regularly

Step-by-Step Compliance Implementation

1. Assess and Map All Utility Sources

  • Utilities to Include:

    • Potable and non-potable water (e.g., process, handwashing, CIP)

      Compressed air and gas systems

      Steam (culinary or cleaning)

      Electrical and mechanical energy systems (indirect impact)

    Evidence to Maintain:

    • Site utility map or schematic

      Utility identification and zoning (food-contact vs. non-contact)

      Approved water and gas supplier records

2. Verify Utility Safety and Quality

  • Control Measures Include:

    • Water: Potability testing and supply line integrity

      Air/Gases: Filtration, oil removal, and microbial testing (if contact occurs)

      Steam: Use of food-grade boiler chemicals and condensate checks

    Evidence to Maintain:

    • Lab reports for water quality

      Air and gas monitoring logs

      Steam system maintenance and treatment records

3. Prevent Utility-Based Contamination

  • Risk Reduction Actions:

    • Install filters and backflow prevention systems

      Ensure air nozzles and pipes are food-grade and hygienically designed

      Isolate non-potable lines from product or equipment zones

    Evidence to Maintain:

    • Maintenance records and calibration logs

      Inspection checklists for utility system hygiene

      Corrective actions for any non-conformances

4. Maintain and Monitor Utility Infrastructure

  • Maintenance Includes:

    • Scheduled cleaning and inspection of utility contact points

      Monitoring of pressure, flow, and contamination risks

      Rapid repair protocols for leaks, faults, or system failures

    Evidence to Maintain:

    • Preventive maintenance schedule

      Utility system performance logs

      Work orders and service documentation

Common Audit Findings & Recommended Fixes

Audit Finding Recommended Action
Unfiltered compressed air in use Install filters and document monitoring protocols
No water potability testing Establish regular sampling and retain lab certificates
Steam lines lack food-grade treatment Switch to approved chemicals and document supplier compliance
No mapping of utility contact points Create utility schematics identifying product-contact risk zones

Auditor Verification Checklist

During a BRCGS audit, expect to provide:

  • Utility schematics or system layout

    Water potability and air quality test results

    Maintenance and monitoring logs for air, steam, and energy systems

    Corrective action records for utility-related issues

Implementation Roadmap

Build Your Utility Control Program

  • Identify all utility systems and map their layout

    Classify utilities by food contact risk

Monitor and Verify

  • Conduct regular quality testing of water, air, and gases

    Maintain logs for maintenance, cleaning, and inspections

Maintain and Repair

  • Develop a documented preventive maintenance plan

    Respond rapidly to utility faults and contamination risks

Improve Continuously

  • Update infrastructure and documentation as your process evolves

    Train teams on safe utility use and contamination prevention

Why This Matters?

  • Protects your products from invisible contamination risks

    Meets regulatory and certification standards (e.g., FDA, BRCGS)

    Prevents costly product recalls due to utility-related failures

    Strengthens audit readiness and process reliability

Support Tools Available

Food Safety Systems provides:

  • Utility risk assessment templates

    Water, air, and steam monitoring logbooks

    Maintenance checklist templates

    Staff training modules on utility control