Complaint Handling
Aligned with BRCGS Food Safety Issue 9 – Clause 3.10
Requirement Overview
BRCGS Food Safety Issue 9 requires sites to have an effective system in place for managing product complaints, including procedures for investigation, trend analysis, and corrective action.
Clause 3.10.1: “The company shall have a documented system for the management of complaints. This shall include the recording, investigation, and reporting of complaints relevant to food safety, legality, and quality.”
Clause 3.10.2: “Complaint data shall be analyzed for trends. Where there has been a significant increase in a complaint type, or a serious complaint (e.g., concerning product safety or legality), root cause shall be established and appropriate corrective action taken.”
Effective complaint handling improves product quality, strengthens consumer trust, and supports audit readiness.
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
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✓ Capture and log all complaints related to food safety, legality, or quality
✓ Investigate complaints with root cause analysis
✓ Apply corrective and preventive actions (CAPA)
✓ Review complaint trends for systemic issues
Step-by-Step Compliance Implementation
1. Establish a Complaint Management Procedure
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System Requirements:
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• Clear definitions of complaint categories (e.g., safety, labeling, contamination)
• Process for complaint intake, logging, investigation, and resolution
• Designated roles for review and response
Evidence to Maintain:
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• Complaint handling SOP
• Contact point for complaint reporting
• Complaint form or intake record
- • Clear definitions of complaint categories (e.g., safety, labeling, contamination) • Process for complaint intake, logging, investigation, and resolution • Designated roles for review and response
- • Complaint handling SOP • Contact point for complaint reporting • Complaint form or intake record
2. Record and Track All Complaints
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Recording Process Includes:
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• Date, product, lot/batch number, and description of issue
• Customer details (if available)
• Classification (food safety, legal, or quality)
Evidence to Maintain:
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• Complaint log or database
• Sample records with investigation status
• Photos or product samples (if applicable)
- • Date, product, lot/batch number, and description of issue • Customer details (if available) • Classification (food safety, legal, or quality)
- • Complaint log or database • Sample records with investigation status • Photos or product samples (if applicable)
3. Investigate and Analyze Root Cause
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Investigation Activities Include:
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• Verification of product details and traceability
• Review of batch records, production logs, or supplier inputs
• Root cause analysis (e.g., 5 Whys, fishbone diagram)
Evidence to Maintain:
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• Investigation report
• Root cause findings
• Supporting traceability documents
- • Verification of product details and traceability • Review of batch records, production logs, or supplier inputs • Root cause analysis (e.g., 5 Whys, fishbone diagram)
- • Investigation report • Root cause findings • Supporting traceability documents
4. Take Corrective and Preventive Actions
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Actions Should Be:
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• Proportionate to complaint severity
• Reviewed by appropriate personnel
• Documented with completion timeline and verification
Evidence to Maintain:
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• Corrective action reports
• Preventive action logs
• Sign-off and effectiveness verification
- • Proportionate to complaint severity • Reviewed by appropriate personnel • Documented with completion timeline and verification
- • Corrective action reports • Preventive action logs • Sign-off and effectiveness verification
5. Monitor and Analyze Complaint Trends
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Analysis Activities:
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• Monthly or quarterly trend reviews
• Identification of recurring issues or complaint spikes
• Presentation to senior management during review meetings
Evidence to Maintain:
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• Trend analysis reports
• Charts or dashboards
• Management review meeting notes
- • Monthly or quarterly trend reviews • Identification of recurring issues or complaint spikes • Presentation to senior management during review meetings
- • Trend analysis reports • Charts or dashboards • Management review meeting notes
Common Audit Findings & Recommended Fixes
| Audit Finding | Recommended Action |
|---|---|
| Complaint not investigated | Ensure investigation is documented for all valid complaints |
| No root cause or CAPA | Perform structured root cause analysis and track CAPA completion |
| Lack of trend analysis | Schedule regular trend review sessions and maintain summaries |
| Poor record-keeping or missing data | Standardize intake forms and complaint logs |