Document Control & Record-Keeping
Aligned with BRCGS Food Safety Issue 9 – Clauses 3.2 & 3.4
Requirement Overview
BRCGS Food Safety Issue 9 requires that all documents forming part of the Food Safety and Quality Management System (FSQMS) be controlled, current, and properly maintained, and that records are legible, retrievable, and verified.
Clause 3.2.1: “The company shall have a procedure to manage documents which form part of the food safety and quality management system. These shall be reviewed and updated at appropriate intervals.”
Clause 3.4.1: “Records shall be legible, maintained in good condition and retrievable. Any alterations to records shall be authorized and justification recorded.”
Proper document control ensures that only approved procedures and forms are in use. Effective record-keeping provides essential evidence of compliance, traceability, and performance monitoring.
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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✓ Maintain up-to-date and approved procedures and forms
✓ Prevent use of obsolete documents
✓ Ensure records are complete, legible, and authenticated
✓ Support traceability and continuous improvement
Step-by-Step Compliance Implementation
1. Establish Document Control Procedures
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Key Components:
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• Document approval by authorized personnel
• Version control and revision history
• Access restrictions and distribution tracking
• Scheduled reviews to ensure ongoing relevance
Evidence to Maintain:
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• Document control procedure (SOP)
• Master list of controlled documents
• Document approval and revision logs
- • Document approval by authorized personnel • Version control and revision history • Access restrictions and distribution tracking • Scheduled reviews to ensure ongoing relevance
- • Document control procedure (SOP) • Master list of controlled documents • Document approval and revision logs
2. Control Access and Usage
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Control Measures Include:
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• Digital or physical distribution control
• Point-of-use version checks
• Clear identification of controlled vs. obsolete copies
Evidence to Maintain:
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• Document access logs
• Training records on document control
• Archived obsolete documents marked “Superseded”
- • Digital or physical distribution control • Point-of-use version checks • Clear identification of controlled vs. obsolete copies
- • Document access logs • Training records on document control • Archived obsolete documents marked “Superseded”
3. Maintain Robust Record-Keeping Practices
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Records Must Be:
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• Complete, legible, and timely
• Authenticated with signature and date
• Stored securely and retrievable for audit
Evidence to Maintain:
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• Record retention policy and schedule
• Completed forms, logs, and verification records
• Secure electronic backups or physical filing system
- • Complete, legible, and timely • Authenticated with signature and date • Stored securely and retrievable for audit
- • Record retention policy and schedule • Completed forms, logs, and verification records • Secure electronic backups or physical filing system
4. Verify and Review Documentation Regularly
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Verification Activities:
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• Internal audits of document and record control
• Review of completed forms for accuracy and compliance
• Updates to procedures based on operational changes or non-conformities
Evidence to Maintain:
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• Internal audit reports
• Change control forms
• Document and record review logs
- • Internal audits of document and record control • Review of completed forms for accuracy and compliance • Updates to procedures based on operational changes or non-conformities
- • Internal audit reports • Change control forms • Document and record review logs
Common Audit Findings & Recommended Fixes
| Audit Finding | Recommended Action |
|---|---|
| Uncontrolled documents in use | Implement strict approval and version control protocols |
| Missing or altered records | Train staff on correct record completion and approval process |
| Illegible or incomplete records | Use standardized forms and provide refresher training |
| No formal retention policy | Establish and communicate a record retention and archiving SOP |