External and Internal Site Condition
Aligned with BRCGS Food Safety Issue 9 – Clause 4.4 Site Standards
Requirement Overview
BRCGS Food Safety Issue 9, Clause 4.4, requires that the internal and external condition of the site be designed, maintained, and managed in a way that minimizes the risk of contamination and supports food safety, legality, and product quality.
Clause 4.4.1: “The external areas of the site shall be maintained in good order. Where necessary, measures shall be taken to prevent access by pests.”
Clause 4.4.2: “The internal condition of the manufacturing, storage and product handling areas shall be suitable for the intended purpose, maintained to prevent contamination and facilitate cleaning.”
Proper site maintenance—both inside and outside—is essential for preventing physical, chemical, microbiological, and pest-related hazards.
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 clean, hygienic, and damage-free internal production and storage areas
✓ Prevent pest harborage and entry from external site surroundings
✓ Support hygienic design and cleaning accessibility
✓ Ensure structural integrity and prevent contamination risks
Step-by-Step Compliance Implementation
1. Maintain the External Site Environment
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Key Areas to Monitor:
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• Grounds and landscaping
• Waste disposal areas
• Drainage systems and standing water
• Perimeter fencing and building exteriors
Preventive Measures:
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• Routine cleaning and vegetation control
• Proper waste containment and scheduled removal
• Pest-proofing at external entry points
Evidence to Maintain:
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• External site inspection records
• Pest control service reports
• Grounds maintenance schedule
- • Grounds and landscaping • Waste disposal areas • Drainage systems and standing water • Perimeter fencing and building exteriors
- • Routine cleaning and vegetation control • Proper waste containment and scheduled removal • Pest-proofing at external entry points
- • External site inspection records • Pest control service reports • Grounds maintenance schedule
2. Ensure Internal Areas Are Hygienic and Suitable
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Key Areas to Assess:
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• Walls, floors, ceilings, and drains
• Doors, windows, and overhead structures
• Lighting, ventilation, and condensation controls
Control Measures Include:
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• Damage-free, sealed surfaces
• No flaking paint, exposed insulation, or open gaps
• Fixtures that prevent water accumulation and dust build-up
Evidence to Maintain:
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• Maintenance logs and repair records
• Hygienic zoning and building layout plans
• Internal housekeeping inspection forms
- • Walls, floors, ceilings, and drains • Doors, windows, and overhead structures • Lighting, ventilation, and condensation controls
- • Damage-free, sealed surfaces • No flaking paint, exposed insulation, or open gaps • Fixtures that prevent water accumulation and dust build-up
- • Maintenance logs and repair records • Hygienic zoning and building layout plans • Internal housekeeping inspection forms
3. Implement Inspection and Maintenance Programs
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Maintenance Program Includes:
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• Scheduled preventive maintenance for structures and fixtures
• Prompt repairs of identified defects
• Tracking of open and closed work orders
Evidence to Maintain:
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• Facility maintenance SOP
• Work order logs and resolution documentation
• Photos or records of repairs before/after
- • Scheduled preventive maintenance for structures and fixtures • Prompt repairs of identified defects • Tracking of open and closed work orders
- • Facility maintenance SOP • Work order logs and resolution documentation • Photos or records of repairs before/after
4. Control Zoning and Environmental Conditions
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Key Zoning Considerations:
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• Random traceability checks during audit or inspection
• Review of inbound/outbound logs for completeness
• Monitoring of product condition at dispatch
Evidence to Maintain:
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• Segregation of low-risk, high-risk, and high-care areas
• Control of airflow and entry between zones
• Temperature, humidity, and lighting control
- • Random traceability checks during audit or inspection • Review of inbound/outbound logs for completeness • Monitoring of product condition at dispatch
- • Segregation of low-risk, high-risk, and high-care areas • Control of airflow and entry between zones • Temperature, humidity, and lighting control
Common Audit Findings & Recommended Fixes
| Audit Finding | Recommended Action |
|---|---|
| Incomplete traceability records | Implement tracking logs that link shipment in/out data |
| Product misidentification during sort | Use barcode scanning or color-coded labeling to prevent confusion |
| Shared cross-dock areas without controls | Mark zones for separation and provide visual management aids |
| No SOPs or inconsistent staff handling | Train team and enforce documented procedures for consistency |