Internal Audits

Aligned with BRCGS Food Safety Issue 9 – Clause 3.4: Internal Audit and Inspections

Requirement Overview

BRCGS Food Safety Issue 9 requires sites to implement a scheduled, risk-based internal audit program that covers the entire food safety and quality management system. Internal audits must verify ongoing compliance with BRCGS requirements, legal obligations, and internal procedures.

Clause 3.4.1: “There shall be a scheduled programme of internal audits throughout the year. The scope shall cover the implementation of the food safety and quality management system and include all processes and activities with a frequency based on risk.”

Internal audits are essential for identifying gaps, verifying procedural compliance, and driving continuous improvement before external audits or incidents occur.

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

  • Verify implementation and effectiveness of the FSQMS

    Identify non-conformities, gaps, or process deviations

    Document corrective actions and follow-ups

    Ensure BRCGS and regulatory compliance readiness

Step-by-Step Compliance Implementation

1. Develop a Risk-Based Audit Schedule

  • Plan Elements:

    • Annual internal audit schedule covering all areas of the FSQMS

      Risk-based frequency and scope (e.g., high-risk areas audited more frequently)

      Designated audit leads and checklists aligned with BRCGS clauses

    Evidence to Maintain:

    • Annual audit plan/calendar

      Risk assessment rationale for audit frequency

      Assigned audit roles and responsibilities

2. Conduct Internal Audits Effectively

  • Audit Execution Must Include:

    • Use of approved checklists and audit tools

      Interviews with staff and review of procedures

      Verification of implementation, not just documentation

      Objective evidence gathering and impartiality

    Evidence to Maintain:

    • Completed audit checklists and notes

      Photos, observations, and collected records

      Auditor qualifications and training documentation

3. Report Findings and Classify Non-Conformities

  • Non-Conformity Classification:

    • Minor – procedural deviation with limited risk

      Major – failure to meet a critical requirement

      Critical – likely to result in product safety failure or regulatory breach

    Evidence to Maintain:

    • Audit reports with classification and evidence

      Summary of audit results with findings logged

      Notification and approval trail

4. Implement Corrective and Preventive Actions (CAPA)

  • CAPA Process:

    • Root cause analysis (RCA)

      Corrective action planning and assignment

      Completion timelines and verification of effectiveness

    Evidence to Maintain:

    • CAPA forms with root cause documented

      Action closure dates and verification signatures

      Revised procedures, training records, or updated logs

5. Review and Trend Audit Performance

  • Trend Monitoring Activities:

    • Track recurrence of non-conformities

      Identify systemic issues and recurring weak points

      Adjust audit frequency or scope as needed

    Evidence to Maintain:

    • Internal audit summary reports (monthly/quarterly/yearly)

      Non-conformance trend charts

      FSQMS updates based on audit outcomes

Common Audit Findings & Recommended Fixes

Audit Finding Recommended Action
Incomplete or missing audit schedule Develop and approve a documented annual audit plan
Repetition of the same non-conformities Conduct root cause analysis and verify CAPA effectiveness
Lack of evidence for audits performed Retain completed checklists, notes, and supporting documentation
No follow-up on non-conformities Track CAPA status and verify closure before marking complete

Auditor Verification Checklist

During a BRCGS audit, be ready to present:

  • Annual internal audit plan and risk basis

    Completed audit reports with dates and findings

    CAPA records with verification of completion

    Audit trend summaries and FSQMS updates

    Qualifications of internal auditors

Implementation Roadmap

Build Your Audit Program

  • Create a risk-based audit schedule covering all system areas

    Assign trained auditors and standardize your tools

Train and Execute

  • Conduct regular audits using BRCGS-aligned checklists

    Interview, observe, and document objectively

Track and Follow Up

  • Record findings and classify non-conformities

    Assign and complete CAPAs with verification

Review and Improve

  • Monitor trends in audit findings

    Revise audit plan and procedures based on results

Why This Matters?

  • Proactively identify risks before external audits or incidents

    Ensure compliance with BRCGS and legal requirements

    Strengthen documentation, traceability, and process control

    Foster a culture of accountability and improvement

Support Tools Available

Food Safety Systems provides:

  • Internal audit SOP templates

    Annual audit schedule planners

    Audit checklists mapped to BRCGS clauses

    CAPA and root cause analysis tools