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
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✓ 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
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Plan Elements:
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• 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:
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• Annual audit plan/calendar
• Risk assessment rationale for audit frequency
• Assigned audit roles and responsibilities
- • 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
- • Annual audit plan/calendar • Risk assessment rationale for audit frequency • Assigned audit roles and responsibilities
2. Conduct Internal Audits Effectively
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Audit Execution Must Include:
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• 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:
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• Completed audit checklists and notes
• Photos, observations, and collected records
• Auditor qualifications and training documentation
- • 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
- • Completed audit checklists and notes • Photos, observations, and collected records • Auditor qualifications and training documentation
3. Report Findings and Classify Non-Conformities
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Non-Conformity Classification:
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• 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:
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• Audit reports with classification and evidence
• Summary of audit results with findings logged
• Notification and approval trail
- • Minor – procedural deviation with limited risk • Major – failure to meet a critical requirement • Critical – likely to result in product safety failure or regulatory breach
- • Audit reports with classification and evidence • Summary of audit results with findings logged • Notification and approval trail
4. Implement Corrective and Preventive Actions (CAPA)
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CAPA Process:
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• Root cause analysis (RCA)
• Corrective action planning and assignment
• Completion timelines and verification of effectiveness
Evidence to Maintain:
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• CAPA forms with root cause documented
• Action closure dates and verification signatures
• Revised procedures, training records, or updated logs
- • Root cause analysis (RCA) • Corrective action planning and assignment • Completion timelines and verification of effectiveness
- • 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
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Trend Monitoring Activities:
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• Track recurrence of non-conformities
• Identify systemic issues and recurring weak points
• Adjust audit frequency or scope as needed
Evidence to Maintain:
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• Internal audit summary reports (monthly/quarterly/yearly)
• Non-conformance trend charts
• FSQMS updates based on audit outcomes
- • Track recurrence of non-conformities • Identify systemic issues and recurring weak points • Adjust audit frequency or scope as needed
- • 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 |
