Management of Non-Conforming Products
Aligned with BRCGS Food Safety Issue 9 – Clause 3.7
Requirement Overview
BRCGS Food Safety Clause 3.7 requires that sites have documented procedures for identifying, managing, and disposing of non-conforming products to prevent unintended use or release.
Clause 3.7.1: “There shall be documented procedures for managing non-conforming materials (including raw materials, packaging, semi-processed or finished products). These procedures shall include identification, documentation, evaluation, segregation (where practical), and disposition of non-conforming products.”
Non-conforming product management ensures food safety is maintained, legal requirements are met, and product integrity is preserved.
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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✓ Prevent unintended use or release of non-conforming materials
✓ Identify, document, and segregate affected product
✓ Define disposition procedures (e.g., rework, disposal, downgrade)
✓ Record corrective actions and root cause analysis
Step-by-Step Compliance Implementation
1. Establish a Non-Conformance Procedure
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Procedure Elements Include:
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• Clear definitions of non-conformance (e.g., physical damage, allergen mislabeling, spec deviation)
• Responsibilities for identification and evaluation
• Workflow for documenting and investigating incidents
Evidence to Maintain:
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• Non-conformance management SOP
• Flowcharts or decision trees for product evaluation
• Approval hierarchy for disposition decisions
- • Clear definitions of non-conformance (e.g., physical damage, allergen mislabeling, spec deviation) • Responsibilities for identification and evaluation • Workflow for documenting and investigating incidents
- • Non-conformance management SOP • Flowcharts or decision trees for product evaluation • Approval hierarchy for disposition decisions
2. Identify and Segregate Non-Conforming Product
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Control Measures:
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• Label or tag clearly with “Hold,” “Reject,” or “Non-Conforming” status
• Store in a designated quarantine area (physical or digital)
• Restrict system access and/or prevent dispatch in ERP/WMS
Evidence to Maintain:
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• Product hold logs or digital records
• Photos or labels confirming segregation
• Access restriction protocols
- • Label or tag clearly with “Hold,” “Reject,” or “Non-Conforming” status • Store in a designated quarantine area (physical or digital) • Restrict system access and/or prevent dispatch in ERP/WMS
- • Product hold logs or digital records • Photos or labels confirming segregation • Access restriction protocols
3. Determine Disposition and Take Action
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Disposition Options Include:
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• Rework or reprocess under defined conditions
• Downgrade for alternate use
• Disposal or destruction with traceable records
• Return to supplier with justification
Evidence to Maintain:
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• Disposition decision log
• Records of rework or destruction (signed and dated)
• Supplier notification forms (if applicable)
- • Rework or reprocess under defined conditions • Downgrade for alternate use • Disposal or destruction with traceable records • Return to supplier with justification
- • Disposition decision log • Records of rework or destruction (signed and dated) • Supplier notification forms (if applicable)
4. Conduct Root Cause Analysis & Corrective Action
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Corrective Measures:
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• Investigate root cause of non-conformance
• Apply corrective/preventive actions (CAPA)
• Review procedures, training, or supplier performance if needed
Evidence to Maintain:
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• Completed non-conformance report
• CAPA records with closure dates
• Trend analysis reports for recurring issues
- • Investigate root cause of non-conformance • Apply corrective/preventive actions (CAPA) • Review procedures, training, or supplier performance if needed
- • Completed non-conformance report • CAPA records with closure dates • Trend analysis reports for recurring issues
Common Audit Findings & Recommended Fixes
| Audit Finding | Recommended Action |
|---|---|
| No documented process for managing holds | Develop SOP with clear roles and segregation protocols |
| Non-conforming product not labeled | Train team to tag and record held materials |
| Missing root cause investigation | Implement formal CAPA documentation |
| Reworked product not validated | Ensure rework is pre-approved and risk assessed |