Process Control: Documented Processing Procedures
Aligned with BRCGS Food Safety Issue 9 – Clause 6.1
Requirement Overview
BRCGS Food Safety Issue 9 requires that all processes affecting product safety, legality, and quality be clearly defined and controlled through documented procedures. These procedures must be accessible, validated, and consistently followed by trained personnel.
Clause 6.1.1: “The company shall have documented process specifications and work instructions for the control of each step in the production process…”
Clause 6.1.2: “All process specifications and work instructions shall be accessible to relevant staff and shall be written in appropriate languages…”
Accurate, controlled, and consistently followed processing procedures are essential for product integrity, food safety, and audit compliance.
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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✓ Define and document all critical production steps
✓ Standardize processing to prevent deviations and ensure safety
✓ Provide staff with clear, accessible instructions
✓ Maintain records of implementation, monitoring, and verification
Step-by-Step Compliance Implementation
1. Develop and Document Processing Procedures
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Each Procedure Should Include:
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• Product name and process step description
• Equipment settings (e.g., time, temperature, pressure, pH)
• Operational limits and tolerances
• Critical Control Points (CCPs) or process monitoring steps
Evidence to Maintain:
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• Approved processing specifications
• Work instructions for each production stage
• CCP validation records
- • Product name and process step description • Equipment settings (e.g., time, temperature, pressure, pH) • Operational limits and tolerances • Critical Control Points (CCPs) or process monitoring steps
- • Approved processing specifications • Work instructions for each production stage • CCP validation records
2. Control and Communicate Work Instructions
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Best Practices Include:
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• Ensure procedures are version-controlled and approved
• Make instructions accessible at the point-of-use
• Translate instructions where language barriers exist
• Include visual aids for clarity when appropriate
Evidence to Maintain:
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• Distribution log for work instructions
• Language verification documentation
• Document control identifiers on posted SOPs
- • Ensure procedures are version-controlled and approved • Make instructions accessible at the point-of-use • Translate instructions where language barriers exist • Include visual aids for clarity when appropriate
- • Distribution log for work instructions • Language verification documentation • Document control identifiers on posted SOPs
3. Monitor and Verify Process Compliance
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Verification Activities Include:
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• Real-time monitoring of key parameters (e.g., cook temps)
• In-process checks and equipment calibration
• Batch documentation and corrective action records
Evidence to Maintain:
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• Monitoring logs and deviation records
• Corrective/preventive action (CAPA) documentation
• Internal process audit reports
- • Real-time monitoring of key parameters (e.g., cook temps) • In-process checks and equipment calibration • Batch documentation and corrective action records
- • Monitoring logs and deviation records • Corrective/preventive action (CAPA) documentation • Internal process audit reports
4. Train and Assess Staff on Procedure Compliance
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Training Scope Should Cover:
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• Understanding of process controls and limits
• How to follow documented procedures
• How to respond to deviations or alarms
Evidence to Maintain:
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• Staff training records and assessments
• Job-specific competency checklists
• Refresher training schedules
- • Understanding of process controls and limits • How to follow documented procedures • How to respond to deviations or alarms
- • Staff training records and assessments • Job-specific competency checklists • Refresher training schedules
Common Audit Findings & Recommended Fixes
| Audit Finding | Recommended Action |
|---|---|
| Incomplete or missing work instructions | Develop standardized, validated instructions for all process steps |
| Instructions not accessible to operators | Post at point-of-use; use visuals or multilingual formats |
| Deviations not recorded or addressed | Implement a deviation log and CAPA tracking system |
| No verification of process control | Conduct periodic internal process audits |