Process Monitoring & Control

Aligned with BRCGS Food Safety Issue 9 – Clause 5.3

Requirement Overview

BRCGS Clause 5.3 requires that processes critical to food safety, legality, and quality are monitored and controlled to ensure products consistently meet defined specifications.

Clause 5.3.1: “The company shall ensure that the process is controlled to ensure that product conforms to specifications.”
Clause 5.3.2: “Process monitoring shall be carried out at a frequency based on risk and capable of detecting loss of control.”

Effective process control ensures consistency, reduces product variation, and protects the safety and integrity of food products throughout the manufacturing process.

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

  • Maintain process parameters that ensure product safety and quality

    Detect deviations quickly to prevent unsafe or non-compliant product

    Verify control measures are functioning effectively

    Document monitoring results and corrective actions

Step-by-Step Compliance Implementation

1. Identify Critical Process Parameters

  • Parameters May Include:

    • Time, temperature, pH, weight, metal detection, flow rate

      CCPs (Critical Control Points) and OPRPs (Operational Prerequisite Programs)

      Defined process specifications or tolerances

    Evidence to Maintain:

    • Process flow diagram with control points

      Product specification sheets

      Approved parameter limits and monitoring procedures

2. Monitor the Process Consistently

  • Monitoring Requirements:

    • Use calibrated instruments and trained personnel

      Set frequency based on risk and process sensitivity

      Record each monitoring check clearly and completely

    Evidence to Maintain:

    • Completed monitoring logs or digital records

      Calibration certificates of measurement tools

      Staff training records

3. Respond to Deviations Immediately

  • Deviation Response Steps:

    • Identify the source and extent of deviation

      Quarantine or hold affected product

      Take corrective and preventive actions

      Investigate root cause and update procedures if needed

    Evidence to Maintain:

    • Deviation and corrective action reports

      Product disposition records

      Updated process SOPs or monitoring protocols

4. Validate and Verify Control Effectiveness

  • Verification Activities Include:

    • Internal audits and supervisory checks

      Data trend analysis for process control

      Review of CCP verification logs

    Evidence to Maintain:

    • Internal audit reports and checklists

      Process performance graphs or summaries

      CCP verification documentation

Common Audit Findings & Recommended Fixes

Audit Finding Recommended Action
Incomplete or missing monitoring logs Train staff on proper record-keeping; use pre-approved templates
No defined limits for key parameters Set clear specifications and justify scientifically
Delayed or undocumented corrective action Implement immediate reporting protocol with CAPA documentation
Equipment not calibrated Create and follow a calibration schedule for all instruments

Auditor Verification Checklist

During a BRCGS audit, expect to present:

  • Defined process parameters and justification

    Monitoring records for CCPs, OPRPs, and other controls

    Calibration and maintenance logs for monitoring equipment

    Evidence of timely corrective action and verification steps

Implementation Roadmap

Build and Document Your System

  • Identify control points in the process flow

    Define process limits and monitoring frequencies

Train and Equip Your Team

  • Train operators and QA on monitoring procedures

    Calibrate and verify monitoring instruments

Monitor and Record

  • Maintain detailed, real-time records

    Address deviations with documented corrective actions

Verify and Improve

  • Analyze trends and deviations

    Update controls, SOPs, or equipment as needed

Why This Matters?

  • Ensures food safety controls function as designed

    Prevents non-conforming product from reaching the market

    Demonstrates due diligence and compliance with BRCGS Clause 5.3

    Builds confidence with auditors, customers, and regulators

Support Tools Available

Food Safety Systems provides:

  • Process control and CCP monitoring SOP templates

    Calibration tracking and verification logs

    Corrective action report forms

    Training materials for QA and production staff