Product Control: Product Release
Aligned with BRCGS Food Safety Issue 9 – Clauses 5.6 & 5.7
Requirement Overview
BRCGS requires that all finished products be held under control until inspection, testing, and verification activities confirm they meet defined food safety and quality criteria. Products must not be released unless approval is granted by authorized personnel.
Clause 5.7.1: “Product shall only be released by authorized personnel and once all release procedures have been completed and records are available to demonstrate that product meets specification.”
Product release is a critical control point in the supply chain where failure can result in non-compliant or unsafe food reaching the market.
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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✓ Ensure product is not released until it meets all specifications
✓ Assign and document release authority to qualified personnel
✓ Maintain records of inspection, testing, and release approvals
✓ Prevent release of non-conforming or suspect product
Step-by-Step Compliance Implementation
1. Define Product Release Criteria
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Release Conditions Include:
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• Completion of all required inspections and laboratory tests
• Conformance with finished product specifications (micro, chemical, sensory, etc.)
• Verification of label accuracy, packaging integrity, and code dates
Evidence to Maintain:
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• Product specification sheets
• Completed inspection/test logs
• Certificates of analysis (if applicable)
- • Completion of all required inspections and laboratory tests • Conformance with finished product specifications (micro, chemical, sensory, etc.) • Verification of label accuracy, packaging integrity, and code dates
- • Product specification sheets • Completed inspection/test logs • Certificates of analysis (if applicable)
2. Assign Release Authority
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Authorized Personnel May Include:
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• Quality Assurance Manager
• Site Technical Manager
• Designated QA Release Officer
Control Measures:
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• Ensure only trained, authorized individuals can approve release
• Maintain a list of authorized signatories and responsibilities
Evidence to Maintain:
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• Product release SOP
• Authorization and training records
• Signature verification list
- • Quality Assurance Manager • Site Technical Manager • Designated QA Release Officer
- • Ensure only trained, authorized individuals can approve release • Maintain a list of authorized signatories and responsibilities
- • Product release SOP • Authorization and training records • Signature verification list
3. Conduct Product Verification Checks
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Verification May Include:
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• Sensory checks (appearance, texture, aroma)
• Lab test results (e.g., allergen, pathogen, moisture content)
• Packaging, date coding, and traceability validation
Evidence to Maintain:
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• Inspection reports or checklists
• QC sampling results
• Records of failed/rejected lots and dispositions
- • Sensory checks (appearance, texture, aroma) • Lab test results (e.g., allergen, pathogen, moisture content) • Packaging, date coding, and traceability validation
- • Inspection reports or checklists • QC sampling results • Records of failed/rejected lots and dispositions
4. Record and Approve Product Release
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Release Documentation Must:
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• Be signed/initialed and dated by an authorized person
• Clearly reference batch/lot numbers and test results
• Include justification for release or hold
Evidence to Maintain:
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• Final product release records
• Retained samples (if applicable)
• Non-conformance or hold/release forms
- • Be signed/initialed and dated by an authorized person • Clearly reference batch/lot numbers and test results • Include justification for release or hold
- • Final product release records • Retained samples (if applicable) • Non-conformance or hold/release forms
Common Audit Findings & Recommended Fixes
| Audit Finding | Recommended Action |
|---|---|
| Products released without approval | Ensure only authorized personnel are permitted to release product |
| Missing or incomplete release records | Use standardized product release forms and train QA team |
| Lab tests pending at time of release | Implement a hold-and-release protocol with documented verification |
| No evidence of specification checks | Cross-check with product spec sheets and retain inspection results |