Product Control: Product Testing & Inspection
Aligned with BRCGS Food Safety Issue 9 – Clause 5.6
Requirement Overview
BRCGS Food Safety Issue 9 requires manufacturers to implement risk-based product inspection and testing programs to ensure that products meet food safety, legality, and quality requirements before release.
Clause 5.6.1.1: “The company shall have a scheduled programme of product testing to cover microbiological, chemical, and physical contamination risks…”
Product testing and inspection are essential to verify that finished goods conform to safety specifications, legal limits, and customer requirements. These activities must be controlled, validated, and documented.
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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✓ Implement a risk-based product testing schedule
✓ Verify product compliance with food safety and legal standards
✓ Maintain control over product release pending test results
✓ Document all inspections, results, and corrective actions
Step-by-Step Compliance Implementation
1. Develop a Product Testing and Inspection Plan
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Plan Components:
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• Identify testing types: microbiological, chemical, allergen, physical
• Define frequency based on product risk and regulatory/customer requirements
• Assign responsibility to qualified personnel or external labs
Evidence to Maintain:
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• Product testing schedule
• Written testing procedures and acceptance criteria
• Approved laboratory list and contracts
- • Identify testing types: microbiological, chemical, allergen, physical • Define frequency based on product risk and regulatory/customer requirements • Assign responsibility to qualified personnel or external labs
- • Product testing schedule • Written testing procedures and acceptance criteria • Approved laboratory list and contracts
2. Conduct In-House or Third-Party Testing
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Testing May Include:
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• Pathogen screening (e.g., Salmonella, Listeria)
• Allergen verification
• Heavy metals, pesticides, or other chemical residues
• Foreign body detection and weight checks
Evidence to Maintain:
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• Lab test reports or in-house testing logs
• Sample collection records
• Product hold/release documentation
- • Pathogen screening (e.g., Salmonella, Listeria) • Allergen verification • Heavy metals, pesticides, or other chemical residues • Foreign body detection and weight checks
- • Lab test reports or in-house testing logs • Sample collection records • Product hold/release documentation
3. Perform Visual and Physical Product Inspections
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Inspection Activities:
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• Visual inspection for label accuracy, integrity, contamination
• Sensory evaluation if applicable (color, smell, texture)
• Packaging integrity and tamper-evidence checks
Evidence to Maintain:
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• Inspection checklists
• Pre-shipment QA logs
• Non-conformance reports if applicable
- • Visual inspection for label accuracy, integrity, contamination • Sensory evaluation if applicable (color, smell, texture) • Packaging integrity and tamper-evidence checks
- • Inspection checklists • Pre-shipment QA logs • Non-conformance reports if applicable
4. Establish Product Release Controls
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Release Protocols Include:
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• Hold-and-release for tested batches
• Quarantine procedures for suspect or failed products
• Defined acceptance criteria and sign-off by QA
Evidence to Maintain:
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• Product release forms
• QA approval records
• CAPA documentation for out-of-spec results
- • Hold-and-release for tested batches • Quarantine procedures for suspect or failed products • Defined acceptance criteria and sign-off by QA
- • Product release forms • QA approval records • CAPA documentation for out-of-spec results
5. Review and Verify the Testing Program
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Ongoing Actions:
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• Trend analysis on test results
• Audit of sampling methods and result accuracy
• Update plan based on product changes or incident reviews
Evidence to Maintain:
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• Testing trend reports
• Internal verification audits
• Updated testing plan with version control
- • Trend analysis on test results • Audit of sampling methods and result accuracy • Update plan based on product changes or incident reviews
- • Testing trend reports • Internal verification audits • Updated testing plan with version control
Common Audit Findings & Recommended Fixes
| Audit Finding | Recommended Action |
|---|---|
| No documented testing plan | Create a formal testing and inspection schedule |
| Testing not risk-based | Review hazards and adjust testing frequency accordingly |
| Lack of release documentation | Implement formal QA sign-off procedures before dispatch |
| Failed results without CAPA | Initiate root cause analysis and documented corrective action |