Introduction

The BRCGS (Brand Reputation through Compliance Global Standard) is one of the most widely recognized food safety and quality management standards. Achieving and maintaining BRCGS certification requires strict adherence to its requirements. However, during audits, companies often face Non-Conformities (NCs) that can impact their certification status.

A key step in resolving these NCs is conducting a proper Root Cause Analysis (RCA) to prevent recurrence. In this blog, we’ll explore the most common BRCGS non-conformities and how to address them effectively using RCA methodologies.

Most Common BRCGS Non-Conformities

Based on audit data, the following are the most frequently occurring NCs in BRCGS audits:

1. Inadequate Food Safety Culture (Clause 1.1)

Issue: Weak employee engagement, lack of management commitment, or insufficient training.

RCA Approach:

Use the "5 Whys" technique to determine why employees are not engaged (e.g., Is training ineffective? Are responsibilities unclear?).

Implement leadership workshops and regular training refreshers.

2. Poor Pest Control Management (Clause 4.4)

Issue: Pest activity detected, inadequate monitoring, or improper documentation.

RCA Approach:

Strengthen preventive pest control measures and improve record-keeping.

3. Non-Compliant HACCP Plan (Clause 2)

Issue: Missing critical control points (CCPs), incorrect hazard analysis, or lack of validation.

RCA Approach:

Conduct a Process Mapping and Gap Analysis to identify where the HACCP plan fails.

Revalidate CCPs and provide HACCP team training.

4. Insufficient Cleaning & Sanitation Procedures (Clause 4.11)

Issue: Poor cleaning schedules, ineffective sanitation, or residue buildup.

RCA Approach:

Use Pareto Analysis to identify the most frequent sanitation failures.

Implement swab testing and revise cleaning protocols.

5. Weak Supplier Approval & Monitoring (Clause 3.5)

Issue: Lack of risk assessments, incomplete supplier audits, or missing documentation.

RCA Approach:

Perform a Supplier Risk Matrix Analysis to prioritize high-risk suppliers.

Strengthen supplier approval processes with documented checks.

6. Inadequate Internal Audits (Clause 8.4)

Issue: Audits not conducted frequently, untrained auditors, or no follow-up on findings.

RCA Approach:

Use Checklist Analysis to verify audit completeness.

Train internal auditors and establish a corrective action tracking system.

7. Poor Allergen Management (Clause 5.3)

Issue: Cross-contamination risks, incorrect labeling, or lack of staff awareness.

RCA Approach:

Apply FMEA (Failure Mode and Effects Analysis) to assess allergen risks.

Implement dedicated storage zones and allergen testing.

How to Conduct Effective Root Cause Analysis for BRCGS NCs?

Define the Problem Clearly – What exactly was the non-conformity?

Gather Data – Audit reports, logs, employee interviews

Use RCA Tools – 5 Whys, Fishbone, FMEA, Pareto Charts.

Identify Root Cause – Go beyond surface-level issues.

Implement Corrective Actions – Address the root cause, not just symptoms.

Monitor Effectiveness – Verify through follow-up audits.

Conclusion

BRCGS non-conformities can be minimized by proactive risk management and structured root cause analysis. Instead of treating NCs as one-time fixes, companies should embed RCA into their continuous improvement culture to ensure long-term compliance and food safety excellence.

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✔️ Real-world scenarios (e.g., allergen cross-contact, pest control failures, sanitation gaps).

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