BRC Audit checklist Product Control (Clause 5)
Management Of Allergens
1. The site shall carry out an assessment of raw materials to establish the presence and likelihood of contamination (cross-contact) by allergens. This shall include a review of the raw material specifications and, where required, the acquisition of additional information from suppliers (e.g. through questionnaires to understand the allergen profile of the raw material, its ingredients and the factory in which it is produced).
| Photo Comment |
3. A documented risk assessment shall be carried out to identify routes of contamination (cross-contact) and establish documented policies, and procedures for handling raw materials and intermediate and finished products, to ensure cross-contamination (cross-contact) is avoided. This assessment shall include: • Consideration of the physical state of the allergenic material (e.g. powder, liquid, particulate) • Identification of potential points of cross-contamination (cross-contact) through the process flow • Assessment of the risk of allergen cross-contamination (cross-contact) at each process step • Identification of suitable controls to reduce or eliminate the risk of cross-contamination (cross-contact).
| Photo Comment |
4. Procedures shall be established to ensure the effective management of allergenic materials to prevent cross-contamination (cross-contact) of products not containing the allergen. These shall include, as appropriate: • Physical or time segregation while allergen-containing materials are being stored, processed or packed • The use of separate or additional protective overclothing when handling allergenic materials • Use of identified, dedicated equipment and utensils for processing • Scheduling of production to reduce changes between products containing an allergen and products not containing the allergen • Systems to restrict the movement of airborne dust containing allergenic material • Waste handling and spillage controls • Restrictions on food brought onto site by staff, visitors and contractors and for catering purposes.
| Photo Comment |
6. Where a justified, risk-based assessment demonstrates that the nature of the production process is such that cross-contamination (cross-contact) from an allergen cannot be prevented, a warning should be included on the label. Legislation, national guidelines or codes of practice shall be used when making such a warning statement.
| Photo Comment |
7. Where a claim is made regarding the suitability of a food for individuals with a food allergy or food sensitivity (sometimes referred to as a ‘food hyper-sensitivity’), the site shall ensure that the production process is fully validated to meet the stated claim and the effectiveness of the process is routinely verified. This shall be documented.
| Photo Comment |
8. Equipment or area-cleaning procedures shall be designed to remove or reduce to acceptable levels any potential cross-contamination (cross-contact) by allergens. The cleaning methods shall be validated to ensure that they are effective and the effectiveness of the procedure routinely verified. Cleaning equipment used to clean allergenic materials shall either be: • Identifiable and specific for allergen use • Single use • Effectively cleaned after use.
| Photo Comment |
Product Authenticity, Claims And Chain Of Custody
2. The company shall have processes in place to access information on historical and developing threats to the supply chain which may present a risk of adulteration or substitution of raw materials (i.e. fraudulent raw materials). Such information may come from, for example: • Trade associations • Government sources • Private resource centres • Activities completed
| Photo Comment |
3. A documented vulnerability assessment shall be carried out on all food raw materials or groups of raw materials to assess the potential risk of adulteration or substitution. This shall take into account: • Historical evidence of substitution or adulteration • Economic factors which may make adulteration or substitution more attractive • Ease of access to raw materials through the supply chain • Sophistication of routine testing to identify adulterants • The nature of the raw material. The output from this assessment shall be a documented vulnerability assessment plan. This plan shall be kept under review to reflect changing economic circumstances and market intelligence which may alter the potential risks. It shall be reviewed annually and whenever there is: • A change in raw materials or a supplier of raw materials • Emergence of a new risk (e.g. known adulteration of an ingredient or developments in scientific information associated with authenticity of the site’s products or raw materials, for example, information obtained as part of clause 1.1.8) • Following a significant product safety incident (e.g. a product recall) where the authenticity of the site’s products or raw materials is implicated.
| Photo Comment |
5. Where products are labelled or claims are made on finished packs which are dependent on the status of a raw material, the status of each batch of the raw material shall be verified. These claims include: • Specific provenance or origin • Breed/varietal claims • Assured status (e.g. GLOBALG.A.P.) • Genetically modified organism (GMO) status • Identity preserved • Named specific trademarked ingredients. The facility shall maintain purchasing records, traceability of raw material usage and final product packing records to substantiate claims. The site shall undertake documented mass balance tests at a frequency to meet the particular requirements of any scheme it is certificated to, or in the absence of a scheme-specific requirement, at least one mass balance test every 6 months.
| Photo Comment |
7. Where a product is designed to enable a claim to be made, the company shall ensure that all claims are substantiated, and product formulation and the production process are fully validated to meet the stated claim and any legal requirements (in the country of intended sale) relating to the claim. The process flow for the production of products where claims are made shall be documented and potential areas for contamination or loss of identity identified. Appropriate controls shall be established to ensure the integrity of the product claims.
| Photo Comment |
Product Packaging
1. When purchasing or specifying primary packaging, the supplier of packaging materials shall be made aware of any particular characteristics of the food or existing packaging (e.g. high fat content, pH, usage conditions such as microwaving, other packaging used on the product, use of recyclable or reusable packaging materials) which may affect packaging suitability. Certificates of conformity or other evidence shall be available for primary packaging to confirm it complies with applicable food safety legislation and is suitable for its intended use.
| Photo Comment |
3. The company shall have a procedure to manage obsolete packaging (including labels). This shall include: • Mechanisms to prevent accidental use of obsolete packaging • Control and disposal of obsolete packaging • Appropriate procedures for the disposal of obsolete printed materials (e.g. rendering trademarked materials unusable).
| Photo Comment |
Product Inspection, On-site Product Testing And Laboratory Analysis
1. There shall be a scheduled programme of product testing which may include microbiological, chemical, physical and organoleptic testing according to risk. The methods, processes for obtaining product samples (including, where appropriate, their delivery to a laboratory), frequency and specified limits shall be documented.
| Photo Comment |
2. Test and inspection results shall be recorded and reviewed regularly to identify trends. The significance of on-site and laboratory results shall be understood and acted upon accordingly. Appropriate actions shall be implemented promptly to address any unsatisfactory results or trends. Where legal limits apply, these shall be understood and appropriate action taken promptly to address any exceedance of these limits. Where applicable, the measurement uncertainty associated with laboratory test results shall be considered.
| Photo Comment |
3. The site shall ensure that a system of validation and ongoing verification of the shelf life is in place. This shall be based on risk and shall include sensory analysis and, as applicable, microbiological testing and relevant chemical factors such as pH and aw. Records and results from shelf-life tests shall verify the shelf-life period indicated on the product.
| Photo Comment |
4. Pathogen testing (including pathogens tested as part of the site’s environmental monitoring programme) shall be subcontracted to an external laboratory or, where conducted internally, the laboratory facility shall be fully segregated from the production and storage areas and have operating procedures to prevent any risk of contamination of products or production areas.
| Photo Comment |
5. Where testing laboratories are present on a manufacturing site, they shall be located, designed and operated to eliminate potential risks to product safety. Controls shall be documented and implemented, and include consideration of: • Operating procedures to contain laboratory activities, including the design and operation of drainage and ventilation systems • Access and security of the facility • Movement of laboratory personnel • Hygiene and protective clothing arrangements • Movement of materials that may pose a risk to products, raw materials or the production area, into and out of the laboratory, including the disposal of laboratory waste • The management and monitoring of laboratory equipment. Where testing activities are performed in production or storage areas (e.g. at the line tests or rapid tests), these shall be located, designed and operated to prevent product contamination.
| Photo Comment |
6. Where the company undertakes or subcontracts analyses which are critical to product safety, authenticity or legality, the laboratory or subcontractors shall have gained recognised laboratory accreditation or operate in accordance with the requirements and principles of ISO/IEC 17025, including proficiency testing where applicable. Documented justification shall be available where accredited methods are not undertaken.
| Photo Comment |
7. Procedures shall be in place to ensure reliability of laboratory results, other than those critical to safety and legality specified in clause 5.6.6. These shall include: • Use of recognised test methods, where available • Documented testing procedures • Ensuring staff are suitably qualified and/or trained and competent to carry out the analysis required • Use of a system to verify the accuracy of test results (e.g. proficiency testing where applicable) • Use of appropriately calibrated and maintained equipment.
| Photo Comment |
Product Release
Pet Food And Animal Feed
3. Where the site manufactures, processes or packs pet food or animal feed products that contain medicinal substances, the site shall have specific procedures for the management of the medicated raw materials and finished products. At a minimum, these procedures shall include: • Identification of medication-containing materials handled on site. These can be raw materials, processing aids, intermediate and finished products, rework or any new product or product development ingredients • Supplier approval equivalent to section 3.5.1 for all medicated raw materials • Specific staff training on the correct handling of medicated materials • Mechanisms to ensure the correct concentrations of medicinal substances in finished products • Procedures (e.g. cleaning procedures) to prevent contamination of non-medicated pet food or animal feed with materials containing medicinal substances • Specific procedures to ensure the correct labelling of medicated pet food or animal feed • Waste disposal mechanisms (see section 4.12) that include the safe and legal disposal of medicated raw materials and products.
| Photo Comment |
Animal Primary Conversion
1. The company shall undertake a risk assessment for potential prohibited substances (i.e. those prohibited by legislation in the country of operation or intended country of sale). Example substances include pharmaceuticals, veterinary medicines (e.g. growth hormones), heavy metals and pesticides. The risk assessment may be completed as part of clause 3.5.1.1 or as a separate activity. The results of the risk assessment shall be included in raw material acceptance and testing procedures and in the processes adopted for supplier approval and monitoring
| Photo Comment |
Product Design/Development
1. The company shall have a procedure for new product development and changes to existing product, packaging and manufacturing processes. This procedure shall include any restrictions to the scope of new product development to control the introduction of hazards which would be unacceptable to the site or customers (e.g. the introduction of allergens, glass packaging, microbiological risks or the introduction of ingredients that may affect product claims).
| Photo Comment |
2. All new products and changes to product formulation, packaging or methods of processing shall be formally approved by the HACCP team leader or an authorised HACCP team member. This shall ensure that hazards have been assessed and suitable controls, identified through the HACCP system, are implemented. This approval shall be granted before products are introduced into the factory environment.
| Photo Comment |
4. Initial shelf-life trials shall be undertaken using documented protocols that reflect conditions expected during manufacture, storage, transport/distribution, use and handling to determine product shelf life. Results shall be recorded and retained and shall confirm compliance with the relevant microbiological, chemical and organoleptic criteria or sensory analysis. Where shelf-life trials prior to production are impractical, for instance for some long-life products, a documented science-based justification for the assigned shelf life shall be produced.
| Photo Comment |
Product Labelling
1. All products shall be labelled to meet legal requirements for the designated country of use and shall include information to allow the safe handling, display, storage, preparation and use of the product within the food supply chain or by the customer. There shall be a process to verify that ingredient and allergen labelling is correct based on the product recipe and ingredient specifications. The company shall have a procedure for artwork approval and sign-off.
| Photo Comment |
Is this sample what you are looking for?
Sign up to use & customise this template, or create your own custom checklist:
Checklist by GoAudits.com – Please note that this checklist is intended as an example. We do not guarantee compliance with the laws applicable to your territory or industry. You should seek professional advice to determine how this checklist should be adapted to your workplace or jurisdiction.
Easy inspection app for your digital checklists
- Conduct inspections anytime, anywhere - even offline
- Capture photos as proof of compliance or areas needing attention
- Instantly generate and share detailed reports after the inspections
- Assign & track follow-up tasks, view historical trends on a centralized dashboard
