BRC Audit checklist Traded Products (Clause 9)

This BRC auditor checklist is the ninth from a set of 9 clauses that make up the BRC Global Food Safety standard - Issue 9 (updated in Aug 2022). It is designed to help you assess your operation against the requirements of the Standard, covering key areas such as food safety plan, performance monitoring for traded food products, specifications, testing, legality/traceability and more. Digitize your internal audits with GoAudits in preparation for a successful third-party BRC certification audit.

BRC Audit checklist Traded Products (Clause 9)



The Food Safety Plan - HACCP

1. The company shall either: • Have a HACCP or food safety plan specifically for the traded products handled on site, or • Incorporate the traded products into its existing HACCP or food safety plans (see section 2). The scope of traded products HACCP or food safety plan shall include the products and the processes for which the site is responsible. At a minimum, this shall include goods receipt, storage and dispatch.


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Approval And Performance Monitoring Of Manufacturers/Packers Of Traded Food Products

1. The company shall have a documented supplier approval procedure which identifies the process for initial and ongoing approval of suppliers and the manufacturer/processor of each product traded. The requirements shall be based on the results of a risk assessment which shall include consideration of: • The nature of the product and associated risks • Customer-specific requirements • Legislative requirements in the country of sale or importation of the product • Source or country of origin • Potential for adulteration or fraud • Potential risks in the supply chain to the point of receipt of the goods by the company • The brand identity of products (i.e. customer own brand or branded product).


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2. The company shall have a procedure for the initial and ongoing approval of manufacturers of products. This approval procedure shall be based on risk and include either one or a combination of: • A valid certification to the applicable BRCGS Standard or GFSI-benchmarked standard. The scope of the certification shall include the products purchased • Supplier audits, with a scope to include product safety, traceability, HACCP review and good manufacturing practices, undertaken by an experienced and demonstrably competent product safety auditor. Where this supplier audit is completed by a second or third party, the company shall be able to: demonstrate the competency of the auditor • Confirm that the scope of the audit includes product safety, traceability, HACCP review and good manufacturing practices • Obtain and review a copy of the full audit report or • Where a valid risk-based justification is provided and the supplier is assessed as low risk only, a completed supplier questionnaire may be used for initial approval. The questionnaire shall have a scope that includes product safety, traceability, HACCP review and good manufacturing practices, and it shall have been reviewed and verified by a demonstrably competent person.


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3. Records shall be maintained of the manufacturer’s/packer’s approval process, including audit reports or verified certificates confirming the product safety status of the manufacturing/packing sites supplying the products traded. There shall be a process of review and records of follow-up of any issues identified at the manufacturing/packing sites with the potential to affect food products traded by the company.


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4. There shall be a process for the ongoing review of manufacturers/packers, based on risk and using defined performance criteria, which may include complaints, results of any product tests, regulatory warnings/alerts, customer rejections or feedback. The process shall be fully implemented. Where approval is based on questionnaires, these shall be reissued at least every 3 years and suppliers shall be required to notify the site of any significant changes in the interim, including any change in certification status. Records of the review shall be kept.


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Specifications

1. Specifications shall be available for all products. These shall either be in the agreed format as supplied by the customer or, where this is not specified, include key data to meet legal requirements and assist the customer in the safe usage of the product. Specifications may be in the form of a printed or electronic document, or part of an online specification system.


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2. The company shall seek formal agreement of the specifications with relevant parties. Where specifications are not formally agreed, the company shall be able to demonstrate that it has taken steps to ensure formal agreement is in place.


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3. Companies shall operate demonstrable processes to ensure that any customer-specified requirements are met. This may be by inclusion of customer requirements within buying specifications, or by undertaking further work on the purchased product to meet the customer’s specification (e.g. sorting or grading of product).


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4. Specification review shall be sufficiently frequent to ensure that data is current or at a minimum every 3 years, taking into account product changes, suppliers, regulations and other risks. Reviews and changes shall be documented.


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Product Inspection And Laboratory Testing

1. The site shall have a product sampling or assurance programme to verify that the products are in accordance with buying specifications and meet legal and safety requirements. Where verification is based on sampling, the sample rate and assessment process shall be risk-based. Records of the results of assessments or analysis shall be maintained.


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2. Where verification of conformity is provided by the supplier (e.g. certificates of conformity or analysis), the level of confidence in the information provided shall be supported by commissioning periodic independent product analysis.


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3. Where claims are made about the products being handled, including the provenance, chain of custody and assured or ‘identity preserved’ status of a product or raw materials used, supporting information shall be available from the supplier or independently to verify the claim.


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4. Where the company undertakes or subcontracts analyses which are critical to product safety 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. Documented justification shall be available where non-accredited test methods are used.


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5. Test and inspection results shall be retained and reviewed to identify trends. Appropriate actions shall be implemented promptly to address any unsatisfactory results or trends.


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Product Legality

1. The company shall have documented processes to verify the legality of products which are traded. These processes shall include as appropriate: • Labelling information • Compliance with relevant legal compositional requirements • Compliance with quantity or volume requirements. Where such responsibilities are undertaken by the customer, this shall be clearly stated in contracts.


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Traceability

1. The site’s traceability procedure (see clause 3.9.1) shall include details of the system used for the traceability of traded products. The traceability system shall ensure that, for all batches of product, the site can identify the last manufacturer or, in the case of primary agricultural products, the packer or place of last significant change to the product. Records shall also be maintained to identify the recipient of each batch of product from the company.


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2. The company shall test the traceability system at least annually to ensure that traceability can be determined back to the last manufacturer and forward to the recipient of the product from the company. This shall include identification of the movement of the product through the chain from the manufacturer to receipt by the company (e.g. each movement and intermediate place of storage).


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3. The traceability test shall include the reconciliation of quantities of product received by the company for the chosen batch or product lot. Traceability should be achievable within 4 hours (1 day when information is required from external parties).


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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.

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