Where Do Sites Lose Points in a BRC Audit?
The most common BRCGS non-conformities sit in Section 4, Site Standards. LRQA, a BRCGS certification body, analysed more than 72,000 audits and found that seven of the eight most frequent non-conformities fall in Section 4, with housekeeping and hygiene (clause 4.11.1) the most common worldwide and chemical control (clause 4.9.1.1) generating more than 10,000 findings (LRQA, 2026). Similarly, figures attributed to the BRCGS Annual Report 2024-25 put clause 4.11.1 at 4,715 non-conformities, with an average of 4.86 non-conformities per audit and 59% of all findings in Section 4 (FSNS, 2025).
At first glance, this looks like a buildings and cleaning problem. However, LRQA’s own reading of the data is more revealing. It describes these findings as “not a system failure, a consistency failure”, and notes that they rely on “controls carried out continuously, across shifts, by different people, under time pressure” (LRQA, 2026). In other words, the procedure usually exists. What varies is whether every person on every shift carries it out the same way.
That is the thread running through the five insights below.
1. The record clause and the competence clause ask different questions
Clause 7.1 is a fundamental requirement, and its statement of intent says that everyone whose work affects product safety, legality and quality must be demonstrably competent, through training, work experience or qualification (BRCGS, 2022). By contrast, clause 7.1.6 sets the minimum content of a training record: the trainee’s name and confirmation of attendance, the date and duration, the course title, the provider, and a reference to the material used.
Notice what that list does not contain. A record that satisfies 7.1.6 in full proves that someone sat through training on a given day. It does not prove that they can now do the task correctly. Consequently, a site can hold a complete, well-organised training file and still struggle to show the auditor demonstrable competence, which is the part that carries fundamental status. Clause 7.1.3 closes the gap by requiring sites to identify the competencies each role needs and to review the effectiveness of training, while 7.1.7 requires a routine review of staff competencies.
| What the auditor wants to know | What a training record shows | What competence evidence shows |
| Was this person trained? | Yes, with a date | Yes, with a date |
| Can they do this task correctly now? | Not addressed | Observed assessment against defined criteria, with assessor sign-off |
| Is that still true after a change? | Not addressed | Reassessment triggered by the change |
| Did the training work? | Not addressed | Effectiveness review, as clause 7.1.3 requires |
In practice: a ready-meals manufacturer’s mandatory unannounced audit arrives at 10pm, when a third of the high-care team are agency workers. The agency holds their food hygiene certificates, and the site holds a signed induction sheet for each one. Clause 7.1.1 requires agency and temporary staff to be trained before starting work and supervised throughout, and clause 7.1.4 extends allergen training to them (BRCGS, 2022). So when the auditor asks an agency operative to explain the high-care changing procedure, the induction sheet cannot answer for them.
What good looks like: a short practical sign-off for each agency worker on high-care entry and allergen procedures, completed before their first shift and visible to the night supervisor.
2. Issue 9 widened who needs a competency assessment
Under clause 7.1.2, training and competency assessment must be in place for anyone engaged in activities relating to control measures and critical control points (BRCGS, 2022). Commentary on the Issue 9 changes identifies “control measures” as a new addition to this clause (ASC Food Safety, 2026). As a result, a training matrix that flags assessments only for CCP monitors may miss the people running other validated controls, which clause 2.7.4 requires wherever a hazard is controlled by a prerequisite programme.
In practice: a bakery runs nut-containing and nut-free products on the same line, separated by a validated changeover clean. The hygiene leader who wrote the procedure has moved to days, and the late-shift changeover is now run by an operative who learned it by shadowing. There is a training record for the shadowing but no competency assessment, even though allergen management (5.3) and training (7.1) are both fundamental clauses.
What good looks like: for every control measure in the HACCP plan, the site can name who operates it and show when their competence was last assessed.
3. “Retrained the operator” is a risky root cause
For every non-conformity, the site must submit root cause analysis and a preventive action plan, and at the next audit the auditor checks whether that action actually prevented recurrence. If it did not, a non-conformity is raised against clause 1.1.12, which sits within the fundamental requirement for senior management commitment (BRCGS, 2022).
Consequently, “operator retrained” is only a credible preventive action if the site can show the retraining worked. Without a follow-up competence check, a repeat of the same issue turns one finding into two, and one of them is against management commitment.
4. Competence goes out of date when things change, not when the calendar says
Most training matrices track competence by date, with an annual refresher or a two-year renewal. However, BRCGS also ties competence to events. For example, commissioning new equipment must include updating training (clause 4.6.3), approved changes to printed packaging must be communicated to goods-in staff (clause 3.5.2.2), and label checkers must be trained on the site’s labelling processes (clause 7.1.5) (BRCGS, 2022).
In practice: a snack manufacturer replaces its metal detector, typically a CCP, with a model that has a different test routine. Its operators were assessed on the old unit last year, so the matrix still shows them as competent on equipment that no longer exists. Similarly, when a dairy’s allergen declaration moves on new label artwork, packers may still check against the old reference, and labelling and pack control (6.2) is a fundamental clause.
What good looks like: a change to equipment or packaging automatically flags the affected operators as “reassessment due” until they have been observed working with the new version.
👉🏻 Suggested Reading: Training and Compliance Management in the Manufacturing Industry covers the UK regulatory landscape, the limits of spreadsheet-based training records and a free audit checklist.
BRCGS vs SALSA vs FSSC 22000: Which Do You Need?
For UK food businesses, the choice usually comes down to what your customers ask for and how large your operation is. SALSA is built for small and micro producers, while BRCGS and FSSC 22000 are GFSI-recognised schemes that buyers can accept in place of their own supplier audits.
| SALSA | BRCGS Food Safety |
| Designed for | UK and Irish producers with typically 1 to 50 full-time employees | Food manufacturers of any size, worldwide |
| GFSI-recognised | No, by design (SALSA, n.d.b) | Yes (BRCGS, 2022) |
| Audit pattern | Annual, pre-arranged | 6 or 12 months, with one unannounced audit in every three years |
| Structure | Practical requirements for smaller sites | Prescriptive clauses, nine sections, 12 fundamentals |
| Where it leads | Described by SALSA as a route to schemes such as BRCGS | One certificate shared with many customers via the BRCGS Directory |
Sources: SALSA (n.d.a; n.d.b); BRCGS (2022); Lehmann Ingredients (2026), an ingredients supplier.
SALSA is run as a not-for-profit joint venture of the Food and Drink Federation, the NFU and UKHospitality, and it describes itself as a route to further schemes such as BRCGS (SALSA, n.d.a; n.d.b). For a growing producer, therefore, SALSA is often a stepping stone. Importantly, the people habits a site builds under SALSA, such as clear procedures and checked understanding, carry straight across when it moves up to BRCGS.
BRC Audit Readiness: The Competence Evidence Checklist
The table below focuses on the people side of an Issue 9 audit, because that is where most generic checklists stop at “training records available”. Each row asks for evidence an auditor can verify on the floor, not just in a folder.
| Clause | What the auditor will look for | Self-check question |
| 7.1 (fundamental) | Demonstrable competence for everyone whose work affects product safety, legality and quality | Can you show competence evidence, not only attendance, for every role on today’s rota? |
| 7.1.1 | Agency, temporary staff and contractors trained before starting and supervised | Could a night supervisor confirm an agency worker’s sign-off before their first shift? |
| 7.1.2 | Training and competency assessment for CCPs and control measures | Is every control measure in the HACCP plan linked to named, assessed operators? |
| 7.1.3 | Role competencies defined, training effectiveness reviewed, training in the right language | Do you review whether training worked, and is it delivered in the trainee’s language? |
| 7.1.4 | Allergen awareness and site allergen procedures for all, including engineers and contractors | Would a contract engineer pass a two-minute allergen question on the floor? |
| 7.1.5 | Labelling and packing training for relevant staff | Does a packaging change trigger a briefing for everyone who checks labels? |
| 7.1.6 | Complete training records, including agency-delivered training | Can you retrieve any person’s records in under a minute, including agency staff? |
| 7.1.7 | Routine review of staff competencies, with refresher, coaching or mentoring | Is competence reviewed when things change, not only on an anniversary? |
| 2.1.1 | HACCP team leader able to demonstrate competence, experience and training | Is the team leader’s HACCP training current and evidenced? |
| 3.4.2 | Trained, competent and independent internal auditors | Does anyone audit their own area? |
| 4.6.3 | Training updated when new equipment is commissioned | Does commissioning sign-off include operator reassessment? |
How Workprove Helps Food Manufacturers Prove Competence for BRCGS
Every example above shares one root: the site knew who had been trained, but could not easily show who was competent for a specific task, on a specific line, today. Workprove is built to close exactly that gap.
- Competence linked to the task, not just the person. Training and competency requirements can be mapped to specific roles, production lines, processes and CCPs, so the matrix answers “who can run this changeover?” rather than “who attended a course?”
- Assessments with evidence attached. Observed assessments carry defined criteria, assessor sign-off, dates and supporting evidence, which is the demonstrable competence that clause 7.1 asks for.
- Change-driven reassessment. Version control with automatic supersession means that when a procedure or work instruction is updated, the people who need to be re-briefed or reassessed are flagged, rather than staying green on the matrix.
- Agency and contractor visibility. Temporary, agency and contract workers sit in the same live matrix as employees, so a supervisor can confirm sign-off before a first shift.
- Audit-ready reporting. Records can be exported for BRCGS, SALSA, FSSC 22000 and customer audits, so evidence can be pulled together quickly when an auditor asks.
👉 Learn more: Training and skills management software for food and beverage production
See how live, task-level competence evidence could look across your own production lines. Take a self-guided tour of Workprove, or speak with a Workprove expert about building audit-ready competence for your next BRC audit.
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