When teams reach out to me for help with BRCGS certification, they usually say something like, “We think we’re close, but we don’t know what we don’t know.” And honestly, that’s exactly where most facilities are before their first BRC audit.
A structured BRC V9 gap-analysis gives you clarity. Instead of guessing, you’ll know what’s already working — and what needs fixing before an auditor steps foot on-site. It saves time, prevents repeat work, and reduces surprises during the certification audit.
By the time you finish this guide, you’ll have a straightforward way to review your documentation, operations, and people against BRC V9 expectations. And you’ll be ready to turn findings into a solid implementation or corrective-action plan.
Understanding Scope: Define What’s Actually Being Certified
Before diving into forms and checklists, it helps to define your scope clearly. I’ve seen teams skip this step because they’re eager to start, and later they realize half the work wasn’t aligned with the intended scope — or worse, their scope was too vague for certification.
What to Clarify:
Which products are included?
Which processes and equipment fall under certification?
What exclusions are allowed — and justified?
Are outsourced processes part of your system?
Here’s what I’ve noticed: the clearer the scope, the smoother the audit. Confusion here almost always leads to avoidable non-conformities.
Pro Tip: Match your scope wording to customer expectations and audit language. Auditors appreciate clarity.
Common Mistake: Including every facility activity just because it exists. Scope should reflect relevance — not volume.
Documentation Review: Compare Your QMS to BRC V9 Requirements
Now we move to the paperwork — policies, procedures, risk assessments, and records. This is where many facilities discover gaps they didn’t expect.
A good approach is to map each BRC clause against your existing system:
Food safety and quality policy
Roles and responsibilities
Risk-based thinking and HACCP
Supplier approval
Allergen management
Traceability and documentation control
A client once told me, “We thought our ISO system covered everything.” After the review, they realized allergen controls, product defense, and supplier monitoring weren’t aligned with BRC expectations.
What to focus on:
Mandatory policies
Key requirements (KO clauses)
Evidence, not just documented intent
Pro Tip: Work clause-by-clause using the standard wording. It prevents misinterpretation and makes audit conversations smoother.
Facility Walkthrough: Validate Site Standards and Operational Controls
A desk review only shows part of the story. The real test happens on the floor.
During a walkthrough, you’re checking whether procedures match reality. For example, if your written cleaning validation says tools must be labeled and segregated — walk into the cleaning room and check if they are.
Look at:
Zoning and product flow
Equipment hygiene and condition
Cleaning and sanitation validation
Foreign-body controls
Pest-control program implementation
I once worked with a site where everything on paper looked perfect — but in the high-care zone, there were no hand-sanitizer refills. That small detail could’ve led to a non-conformity.
Common Pitfall: Reviewing operations from the office instead of walking every area.
Pro Tip: Take photos and timestamp evidence. It helps when planning corrective actions.
System Validation: Prove the System Works, Not Just Exists
This stage isn’t about documents or observations — it’s about performance. You’re asking: Does the system actually work?
Validate:
HACCP implementation
CCP and OPRP monitoring
Calibration and verification
Internal audit results
Traceability and recall testing
Training and competency records
One company I worked with felt confident until we ran a mock recall. It took them nearly six hours to trace materials upstream and downstream. Under BRC V9 expectations, that wasn’t acceptable — and they never would’ve known without testing.
Pro Tip: Run a mock audit using BRC language. It prepares your team mentally for the real assessment.
Scoring the Gaps: Prioritize Findings Based on Risk
Once you’ve collected findings, it’s time to turn them into an action plan. Not all gaps have equal impact, so classify them.
Priority levels work well like this:
High: KO clause gaps, legal requirements, or major safety risk
Medium: Process misalignment or partial implementation
Low: Minor gaps like formatting or record consistency
Avoid the temptation to close findings only on paper. Implementation must be visible and verifiable.
Pro Tip: Assign each task an owner, deadline, and verification method.
Final Readiness Check: Confirm You’re Audit-Ready
Before scheduling your audit, give everything one more review.
Focus on:
Staff understanding of their roles
Evidence of monitoring and verification
Smooth flow between documentation and practice
Consistency across shifts
One facility reduced findings by 60% just by doing short staff refresher sessions and walking supervisors through audit questions before the certification date.
If you can walk auditors confidently through your system and answer questions with examples — you’re ready.
FAQs
How long should a BRC gap-analysis take? It depends on the size and maturity of your system. Most facilities complete it in 1–4 weeks.
Do we need a consultant to run this? Not necessarily. But having someone experienced can speed up the process and highlight gaps you might not see internally.
Can we use previous standards or audit results as part of this process? Yes, as long as they’re updated and aligned with BRC V9 requirements.
Conclusion: Move Forward with Confidence
A solid gap-analysis bridges the uncertainty between where you are and where you need to be. It keeps the process structured, reduces risk, and increases the chances of passing your certification audit the first time.
If you’re ready to take the next step, you can download the editable BRC V9 gap-analysis matrix — or, if you prefer guided support, request a readiness review.
Either way, you’re no longer guessing — you’re building toward certification with purpose and clarity.
Melissa Lavaro is a seasoned ISO consultant and an enthusiastic advocate for quality management standards. With a rich experience in conducting audits and providing consultancy services, Melissa specializes in helping organizations implement and adapt to ISO standards. Her passion for quality management is evident in her hands-on approach and deep understanding of the regulatory frameworks. Melissa’s expertise and energetic commitment make her a sought-after consultant, dedicated to elevating organizational compliance and performance through practical, insightful guidance.
