Last Updated on November 27, 2025 by Melissa Lazaro

Understanding BRC V9 Mandatory Procedures & Why They Matter

If you’re implementing BRC Version 9 or preparing for your next audit, one of the first questions that usually pops up is:

“What procedures are actually mandatory?”

I’ve seen companies create hundreds of documents they never needed — and I’ve seen others walk into Stage 1 thinking a hygiene procedure and HACCP plan would be enough. Neither approach works.

When you know exactly which documented procedures must exist, everything becomes easier: your workload shrinks, your team has clarity, and you build a system that supports operations — not one that overwhelms them.

In this guide, I’ll walk you through every mandatory procedure required under BRC V9, explain where most companies trip up, and share practical tips from real audits and implementation projects.

By the time you finish this, you’ll know what is required, what’s optional, and where documentation needs to match practice — because that’s what auditors check.

Core Mandatory Procedures Under BRC V9 – What the Standard Requires

There are procedures in BRC that aren’t negotiable. They’re clearly referenced and must be documented, implemented, and maintained.

Here’s the list most food businesses need:

• Food-Safety and Quality Policy
• Internal Audit Procedure
• Corrective and Preventive Action (CAPA)
• Supplier Approval & Monitoring
• Change Management
• Recall & Withdrawal
• Complaint Handling & Trending

A common mistake? Teams write these procedures once and never revisit them. Then the audit comes, and the SOP reflects a process that hasn’t existed in three years.

Pro Tip: Every time something changes — equipment, supplier, formulation, flow, or risk level — update the document and training record.

A few months ago, I worked with a beverage facility where the recall procedure existed, but no one had tested it. The mock recall exposed gaps no one expected. Within two hours, they updated the process, assigned responsibilities, and ran a new drill. Their next audit? Zero non-conformities in recall traceability.

That’s the difference between having a document and having a working system.

Operational Mandatory Procedures for Food-Safety Compliance

These are tied to day-to-day operations and good manufacturing practices (GMP). They’re non-negotiable because they protect the product and the consumer.

Key procedures include:

• Hygiene and GMP
• Allergen Management
• Foreign Body Control (glass, metal, plastic)
• Cleaning and Sanitation
• Traceability & Mass-Balance Testing
• Pest Control
• Environmental Monitoring (where applicable)

This is where most companies struggle — not because procedures are missing, but because they exist in siloed formats: wall posters, binder SOPs, outdated laminated cards, and verbal instructions from supervisors.

If procedures don’t match what operators actually do, the auditor will catch it.

One bakery client had a beautifully written allergen procedure — but production used a completely different allergen-wash method. The fix wasn’t rewriting the document — it was aligning reality with documentation and retraining staff.

Mandatory Risk-Based Procedures – Aligning with HACCP and Verification Requirements

Some procedures must be risk-based. They should connect directly to your food safety plan, hazard analysis, and validation evidence.

These typically include:

• HACCP / Food-Safety Plan
• Validation & Verification Procedure
• Calibration & Equipment Control
• Testing & Sampling Procedure
• Environmental Monitoring (if applicable)

A big misunderstanding is the difference between validation and verification.

• Validation: “Does this method actually prevent or reduce the risk?”
  Example: proving heat treatment is effective.
• Verification: “Are we consistently doing what we said we would do?”
  Example: reviewing cooking logs weekly.

During one audit, a company had records but no documented verification review. Once we added signatures, review frequency, and responsible roles — compliance was clear.

Document Control & Record-Keeping Procedures

These procedures help demonstrate traceability, accountability, and system integrity. They’re also foundational to audit readiness.

Required procedures usually include:

• Document Control
• Record Retention & Archiving
• Training & Competency
• Management Review

Auditors aren’t just looking for whether procedures exist — they’re checking if they’re controlled, versioned, retrievable, and used consistently.

I still remember a company that passed every clause — until the auditor found ten uncontrolled printed SOPs in the production area. That single finding could have been avoided with a simple controlled-copy stamp and periodic document sweeps.

Implementation Strategies – Making Procedures Practical and Audit-Ready

Creating mandatory procedures isn’t the hard part — making them usable is where most teams struggle.

Here’s a framework that works well:

1. Keep SOPs short and clear.
2. Use consistent formatting (scope, definitions, roles, steps, records).
3. Train staff — and record the training.
4. Test critical procedures (mock recall, allergen clean, security response).
5. Review and update at least annually or when process changes.

Templates help, but they must be customized. Auditors can tell when a procedure has never been used, and they’ll follow the document step-by-step with operators.

If the system works before the audit, the audit becomes confirmation — not a stress test.

Common Mistakes to Avoid

I see the same patterns repeatedly:

• Procedures written for auditors instead of users.
• Outdated SOPs stored in multiple locations.
• No evidence of training or competency checks.
• Procedures existing without supporting records.
• Over-complicated wording that confuses operators.

The simplest rule?

If people can’t follow the procedure during daily work, rewrite it.

FAQs – BRC V9 Mandatory Procedures

Do procedures need to be digital?
No — digital or printed is fine. What matters is version control, access, and consistency.

Can one procedure cover multiple requirements?
Yes — as long as it’s clear, traceable to the clause, and aligns with actual practice.

Are templates allowed?
Absolutely — just make sure they reflect your process, not a generic sample.

Conclusion – Your Next Step

Mandatory procedures aren’t just about ticking boxes. They’re the backbone of a working food-safety and quality system — and when they’re written well, they make operations smoother, audits easier, and compliance stronger.

If you’d like help building fully compliant procedures, reviewing existing documents, or accessing editable templates aligned with BRC Version 9, I’m happy to support that next step.