Documentation is one of the core foundations of BRCGS Version 9 compliance. It proves control, consistency, and alignment between what is written, what is trained, and what happens in daily operations. Without the right documentation framework, even strong food-safety systems can fail during audits simply because evidence isn’t available, accessible, or properly controlled.
This guide brings together every major document category required under BRC V9 and provides a clear structure to help you build a system that’s organized, controlled, and audit-ready. The goal isn’t just compliance — it’s building a documentation system that supports efficiency, traceability, and operational confidence.
What BRC V9 Requires: Documentation Essentials at a Glance
To meet BRC expectations, documentation must demonstrate:
What the business does
How it does it
Who is responsible
How implementation is verified
Where and how evidence is stored
Documentation requirements fall into several categories, including:
Policies
Procedures and SOPs
Specifications
Forms and Records
Validation and Verification Evidence
Traceability and Recall Documentation
Auditors will review content, formatting, revision control, document ownership, and real-world alignment. If documentation doesn’t match current practice, it signals loss of control.
Policies You Need for BRC V9 Compliance
Policies set the direction of the system and define leadership commitment. They should be concise, clearly written, and visible to employees.
Policies should have documented reviews, signatures, and dates demonstrating leadership accountability and alignment with business objectives.
Mandatory Procedures You Must Have in Place
Procedures and SOPs provide step-by-step instructions for core operational activities. They ensure consistency and help prevent errors.
Examples of essential procedures include:
Recall and Withdrawal
Internal Auditing
Corrective and Preventive Action (CAPA)
Supplier Approval and Monitoring
Allergen Control
Cleaning and Sanitation
Document and Record Control
Traceability Management
Change Control
Consistency in layout, terminology, roles, and formatting supports usability, especially during training and audits.
Product-Specific Documentation – Specifications and Regulatory Requirements
Product specifications define what the product is, how it must be made, how it must be labelled, and its key safety and quality attributes.
Information typically includes:
Ingredients and formulation
Allergens
Claims and regulatory declarations
Physical, chemical, sensory, and microbiological requirements
Shelf life and storage conditions
Packaging specifications and labelling rules
Specifications must align with actual product formulation and packaging. Outdated specifications are one of the most common audit findings — especially where formulations, packaging, or suppliers have changed.
HACCP & Risk-Based Documentation – The Core of the System
The Food-Safety Plan is the most critical document in a BRC-compliant system. It must reflect the current process and include:
Product description and intended use
Process flow diagram
Hazard analysis
CCP and OPRP determination
Critical limits and control measures
Validation and verification activities
Corrective actions
Record templates
Evidence supporting validation and verification must be stored, controlled, and easy to retrieve during audit.
Operational Records – Daily Evidence of Compliance
Records prove implementation. They’re reviewed more than any other document type during audits.
Typical operational records include:
CCP monitoring logs
Cleaning and sanitation records
Calibration and maintenance documents
Allergen changeover verification
Environmental monitoring records (where required)
CCP/OPRP deviations and corrective actions
Traceability and batch coding logs
Records must be legible, complete, dated, signed, and stored for the appropriate retention period.
Supplier & Outsourced Process Documentation
Supplier assurance documentation demonstrates control over risks associated with raw materials, packaging, and externally provided services.
Required documents may include:
Supplier questionnaires
Certificates of analysis (COAs)
Packaging compliance and migration certificates
Audit reports or certifications (BRC, ISO, GFSI schemes)
Contract service agreements
Documentation must be maintained, reviewed, and aligned with current suppliers and materials in use.
BRC requires sites to demonstrate full supply-chain traceability from supplier to customer — including packaging, ingredients, and rework.
Documentation supporting traceability includes:
Batch coding procedures
Traceability logs
Recall simulation records
Mass-balance exercises
Record retention schedules
Retention periods must meet legal, regulatory, and customer expectations, and documents must be retrievable promptly.
Digital vs. Paper Systems – Choosing the Right Approach
Both digital and paper systems are allowed under BRC V9. What matters is whether the system is controlled, secure, and aligned with the standard.
A digital system may offer:
Automated version control
Controlled user access rights
Instant retrieval
Backup and disaster-recovery capability
E-signatures and audit trails
Paper systems require clear processes for controlled print copies, version control, and document removal.
Hybrid systems are acceptable but must avoid duplication and outdated formats.
Audit-Readiness Documentation Checklist
A strong documentation system supports audit readiness. The checklist below reflects what auditors will look for:
Current document versions used across the site
Controlled access and secure storage
Complete signatures and dates
Clear revision history
Training aligned with document changes
Full accessibility during audit
Records demonstrating implementation and verification
Documentation must show that the system is not just designed — but actively used.
FAQs – Documentation Requirements Under BRC V9
Is a specific format required for documentation? No — but formatting must be clear, controlled, and consistent.
Do all documents require signatures? Documents that define processes require approval signatures. Records require completion signatures.
Can multiple procedures be combined? Yes — if responsibilities, requirements, and controls remain easy to follow and implement.
Conclusion – Building a Documentation System That Works
A complete, controlled, and well-organized documentation system supports compliance, strengthens operational control, and ensures audit readiness. Once the framework is established, maintaining documentation becomes routine instead of reactive.
A structured toolkit, consistent formatting, and clear responsibilities make the process manageable and scalable as the business grows.
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.
