What BRC V9 Expects from a Documented Food-Safety & Quality Management System
A compliant Food-Safety and Quality Management System is more than a set of files, flowcharts, or SOPs stored in a shared folder. In every audit I’ve supported, the sites that perform best aren’t the ones with the biggest manuals—they’re the ones where the system reflects how the site genuinely works day-to-day.
If you’re here because you’re updating from Version 8, building a system from scratch, or simply making sure nothing gets missed before the audit, you’re already doing the right thing.
By the end of this section, you’ll have clarity on:
What BRCGS expects your QMS to include.
How to structure documentation in a way that’s practical—not overwhelming.
The common pitfalls that lead to preventable nonconformities.
Building a Structured, Practical QMS — Policies, Procedures & Framework Expectations
A strong QMS should feel intuitive. Anyone walking into your operation—from an auditor to a newly hired operator—should be able to follow the system without confusion.
Under BRC V9, your QMS should clearly include:
A food-safety and quality policy
Defined scope, product descriptions, and intended use
Risk-based procedures aligned with operations
Verification and validation activities
One thing I’ve noticed repeatedly is that overly complicated systems actually increase audit risk. Simple, clear, and accurate wins every time.
A client once told me, “We kept adding documents until no one understood the system anymore.” We simplified it—removed duplicate procedures, created visual work instructions, and suddenly the system worked the way it should.
So the rule is simple: make it usable, not impressive.
Document Control Essentials — Versioning, Approval & Accessibility Requirements
Document control is one of those areas where things often look good on paper—but fall apart when tested. BRC V9 expects controlled documentation that:
Has clear version numbers and revision history
Is approved by an authorized person
Is stored securely but easily accessible
Removes obsolete documents from use
If operators are relying on outdated SOPs taped to equipment—or worse, handwritten notes—you’ll get flagged.
A document register helps, but accessibility is key. If employees can’t find the latest version during an audit, the system isn’t controlling documents—it’s storing them.
Pro tip: Whether digital or paper-based, choose a structure people actually use, not one that looks “certification-ready.”
Record-Keeping & Evidence — Proving Compliance in an Audit-Ready Way
Records are your proof that the system is working—not occasionally, but consistently.
Auditors look for records that are:
Legible
Complete
Accurate
Time-bound
Signed or electronically traceable
Retained for the required period
A good test I use is simple:
“If someone picked up this record five years from now, could they understand what happened and why?”
One facility switched from handwritten CCP logs to digital time-stamped entries. It didn’t just reduce errors—during their audit, they demonstrated traceability and compliance in under 10 minutes. The auditor literally said, “This is the easiest record review I’ve done all year.”
That’s the standard to aim for.
Internal Audit Program — Systematic Review, Frequency & Competency Requirements
Internal audits are your rehearsal before the real event. BRC V9 expects you to audit:
All clauses of the standard
All processes impacting safety and quality
On a defined frequency based on risk
Auditors also now pay closer attention to auditor competency. Training is important—but so is impartiality. Internal auditors shouldn’t audit their own work.
A good structure is:
Annual schedule
Clause-by-clause checklist
Clear corrective-action follow-up
Common pitfall: Auditing paperwork only, and never observing the process.
Auditors expect to see internal audit records that mirror their approach—not just formality.
A strong system doesn’t eliminate problems—it responds to them intelligently.
Under BRC V9, corrective actions must include:
Immediate containment
Root-cause analysis (not assumptions)
Preventive actions
Verification of effectiveness
I’ve lost count of how many times I’ve read “operator error” as a root cause. In reality, operator error almost always points to unclear training, weak procedures, or poor system design.
When the real cause is addressed—not the symptom—repeat nonconformities disappear.
Complaints, Trends & Learning — Using Data to Strengthen the System
Customer complaints aren’t just feedback—they’re data.
BRC expects you to:
Categorize and trend complaints
Identify recurring patterns
Perform root-cause and escalation when thresholds are exceeded
Document actions taken and confirm effectiveness
If metal complaints spike, allergen errors repeat, or foreign materials appear more than once, the expectation is proactive—not reactive—action.
Auditors love when sites can say: “Here’s the trend, here’s what changed, and here’s the data showing the improvement.”
Management Review — Bringing It All Together at the Leadership Level
Management review is where leadership shows ownership—not just awareness.
The review should include:
KPI trends
Internal audit performance
Complaint trends
Incident investigations
Validation and verification outcomes
Resource and staffing needs
Once a year is the minimum—not the recommendation. Quarterly or biannual reviews provide stronger oversight and fewer surprises before audits.
A simple dashboard goes a long way here. Leadership should be able to see the pulse of the system at a glance—not dig through binders to understand it.
FAQs
Q: Can our QMS be fully digital for BRC V9? Yes—as long as it’s secure, controlled, accessible, and retains audit trails.
Q: Do we need to audit all clauses every year? Yes—though frequency can increase based on risk or nonconformities.
Q: Do SOPs need a specific format? No—but they must be clear, consistent, controlled, and understandable to the users.
Conclusion — A Strong QMS Protects the Business, Not Just the Certificate
A compliant QMS isn’t just documentation—it’s how you operate. When your system is clear, controlled, audit-ready, and actively improving, certification becomes a natural outcome—not a stressful target.
If you want folder structures, templates, internal audit tools, or QMS workflows built for BRC V9, the next step is refining—not expanding—your system.
Your QMS should work for you—not the other way around.
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.
