When companies start preparing for BRC V9, one question always comes up: “Where do we begin?”
If you’re feeling that way, it’s normal. I’ve helped teams transition from previous BRC versions, and the smoothest transitions always start with a structured, honest gap-analysis — not guesswork, not rushed document edits, and definitely not waiting until the internal audit.
A good gap-analysis gives you clarity. It shows what’s already compliant, what needs updating, and what requires deeper work — before an auditor finds it.
By the time you finish this guide, you’ll have a clear structure to evaluate your current system, assign responsibility, and prioritize what needs attention first.
How to Use This Gap-Analysis Template (Before You Begin)
Before diving in, it helps to understand how to make this tool work in real operations, not just on paper.
Here’s the simplest way to approach it:
Do it as a team, not alone behind a laptop.
Review each requirement using real operational evidence, not assumptions.
Validate controls with people — not just documents.
Compare V8 vs V9 wording to understand intent, not just compliance.
Who should be involved?
QA or Technical Manager
Production Supervisors
Training/HR
Food Defence/TACCP Lead
IT or cybersecurity representative
Procurement or supplier assurance (depending on structure)
Pro Tip
Treat this as a working workshop, not a tick-box exercise. The conversations during the assessment are often more valuable than the form itself.
Common Mistake
Only reviewing documents — without checking whether actual practice still matches.
Section-by-Section Comparison Table: BRC V8 vs V9 Requirements
This is where the real work happens.
The table format should make gaps visible immediately — not buried in paragraph text.
Clause
V9 Requirement Summary
Current Evidence
Gap Identified
Priority (H/M/L)
Actions Needed
Owner
Deadline
Status
Keep your responses short and factual. You’re not writing audit notes — you’re mapping reality.
Why This Table Matters
I’ve seen teams skip the comparative format and jump straight to corrective work. The result? They fix low-priority items and discover high-impact gaps too late.
This table prevents that.
Key Focus Areas in V9 to Audit More Deeply
Some areas in V9 are new or strengthened — meaning auditors will pay closer attention. Let’s go through the ones that typically require the most work.
1. Food Safety Culture Requirements
BRC now expects measurable and repeatable actions — not slogans.
Examples of evidence:
Culture KPIs
Staff engagement metrics
Training effectiveness evaluations
Leadership review records
If your current culture approach is a paragraph in the manual, this will need updating.
Avoid: assuming “training = culture.” Culture is about behavior, accountability, and follow-through.
2. Allergen and Label Control Enhancements
Allergen mislabeling remains a leading cause of recalls — so V9 tightens expectations.
Check:
Cleaning validation
Label verification steps
Reformulation controls
Trending of allergen swab results
Corrective action evidence
If your system relies heavily on operator judgment without verification steps, that’s a gap.
3. Food Defence, TACCP & Cybersecurity
Cybersecurity is now explicitly referenced — which surprises a lot of teams.
Look for:
User access controls
Password policies
System backup procedures
Evidence of review and testing
Vulnerability assessment updates
A quick test: If you can’t explain how unauthorized access to production or quality systems is prevented, there’s a gap.
4. Risk-Based Documentation & Evidence Trails
V9 expects decisions to be justified — not just written.
Examples:
Rationale for sampling frequency
Explanation for cleaning validation frequency
Documented review triggers
Trend analysis, not isolated results
Auditors don’t just ask “Show me.” They now ask: “Why this frequency, and how did you decide?”
Prioritization & Action Planning Framework
Once the gaps are visible, the next challenge is deciding what to do first.
A second table helps convert findings into action:
| Gap | Risk Level | Effort Required | Owner | Support Needed | Verification Method | Completion Evidence | Status |
Focus on risk and impact, not convenience.
Pro Tip
Small improvements delivered consistently beat large plans never implemented.
Common Mistake
Assigning everything to QA. Ownership should reflect where the risk lives.
Validation & Internal Review Checklist
Before closing transition work, confirm:
All identified gaps are addressed
Evidence exists — not just revised documents
Risk-based decisions are justified and recorded
Records align with procedures
Team is trained and can demonstrate competence
Internal audit confirms readiness
This step is where most teams uncover final blind spots — especially in implementation.
FAQs
1. How often should we repeat the gap-analysis? Once during transition, again before internal audit, and after major process or supplier changes.
2. Can the template replace an internal audit? No — it supports the internal audit, but the audit validates system performance.
3. Who should own the final review? The QA or Technical Manager — with cross-functional input.
Conclusion: What Happens After the Gap-Analysis
A solid gap-analysis turns the transition into a structured plan instead of a stressful scramble. It gives your team clarity, ownership, and a roadmap to full V9 alignment.
Once you’ve completed the review, the next logical steps are:
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.
