Implementing BRC V9: 90‑Day Action Plan

Last Updated on December 1, 2025 by Melissa Lazaro

A Clear 90-Day Plan Makes BRC Implementation Manageable

Most teams approach BRC implementation with a mix of motivation and uncertainty. The requirements are detailed, the expectations are specific, and the process can feel overwhelming without structure. The good news is that BRC implementation becomes far more achievable when broken into clear phases with defined responsibilities, outcomes, and checkpoints.

A 90-day action plan gives you direction. It helps you move from general understanding to controlled, documented, and verifiable compliance. Instead of scrambling to fix issues late in the process, this approach builds progress week by week — with the end goal of confidence before the certification audit.

By the end of this article, you’ll have a practical roadmap to implement BRC V9 efficiently, without overcomplicating the work or losing momentum along the way.

Weeks 1–2: Define Scope, Leadership Commitment, and Project Structure

The first phase sets the foundation. Before documents are written or procedures updated, everyone needs clarity on the scope and structure of the certification journey.

Key actions:

• Define certification scope, including products, processes, and exclusions.
• Assign roles: project owner, HACCP lead, internal auditor, documentation coordinator.
• Create a project plan aligned with BRC clause structure.
• Communicate expectations across departments so responsibilities are shared, not siloed.

This phase establishes alignment and accountability — two elements that prevent confusion later in the implementation process.

Pro Tip: Capture decisions in writing from day one. Early documentation becomes early compliance evidence.

Weeks 3–4: Perform a Gap-Analysis and Build the Corrective-Action Matrix

With roles and project governance in place, the next step is to understand where you currently stand. A structured gap-analysis helps you audit your existing system against BRC V9 requirements.

Focus areas include:

• KO requirements
• Documentation and policies
• Operational practices
• HACCP alignment
• Site standards and hygiene
• Traceability and recall capability

Once the gaps are identified, build a corrective-action matrix with owners, timelines, and required evidence.

This stage determines priorities. Instead of treating all tasks equally, you tackle high-impact risks first.

Weeks 5–6: Update and Standardize Documentation

With your gap findings guiding priorities, begin updating policies, procedures, and forms. Documentation should be accurate, practical, and aligned with how work is performed — not theoretical.

Tasks to complete:

• Update or create policies aligned with BRC intent.
• Standardize SOP formats and document control rules.
• Add missing forms, checklists, and monitoring records.
• Verify alignment between written processes and actual practices.

Documentation only works when it’s usable. Long paragraphs, unclear instructions, or overly technical language slow implementation and weaken compliance.

Pro Tip: Keep documents concise and visually structured — especially for operators.

Weeks 7–8: Strengthen Site Standards and Operational Controls

Now that written expectations are clearer, the focus shifts to the physical environment and operational execution. BRC is heavily evidence-based — meaning improvements must be visible on the floor.

Areas to address:

• Zoning and hygiene controls
• Cleaning validation and verification
• Foreign-body control measures
• Label accuracy and packaging control
• Supplier management and incoming goods verification
• Maintenance hygiene procedures

This phase ensures the facility meets the operational discipline expected during audit.

Common adjustments include improving storage segregation, validating cleaning processes, strengthening labeling checks, and refining maintenance work instructions.

Weeks 9–10: Build Competence Through Structured Training

A system is only effective when people understand it. Training must be role-based, practical, and competency-verified — not merely attendance-based.

Training priorities:

• BRC awareness for supervisors and leads
• HACCP and risk-based thinking for key personnel
• GMP and hygiene expectations for operators and sanitation staff
• CCP and monitoring requirements for production roles
• Supplier and materials approval for purchasing teams

Competence isn’t confirmed by signatures — it’s confirmed by observed correct behavior, consistent documentation, and confident responses during audit.

Weeks 11–12: Internal Audit, Mock Recall, and Readiness Review

With the system documented, implemented, and understood, the final phase validates performance.

Activities to complete:

• Conduct a full internal audit using BRC structure and terminology.
• Run a traceability and recall drill with time-bound expectations.
• Validate monitoring records for completeness and consistency.
• Close or update outstanding actions from the corrective-action matrix.
• Hold a leadership review to approve audit readiness.

By the end of this phase, your team should be aligned, documentation organized, operational controls demonstrated, and confidence established.

Certification Ready: Prepare for the Audit

With implementation complete and verification steps confirmed, the final preparation focuses on smooth audit execution.

Final steps:

• Schedule or confirm certification audit dates.
• Organize documents logically (digital or binder-based).
• Brief staff on how to respond clearly and confidently to auditor questions.
• Perform one last visual walk-through to verify consistency across areas and shifts.

The goal here is simple: ensure the system is not only compliant — but consistently demonstrated.

FAQs

Can BRC be implemented in 90 days?
Yes, if there is leadership commitment, clear project ownership, and existing systems in place. Facilities starting from scratch may need more time.

Do small or resource-restricted teams need additional tools or software?
Not necessarily. What matters is control, traceability, and consistency — the platform can be paper-based or digital.

What matters most during audit?
Alignment between documentation, practice, and evidence. Auditors expect to see the system functioning, not just described.

Conclusion: Progress Matters More Than Perfection

A 90-day action plan breaks implementation into manageable phases, helping teams move from uncertainty to structured readiness. The goal isn’t complexity — it’s clarity, consistency, and confidence.

If you’re ready to move forward, you can use this roadmap as your internal structure and begin assigning tasks, timelines, and responsibilities.