When teams start preparing for a BRC audit, one of the questions I hear most is: “What do sites typically get marked down for?”
And honestly, knowing the patterns helps. After supporting companies across ready-to-eat environments, frozen foods, bakery lines, beverage plants, and high-risk chilled production, I’ve noticed the same types of findings repeating. Not because companies don’t care—but because operational reality gets busy, and certain controls slip quietly.
If you understand where most businesses struggle, you can prevent avoidable mistakes before they ever hit your audit report. By the end of this guide, you’ll know the most common non-conformities under BRC V9, what causes them, and what you can do now to avoid them.
Documentation & Record-Keeping Failures
Documentation may not feel exciting, but it’s the backbone of compliance. One of the most frequent findings in audits isn’t poorly run processes—it’s gaps in records proving those processes happened.
Typical examples include:
Missing signatures
Outdated versions of forms
CCP logs filled at the end of the shift instead of in real time
SOPs printed but not controlled
A facility I supported once ran a flawless production environment, but they received multiple minors simply because records weren’t aligned or time-stamped correctly.
Pro tip: Record it when it happens—not later. “Catch-up paperwork” is one of the fastest ways to lose trust during an audit.
Allergen Management Issues
Allergen control continues to be one of the biggest focus areas in BRC V9. And rightly so—mistakes here can lead to harm, recalls, or legal consequences.
Common gaps include:
Poor changeover validation
Shared equipment without verification
Missing or unclear allergen storage segregation
Incorrect label checks
A lot of teams assume allergen controls are “common sense,” but compliance requires proof—not assumptions.
If it isn’t validated, it isn’t compliant.
Cleaning & Housekeeping Failures
Most factories clean daily—but what auditors often uncover are weaknesses in deep cleaning routines or those forgotten corners no one sees daily.
Findings often appear in:
Under conveyors
High ledges and overheads
Inside equipment guards
Hard-to-reach framework areas
One client shifted responsibility for hygiene checks from QA to shift supervisors. That single change created ownership. Audit findings dropped because the people closest to the work took charge.
Pro tip: Use “three-level cleaning checks”: visual, detailed, and verified.
Calibration & Equipment Verification Gaps
Even strong QA teams get caught out by calibration. The most common mistake? Believing that annual calibration alone is enough.
BRC expects:
A full equipment register
Valid calibration certificates
Routine verification records
Removed or labeled equipment that’s out of tolerance
A site I worked with had calibrated metal detectors but no evidence of performance verification. Result: Major non-conformity.
Think of calibration as the foundation. Verification is the confidence layer.
Pest-Control Weaknesses
Pest control findings often aren’t because pests are present—it’s because follow-up actions, documentation, or trend analysis are missing.
Typical non-conformities:
Trap maps not updated
Missing inspection signatures
Slow action follow-up after activity
Inaccessible monitoring points
The trend I see often? Technicians do their job—but the site doesn’t track what the data means.
Pro tip: Review trends monthly, not yearly.
Training & Competency Failures
Training records sound simple, yet they frequently become findings. The gap isn’t training—it’s proving competence.
Examples:
Out-of-date hygiene certificates
No evidence staff were trained on updated procedures
Temporary staff operating without validation
Team members signing forms they don’t understand
One facility solved this by aligning a role-based training matrix with expiry dates and responsibility tags. It streamlined compliance and removed assumptions.
Training is only meaningful when competence is demonstrated—not just documented.
Traceability & Mass-Balance Errors
Traceability exercises are make-or-break moments during audits. BRC expects full traceability within hours—not days.
Where teams struggle:
Reworked product variability
Missing supplier documents
Batch linking inconsistencies
Poor label and packaging controls
A processor I supported reduced their recall test time from nearly three hours to under 45 minutes simply by standardizing batch codes.
If you can’t trace it quickly, you can’t prove control.
Internal Audit & Management Review Weaknesses
Internal audits aren’t just a requirement—they’re a rehearsal. Yet many companies treat them as a checklist instead of a stress test.
Common issues include:
Audits not covering all clauses
No evidence of follow-up
Repeat findings ignored
Weak management review inputs (or outdated data)
One site improved dramatically by scoring their internal audits as if they were real BRC findings. Their next external audit score jumped because nothing caught them by surprise.
FAQs – Non-Conformities in BRC V9
Which non-conformities most often escalate into Majors? Repeat allergen issues, traceability failures, and verification gaps.
How many minors are “normal”? There’s no fixed number—but clusters or patterns matter more than quantity.
Can we correct a finding during the audit? Yes, but correction doesn’t erase the root cause—it may downgrade severity, not remove the finding.
Conclusion – Turning Findings Into Improvement
Non-conformities aren’t a failure—they’re information. They highlight where the system needs strengthening, and when you approach them with honesty and strategy, performance improves audit after audit.
If you want support turning these insights into readiness, your next step could be:
Downloading a corrective action template
Running a mock audit
Or building a site-specific action plan
The goal isn’t perfection—it’s consistent control. And now you know where most sites slip, you’re already ahead.
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.
