BRCGS Consumer Products Issue 4 Section 1: Senior Management Commitment, What Auditors Actually Look For

By Robert Low, Director, Lead Auditor & BRCGS Approved Trainer

Section 1 of Issue 4 is short on clauses and long on consequence, because it is where the auditor calibrates their read of the whole site. Senior management commitment and continual improvement, plus organisational structure, responsibilities and management authority. Two themes, and both get tested within the first hour of the audit, usually before anyone has opened a procedure.

Commitment Means Evidence, Not Enthusiasm

The section asks whether the top of the business genuinely owns product safety and quality: a signed, communicated policy, documented objectives with measures and monitoring, management review that actually reviews, and the human and financial resources to make the rest of the standard achievable. The evidence auditors weigh is behavioural. Does the senior manager attend the opening meeting and speak knowledgeably, or delegate and disappear? Do the objectives connect to anything real, complaint reduction, audit findings, right-first-time rates, or are they the same three lines rolled over annually? Were last year’s non-conformities closed at root cause, or patched? That last one matters doubly, because failing to address previous audit findings is one of the most self-inflicted non-conformities in the scheme.

Management Review Done Properly

The classic weak spot. A genuine management review evaluates audit results, complaints, incidents, objective performance and resource needs, produces decisions with owners and dates, and communicates them. The version that gets findings is a meeting that happened once, minuted thinly, with last year’s actions still open. My advice is unglamorous: run it more than annually, keep the minutes decision-focused, and walk into your audit able to show an action from review to closure.

Structure People Can Actually Describe

The organisational side asks for a current chart, clear allocation of responsibilities for product safety, legality and quality, documented deputies for absence, and personnel who know their responsibilities. The finding I see most: the chart says one thing, the floor says another, or nobody can tell the auditor who deputises for the quality manager on holiday. Auditors test this by asking operators, not by reading the chart.

What Changes Under Issue 5

Section 1 grows teeth in Issue 5, as per the public draft: a formal product safety and quality culture plan with phased auditable dates, a confidential reporting system, and management review pulled out as its own sub-section with a defined agenda. If your Issue 4 commitment evidence is thin, Issue 5 will be harder, so build the habits now. I have covered culture plans in depth, and the full changes are in the Issue 5 breakdown. Back to the series hub, or on to Section 2.