BRCGS Consumer Products Issue 5 Process Control and Personnel: Sections 5 and 6 Explained

By Robert Low, Lead Management System Specialist and BRCGS Approved Trainer

Sections 5 and 6 are where the standard meets the shop floor. They cover how materials come in, how product is made, tested, packed and shipped, and how the people doing the work are trained and kept hygienic. Here is my plain English take on BRCGS Consumer Products Issue 5 process control and personnel, and a simple way to test your own site. This is my interpretation of the published standard, so read the official wording for the detail.

Process Control: Follow the Product Through

Start at the loading bay. Incoming materials, components and packaging need a defined acceptance process, and anything waiting on test results or paperwork has to be held until it is released. Stock rotation matters too, whether first in first out or first expiry first out. Next comes a new area to note: product vulnerability. The site needs a way to learn about threats in the supply chain and a documented assessment of the risk of substitution, adulteration or misrepresentation for materials and packaging. That part is not auditable until 1 June 2028, but the thinking is worth starting now.

Testing is risk based. You need a schedule for each product or group, built from your product risk assessment and your HARA, with defined methods, frequencies and limits. Where testing protects safety or legality, the laboratory or method is expected to be accredited or to follow the principles of ISO 17025, or you justify why not. Equipment that checks product in line has to be shown to be set up properly and capable of catching a failure.

Manufacturing itself is covered by line clearance, in-process checks and defined control points with limits. Then come storage, calibration, packing, release and dispatch. On calibration, the expectation includes a list of equipment, identification and due dates, protection from unauthorised adjustment, and a record of what you did when something is found to be out. Where safety, legality or quality depended on an instrument that turns out to be wrong, product at risk must not go out.

Personnel: Trained, Supervised, Hygienic

Everyone who can affect product has to be trained before they start and supervised while they work. That includes agency staff, contractors and home workers. Induction has to cover your hygiene rules. Training should be in a language people understand, the effectiveness of the training and the trainers should be reviewed and anyone doing monitoring activities needs a specific competency check. Records need to show who, when, what and by whom.

Protective clothing and personal hygiene both rest on risk assessment. You decide what is needed and where, and if you decide an area does not need it, you justify that in writing. There are rules to define for wearing clothing outside the area, for gloves, for laundering and for jewellery, nails and plasters. Hand cleaning, eating, drinking and smoking all have clear expectations, and so does telling the site about infectious illness where it is a risk to product.

My Model: The Three Moments

When I walk a line, I look at three moments. Most failures sit in one of them.

The start. Is the line clear of the last job, are the right materials and documents there, and is it recorded and signed off before anyone presses go?

The change. When something is adjusted, a changeover happens or a new product starts, is there a check, and does it have a record? Line clearance, packing checks and process checks after adjustments all live here.

The finish. At the end of the run, is the last check done, is the product held until it is released and does release actually need everything to be complete?

Pick any line, any shift. If someone can show you the start, change and finish records in a few minutes, you are in good shape. If they have to hunt, so will the auditor. Picture an operator who clears the line from habit but has no signature to show it. The work was done, and for audit purposes it was not.

Where Sites Get Caught Out

The usual ones: control limits that exist on paper but are not on the work instruction, calibration lists that are missing a gauge someone uses every day, training records with no competency check for the people monitoring, and contractors who were never inducted. Another is a HARA that says one thing and a test schedule that says another. They should match, which is why I wrote about the HARA separately.

If you would like a second opinion on how your shop floor measures up, a short remote gap analysis can walk through these sections with you. For the route to the audit date, see my Issue 5 transition plan.