BRCGS Consumer Products Issue 4 Section 3 Part 1: Quality Management, Internal Audits and Supplier Approval

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

Section 3 is the engine room of Issue 4, big enough that I am splitting it across two posts. This first half covers the product safety and quality management system itself, document control, record completion, internal audits, and supplier approval with the control and acceptance of incoming materials, which carries Fundamental status at 3.5.2. If the audit goes wrong for a site, it usually goes wrong somewhere in here.

The System, Documents and Records

The expectations are unglamorous and non-negotiable: a fully implemented system that people can navigate, controlled documents where only current versions are in use, and records that are legible, authorised, retained and retrievable. The findings write themselves: obsolete versions on the shop floor, records completed in advance or in a suspiciously uniform pen at shift end, alterations with no authorisation. Auditors are professionally suspicious of perfect records, and genuinely respect a crossed-out entry with initials and a reason.

Internal Audits

The scheduled internal audit programme must cover the full system, use independent, trained auditors, and drive corrective action to closure. I have written a full guide to building the programme, so here I will only repeat the headline: your internal audit programme is the best predictor of your external audit result, and a programme crammed into the month before the audit predicts badly.

Supplier Approval and the Fundamental at Incoming Goods

Supplier approval must be risk-based and documented: certification, audits or questionnaires proportionate to what the material can do to your product, with ongoing performance monitoring, not a one-off form from 2019. My views on doing this without drowning your suppliers are in the supplier approval bottleneck piece: verify certificates through the BRCGS Directory and accreditation tools first, question second.

Then incoming goods, the Fundamental. Control and acceptance of incoming raw materials, components and packaging must ensure nothing enters your process that has not been verified against defined acceptance criteria, with material held until released where testing or verification is pending. Fundamental status means a major here is a certificate-ending event, as my Fundamentals article explains. The recurring finding: acceptance criteria that say check against specification while goods-in staff have never seen the specification. Walk your own goods-in with fresh eyes before the auditor does.

What Changes Under Issue 5

Issue 5 keeps this architecture but expands it, as per the public draft: outsourced processes and service supplier approval get their own sub-sections, internal audits must spread across the year, and incoming goods control remains Fundamental. Details in the Issue 5 breakdown. Back to the series hub, or on to Section 3 part 2.