BRCGS Consumer Products Issue 4 Section 7: Personnel, Training, Protective Clothing and Hygiene

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

Section 7 closes Issue 4 with the resource every other section depends on: people. Training and competency, protective clothing, and hygiene practices. It reads as the gentlest section in the standard, and it is where auditors quietly verify everything else, because an operator who does not know why a control exists is a control that is not really operating.

Training and Competency

The requirements: everyone affecting product safety, legality and quality trained before starting work and supervised until competent, including temporary staff and contractors, with induction covering hygiene rules, job-specific training, competency assessed rather than assumed, refreshers at appropriate intervals, and records of all of it. The findings follow a familiar shape. The training matrix that stopped being maintained when someone left. Agency staff on the line whose induction happened, if at all, in a language they do not speak, the standard expects training delivered so people actually understand it. And the signature-only record: attendance proves presence, not competence, so build in the assessment, questions, observation, sign-off by a supervisor, and record that. The audit test is conversational: the auditor asks an operator what they check, why, and what they do when it is wrong. Coached answers collapse under the second follow-up question, genuine understanding does not.

Protective Clothing

Requirements for protective clothing must be risk-based and documented: what is worn where, laundering arrangements that actually get garments clean, changing rules between areas of different requirements, and rules that bind visitors and contractors as tightly as staff. The two chronic findings: home laundering with no defined instructions where the risk assessment quietly assumed professional laundering, and the manager or visitor waved through the rules that operators are disciplined against, which does more cultural damage than any poster can repair.

Hygiene Practices

Hygiene rules, jewellery, hand cleaning, covering cuts with monitored site-issued plasters, metal-detectable where detection is used, eating, drinking and smoking confined to designated areas, must be documented, communicated, and enforced consistently. Consistency is the whole game: rules applied to some people some of the time are not rules, they are suggestions, and audits surface the difference within an hour on the floor.

What Changes Under Issue 5

Issue 5, as per the public draft, keeps training and competence as a Fundamental, restructures the section into training, protective clothing, personal hygiene, personnel facilities and a new medical screening element, and for qualifying products layers the enhanced hygiene requirements of Section 7 on top, see my enhanced hygiene mapping and the full Issue 5 breakdown. That completes the series: back to the series hub, and if your Issue 4 audit is approaching, the buttons below are the fastest route to a second pair of eyes.