BRCGS Food Safety Issue 9: How to Avoid Major Non-Conformances in Section 3.5

## Navigating BRCGS Standard for Food Safety Issue 9 (Clause 3.5) Clause 3.5 is one of the most rigorously scrutinized sections during a BRCGS certification audit. It requires complete end-to-end evidence of supplier qualification and performance. ### 1. Risk-Based Supplier Approval (3.5.1.1) The standard requires documented risk assessment of all raw materials and primary packaging. This assessment dictates whether a supplier can be approved via: - Valid GFSI-benchmarked audit certification (SQF, BRCGS, FSSC 22000). - Supplier audit conducted by an experienced and qualified auditor. - Comprehensive supplier questionnaire (only permissible for low-risk commodities). ### 2. Exception & Emergency Approval Procedures (3.5.1.4) When raw materials are urgently sourced from a non-approved emergency supplier, specific controls must be enacted: - Documented authorization by a qualified technical manager. - Increased testing / Certificate of Analysis verification prior to release. - Hard expiration date on the emergency waiver. ### 3. Traceability of Primary Packaging & Ingredients BRCGS auditors will pull random lots during the vertical audit and demand immediate sight of the supplier qualification file active on the date of manufacture. Having an immutable digital audit trail ensures this evidence can be retrieved in seconds.