Top BRGCS and FSSC non-conformances – what we can learn?

12 January 2026 | Richard Leathers, Global Quality Lead

Learning from the most common non-conformances, in audits for standards such as FSSC 22000 and the BRCGS Global Standard for Food Safety, can help food business operators to identify improvements for their own sites and systems, minimise their own audit non-conformances, and improve audit results.

Here we cover the key themes and focus areas that may be drawn from recent global non-conformance (NC) data of FSSC 22000 and BRCGS audits.

First, the global data:

Learning from the most common non-conformances, in audits for standards such as FSSC 22000 and the BRCGS Global Standard for Food Safety, can help food business operators to identify improvements for their own sites and systems, minimise their own audit non-conformances, and improve audit results.

Here we cover the key themes and focus areas that may be drawn from recent global non-conformance (NC) data of FSSC 22000 and BRCGS audits.

FSSC 22000

• Top major NCs
  1. Internal audits
  2. Traceability system
  3. Non-conformance and corrective action
  4. Monitoring systems
  5. Environmental monitoring
• Top minor NCs
  1. Quality control
  2. Physical contamination
  3. Food safety/quality culture
  4. Preventative maintenance
  5. Traceability system

BRCGS Global Standard for Food Safety

• Top major NCs
  1. Audit cycle dates (1.1.10)
  2. Pest assessment (4.14.10)
  3. Pest activity (4.14.1)
  4. Factory hygiene (4.11.1)
  5. Monitoring records (2.10.2)
• Top minor NCs
  1. Factory hygiene (4.11.1)
  2. Equipment design (4.6.2)
  3. Chemical control (4.9.1.1)
  4. Doors (4.4.8)
  5. Walls (4.4.1)

BRCGS Latest Overall Top 10 NCs

The overall top 10 BRCGS non-conformances (both major and minor), as confirmed in the latest BRCGS Technical Advisory Committee meeting, are as follows:

1. Hygiene (4.11.1)
2. Chemicals (4.9.1.1)
3. Equipment (4.6.2)
4. Doors (4.4.8)
5. Walls (4.4.1)
6. Ceilings (4.4.4)
7. Traceability/labelling (3.9.2)
8. Floors (4.4.2)
9. Storage (4.15.1)
10. Cleaning procedures (4.11.2)

What can we learn from this?

BRCGS section 4 non-conformances

Nine of the top 10 BRCGS non-conformances are for section 4 clauses. Similarly, physical contamination risks also rank highly in occurrences of FSSC minor non-conformances.

For much of these (e.g. hygiene, chemicals and especially doors/walls/ceilings/floors), it would not take an external auditor for these issues to be identified. See the below section on systems / internal audits / corrective action management for more on effectively finding and addressing such issues internally.

The aim of audits and of the sites receiving them is to drive forward food safety and quality, and it is unlikely that a focus on things like walls/floors/ceilings/doors will achieve this.

The apparent scale of these types of issue may be preventing a focus on other key areas, namely reviewing systems, applying best practice and driving continuous improvement. Even sites with good audit results and few section 4 issues need to ensure that their systems don’t have flaws.

It is possible that the scale of non-conformance for section 4 of the BRCGS Global Standard for Food Safety could mean that this section may see updates in the next issue (v10) of the standard, when it is reviewed and updated. For top scoring NCs, the working group typically explores why issues are recurrent.

Hygiene

The requirement in BRCGS clause 4.11.1 is:

“The premises and equipment shall be maintained in a clean and hygienic condition.”

Whilst many facilities may not always help themselves, it would be difficult not to find something for this clause. However, the Technical Advisory Committee hopes that auditors are pragmatic in the application of this clause and the practicality of their expectations.

The advice here is to put in place practical measures that facilitate a clean, hygienic environment – ensure that you can justify the schedules and practices that you have in place, and that you are demonstrating compliance to the plan that you have set out.

Within the same hygiene theme, environmental monitoring non-conformances are one of the top major FSSC non-conformances. We can help you design an optimal environmental monitoring plan that covers all necessary elements and works for you. We will ensure you know what to look for, how to take and handle samples, as well as what the information tells you and what to do with it. We can also support with how to manage unwanted or unexpected results.

Chemical control

Many instances of this can be as simple as decanting bulk chemical for local use, and the local container being inadequately labelled or unlabelled. Other common non-conformances in this area may relate to using a chemical at a different strength to that recommended by the supplier / documented in procedures.

In the case of not labelling decanted chemicals correctly, this is simple to fix – perhaps even more so than addressing factory cleanliness and hygiene (see above). Sometimes, however, things can be more complex / involve more chemicals than they first appear to (all of which need to be adequately controlled).

We are also always on hand to offer guidance and practical support.

Equipment

Across many relevant standards, there are now more detailed requirements regarding equipment. For example, section 4.6 was introduced into the BRCGS Global Standard for Food Safety as part of Issue 9. This means that you will potentially receive non-conformances that were not raised as such when you were audited against previous issues of the standard.

We can help you ensure that your equipment is compliant, from its design phase right through to installation and assessing existing process lines. We can support with troubleshooting of known issues with hygiene, conduct an independent review of your equipment, and provide training to support awareness of relevant requirements.

We are qualified by EHEDG (European Hygienic Engineering Design Group) to evaluate that equipment complies with their design criteria. We are also able to undertake assessment of in-place cleanability of food processing equipment, and are trained by 3A Sanitary Standards Inc in the USA to perform Third Party Verification of equipment or systems for conformance against 3A standards for sanitary equipment design, fabrication and construction material.

Maintenance of equipment is, of course, also an important consideration (see ‘preventative maintenance’ in the FSSC most common minor non-conformance list).

Internal audits and Non-conformance & corrective action

These two issues appear in the list of top FSSC 22000 major non-conformances, but could also be indicative of the sort of reason why BRCGS section 4 issues are not being addressed.

Food business operators must ensure their internal audit programmes not only demonstrate conformity with relevant standards, but also actively support continuous improvement.

With the high instances of non-conformance for both FSSC and BRCGS, there are several issues that could be happening here:

• Are the internal audits not finding NCs appropriately?
• Are the NCs being found, but the RCA is lacking?
• Are the corrective actions being identified but not being implemented?

Our food safety and quality management experts offer support with the planning, development, implementation and improvement of internal audit programmes, as well as training in this area. We can also assess the effectiveness of existing internal audit programmes and make recommendations for improvements.

When it comes to non-conformances and corrective actions, we can provide practical support with finding the true root cause and determining the right corrective and preventive actions to ensure that you have cost effective solutions in place. We can also support with ensuring robust systems for managing non-conformances and their corrective actions.

Food safety and quality culture

Food safety/quality culture non-conformance appears only in the top / most common list for FSSC 22000 minors, but seems to be a relevant theme for the majority of the BRCGS top non-conformances also. Namely in relation to the nature of section 4 issues, which could feed negatively into culture based on how on-the-ground team members may perceive things not being fixed when reported.

Preventative maintenance issues (FSSC non-conformances for which are in the top 5 most common minors) also link to food safety/quality culture. Both from the point of view of culture impacting how highly preventative maintenance is prioritised, as well as the impact that perceived neglect of preventative maintenance could have on culture.

Traceability

Traceability-related non-conformance appears in both the major and minor top / most common list for FSSC 22000 non-conformances, as well as in the latest top 10 BRCGS non-conformances list.

Traceability is a legal requirement, but is often found lacking retrospectively after an issue has occurred. We can help you to proactively review and improve your systems, as well as to troubleshoot and address when things go wrong.

Monitoring systems / monitoring records

When it comes to major non-conformances, monitoring systems issues are in the top most common list for FSSC 22000, as are monitoring records issues (2.10.2) for BRCGS.

There may be several causes of these monitoring issues:

• Are staff adequately trained?
• Has the importance and awareness of monitoring been reinforced? (Links to the above section on food safety/quality culture)
• Is there enough time to perform and record all tasks?
• Is this a one-off lapse or a more systemic failure?

How to comply and prevent non-conformances – we can help

We offer a wide range of technical support activities to help companies implement FSSC 22000, the BRCGS Global Standard for Food Safety, ISO standards, best practice guidance, troubleshooting and more. We support verification activities, including auditing – and can visit your facilities and support you in addressing the findings and implementing best practices.

Through our consultancy services, we can help you ensure compliance and prevent potential non-conformances. This can take the form of independent systems sense-checking and supporting improvements, through to hands-on input into developing and implementing your whole management system.

As members of EHEDG, we are a significant contributor to the development of guidelines and test methods to help industry comply with European Commission (EC) legislation for the safe and hygienic processing of foods. We are therefore best placed to support and advise on hygienic equipment design and construction.

How can we help?

If you’d like to find out more about how we can help you ensure compliance and prevent potential non-conformances, get in touch.

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