What an auditor asks to see for packaging and PPE

For each item you need a spec sheet, a declaration of compliance, a supplier certificate, and where it applies a safety data sheet or a PPE declaration of conformity. All of it current, and all of it to hand in minutes, not "I'll find it for you after lunch". That's what an auditor asks to see, and the gap between having a document somewhere and having it ready is where sites lose marks.

Why does an unannounced audit catch people out?

Under BRCGS, sites on the announced programme must also take a mandatory unannounced audit once every 3 years. You know it's coming at some point. You just don't know when.

An unannounced visit doesn't test your best week. It tests your normal week. Auditors do spot checks: pick a pallet of film, a box of gloves, a drum of sanitiser, and ask for the paperwork behind it. If the file is in the buyer's inbox and the buyer is on holiday, you have a problem.

We started inside a UK food factory and lived this. The thing manufacturers tell us most is the chasing. One item can have several certificates, from several suppliers, in several formats, each with its own renewal date. Multiply that by every consumable on site.

What documents does each item need?

Start with the specification sheet. It says what the product is, what it's made from, its size and weight, and how it should be used. Under SALSA, specifications are expected for all materials, including food contact packaging, signed and dated. A safety data sheet isn't a spec, and auditors know the difference.

Next, for plastic that touches food, the declaration of compliance. Under GB food contact law (retained Regulation 10/2011, Article 15 and Annex IV), it should name the issuer, the manufacturer or importer, identify the material, carry a date, confirm compliance, list any restricted substances and set out the conditions of use. A one line email saying "it's food safe" doesn't cover it.

Then the supplier certificate, such as a site certification for the maker, which feeds your supplier approval. For chemicals such as sanitisers and degreasers, you need the safety data sheet, which is required under UK REACH for hazardous chemicals.

For PPE, you need the declaration of conformity. UKCA or CE marking is accepted, and CE is recognised in Great Britain indefinitely from 1 October 2024. Gloves, coats, footwear and eye protection each need their own.

What do BRCGS and SALSA expect to see?

We aren't quoting clause text here, and what follows is as commonly summarised by consultants and training providers. Read the standard itself for the exact wording.

Under BRCGS Issue 9, supplier management is a fundamental requirement. Suppliers, including those providing primary packaging, are approved on a risk basis, which might be a certificate, an audit or, for low risk items only, a questionnaire. Approval is reviewed at least every 3 years. Specifications are reviewed at least every 3 years too, and goods are checked on receipt, primary packaging included. Traceability is also a fundamental.

SALSA looks for the same thing in plainer terms: a signed, dated spec for what you buy, and a visit every year.

What happens if the paperwork isn't there?

The soft cost is time. Say your QA lead spends 2 days before every audit ringing round for certificates. That is 2 days not spent on the floor.

The harder cost is the grade. Under BRCGS, grades run from AA to D, and as commonly summarised a site gets a D if there is any critical or 3 or more majors. A major against a fundamental requirement, such as supplier management, prevents certification. How a gap is graded is the auditor's call. But a pattern of missing certificates looks like a failure of the supplier approval system, and that is the kind of finding that can rise to a major.

Then there's your customers. Many retailers and large buyers expect certification at a set grade. A lower grade or a failed certificate puts you in conversations you don't want to have, and some contracts depend on it. We can't tell you what yours will say, but you should read it.

Can the law reach you directly?

Yes. In England, the Food Contact Materials Regulations 2012 allow enforcement officers to serve compliance notices (regulation 19A). Offences carry fines that are unlimited in magistrates' courts since 2015. Directors can be personally liable in some circumstances under regulation 21.

Business Companion, the official guidance for businesses, says to ask your supplier for a declaration of compliance, keep it, and expect Trading Standards or environmental health to ask for it.

Not sure what yours are missing? Send us your consumables list and we'll show you.

How do you fix it?

Build one document register. A spreadsheet is fine to start. One row per item: product, supplier, spec sheet date, declaration of compliance date, certificate expiry, SDS date, PPE declaration, and the name of the person who owns the row.

Set the review cycle. We suggest checking expiry dates monthly and reading each spec properly at least every 3 years, matching what BRCGS commonly summarises. Someone in QA owns the register, and a named deputy covers holidays.

Keep everything in one place, with one naming scheme. Not the buyer's inbox, not 3 shared drives. Then run your own unannounced spot check each quarter: pick 5 items at random and time how long the paperwork takes to find. If it's longer than 5 minutes, tidy up.

Illustrative example: 60 items, one afternoon

Say you buy 60 consumable lines, and each needs 4 documents. That's 240 documents, each with a date. If even a quarter are out of date at any moment, that's 60 gaps an auditor can find.

If chasing each takes 20 minutes, that's 20 hours. One person, most of a working week, and it comes round again next year. The register turns that into a 10 minute monthly check.

What do we do at KP?

Every client gets their own login with every spec sheet, certificate and declaration of compliance for what they buy from us. When the auditor arrives, you open one screen.

There are several manufacturers behind every product we supply, and we do the chasing so you don't have to. We test what you buy, lock the spec and never swap without your approval.

Frequently asked questions

How often should I review supplier documents?

Check expiry dates at least monthly. Review specifications and supplier approval at least every 3 years, as BRCGS is commonly summarised, and sooner if the product changes.

Do I need a declaration of compliance for every plastic item?

For plastic materials meant to touch food, yes. Ask the supplier for it, check it covers the contents listed in Annex IV, and keep it where you can find it.

Is a safety data sheet the same as a spec?

No. SALSA guidance is clear that an SDS isn't a specification. You need both for chemicals.

Does an unannounced audit replace my announced one?

No. On the announced programme, the unannounced audit is an additional mandatory audit at least once every 3 years.

Send us your consumables list

Email us your list of packaging, wrap, gloves, coats and chemicals. We'll show you which documents you should hold for each, and which are missing.

We can also walk your site with your operations team. It takes about 30 minutes, you get a written report, and there's no contract. Testing is arranged only where needed.

Email sales@kptrading.uk or call 020 4576 5500.

Sources

ASC Food Safety, BRCGS Issue 9: https://ascfoodsafety.com/?p=41258

Techni-K, managing suppliers: https://techni-k.co.uk/supplier-management/managing-suppliers/

DQS, BRCGS Food Issue 9 changes: https://www.dqsglobal.com/intl/learn/blog/brcgs-food-issue-9-new-clauses-and-changes-in-this-revision

High Speed Training, BRCGS: https://www.highspeedtraining.co.uk/hub/?p=52167

Campden BRI, BRCGS 9 common non-conformances: https://campdenbri.co.uk/blogs/brcgs-9-common-non-conformances.php

IFST, SALSA raw materials specifications: https://www.ifst.org/sites/default/files/1.6.2%20Raw%20Materials%20Specifications%20Issue%205.pdf

SALSA FAQ: https://www.salsafood.co.uk/faq

Regulation 10/2011 Article 15: https://www.legislation.gov.uk/eur/2011/10/article/15

Regulation 10/2011 Annex IV: https://www.legislation.gov.uk/eur/2011/10/annex/IV

Regulation 1935/2004 Article 17: https://www.legislation.gov.uk/eur/2004/1935/article/17

Business Companion, food contact materials: https://www.businesscompanion.info/node/827/printable/pdf

Food Contact Materials Regulations 2012, reg 19A: https://www.legislation.gov.uk/uksi/2012/2619/regulation/19A

Legal Aid, Sentencing and Punishment of Offenders Act 2012 s85: https://www.legislation.gov.uk/ukpga/2012/10/section/85

HSE, safety data sheets: https://hse.gov.uk/chemical-classification/labelling-packaging/safety-data-sheets.htm

Illustrative figures are labelled in the text. Images are illustrative.