Global standard BRC: Novedades versión 9

La Norma BRC (British Retail Consortium), en su versión 9 (v. 9), recoge los requisitos necesarios que debe cumplir una empresa dedicada a la fabricación de alimentos con el fin de que obtengan la certificación conforme a la Norma Mundial de Seguridad Alimentaria. Dicha certificación, garantiza la seguridad, integridad, legalidad y calidad de los productos alimenticios a lo largo de toda la cadena de producción.

Dentro de la Norma BRC (v.9), existen una serie de requisitos considerados “Fundamentales”. La Limpieza e Higiene (cláusula 4.11) es uno de ellos, resultando así ser un sistema esencial para la elaboración y aplicación de un programa eficiente de calidad y seguridad alimentaria.

Consequencias de la falta de adherencia a los requerimientos

El incumplimiento de los requisitos fundamentales recogidos en la norma BRC y la presencia de desviaciones críticas pueden tener consecuencias graves. Una de las más importantes, sería la no obtención o la pérdida de la certificación, generando una desventaja frente a competidores o la pérdida de confianza del resto de partes interesadas (proveedores, clientes y consumidores), entre otros.

Asimismo, una implementación ineficaz de los procedimientos de limpieza e higiene puede traducirse en brotes de enfermedades de transmisión alimentaria, contaminación o presencia de alérgenos en productos de consumo humano. Dichas situaciones, afectan a la salud
del consumidor, conllevan a la retirada del producto del mercado y, por
tanto, causan daños económicos y al prestigio de las empresas.

Clause 4.11 Requirements and Their Effective Implementation

The successful implementation of the fundamental requirements, and specifically those set out in Clause 4.11 (Cleaning and Hygiene), depends on the level of compliance with and adherence to the requirements of the Standard.

Broadly, Clause 4.11 is divided into three sections: general requirements, requirements for the development of an effective Cleaning-in-Place (CIP) programme, and requirements for the environmental monitoring programme.

The contents of this clause are summarised and explained below to provide a better understanding of each requirement and its application.

General Requirements

4.11.1. Plant equipment and facilities shall be maintained in a clean and hygienic condition. The general condition of the facility and the specific condition of the equipment will be assessed during the on-site audit. Records of cleaning activities carried out prior to the audit will be reviewed and verified.

4.11.2. Documented cleaning and disinfection procedures shall be implemented and maintained for the building, production areas, and all equipment.

Cleaning procedures established for food processing equipment and food-contact surfaces shall include, as a minimum:

• Personnel responsible for carrying out the cleaning: ensure that they have received appropriate training.
• Item or area to be cleaned: identification of the equipment, component, or area.

• Cleaning frequency (daily, weekly, monthly, or other) and cleaning method (manual, immersion, foam cleaning, or other), based on risk assessment. Where necessary, the procedure shall include the disassembly of equipment parts. Access to all hard-to-reach areas is essential to prevent contamination.

• Cleaning chemicals and use concentrations: refer to the product technical data sheet or the supplier's instructions. 

• Cleaning materials and tools: scouring pads, brushes, etc., identified according to the established colour-coding or identification system. 

4.11.3. Validation of cleaning and disinfection processes for equipment and food-contact surfaces shall be available, together with acceptable and unacceptable cleanliness limits based on the potential risks associated with the product or processing area.

Methods for verifying the effectiveness of cleaning and disinfection shall be implemented as appropriate (visual inspection, microbiological surface analysis, etc.). Corrective actions to be taken in the event of deviations from established limits shall also be defined. For example, a corrective action may consist of performing an intensive cleaning of the contaminated area using cleaning chemicals that are more effective than those routinely applied.

4.11.4. Adequate resources shall be available to ensure the effective and planned cleaning of both the external and internal surfaces of equipment. Particular attention should be paid where equipment disassembly is required, as this may involve support from other departments, such as Maintenance.

4.11.5. Records of cleaning verification results shall be maintained, regardless of the verification method used, to ensure that production starts without any risk of contamination and to identify trends in cleaning performance, thereby enabling the implementation of improvements where necessary.

For example, some bacteria may develop resistance to certain disinfectants following prolonged use. Historical trend analysis of results can support changes in the active ingredient of the disinfectant used in order to improve microbiological performance.

In addition, the database used for the statistical evaluation of results should include, as a minimum, information on the sampling location, its criticality, and the microbiological results obtained from the sampled points over a defined period.

4.11.6. Cleaning equipment and materials shall be hygienically designed, suitable for their intended use, and colour-coded to prevent cross-contamination between areas with different hygiene requirements. They shall be kept clean at all times and stored in a manner that prevents contamination.

CIP Requirements

4.11.7.1. It is essential to have validation demonstrating the correct design and operation of the CIP system, together with an up-to-date schematic diagram of its configuration. The documentation should include as much information as possible regarding the characteristics of the installation, including: equipment to be cleaned, pipe diameters and lengths, pump flow rates and capacities, among other relevant details. Particular attention should be paid when rinse solutions are recovered or reused during CIP operations, as a risk assessment for cross-contamination must be conducted.

Modifications to the CIP system may only be carried out under the authorization of a suitably trained person, as changes to cleaning recipes or programmes may have serious consequences, such as the presence of chemical residues in the final product due to insufficient rinsing. Any changes, once reviewed and approved, shall be documented and retained.

All the points mentioned above shall be revalidated at a frequency based on risk and following any modification or addition to the system, in order to ensure effective cleaning.

4.11.7.2. The elimination of hazards shall be ensured through the validation of critical limits for the key CIP process parameters. As a minimum, these parameters include: stage times, detergent and disinfectant concentrations, flow rate, pressure, and temperature. All limits shall be documented following validation, which should be performed over a sufficient number of cleaning cycles to obtain statistically meaningful data, taking into account the types of residues and the characteristics of the installation. As a minimum, three cleaning cycles are recommended.

4.11.7.3. CIP equipment and components shall be properly maintained by suitably trained personnel to ensure that cleaning operations are carried out within the defined specifications.

In the day-to-day operation of a manufacturing facility, routine verification of detergent concentrations can help identify deviations in the preparation of CIP cleaning solutions, such as failures in the conductivity meters installed on the line. Likewise, monitoring recovered post-rinse solutions may provide indications of detergent carry-over accumulation within the system.

4.11.7.4. CIP installations shall be monitored at a defined frequency based on risk assessment. Monitoring activities may include:

• Verification of the process parameters defined in Clause 4.11.7.2.
• Verification of correct connections, pipework, and system configurations.
• Confirmation that the process is operating correctly and that the cleaning cycle is being completed as intended.
• Monitoring to ensure that effective cleaning results are achieved.

Procedures shall define the actions to be taken when monitoring indicates that the process is operating outside the established limits.

It is recommended that periodic validations be carried out in collaboration with the chemical supplier to ensure optimum operating conditions. In addition, audits aimed at reducing water and chemical consumption should be conducted, as environmental requirements are becoming increasingly demanding.

Environmental Monitoring: Surface Monitoring

The Standard requires the implementation of risk-based environmental monitoring programmes for pathogens and/or spoilage organisms. At a minimum, all production areas handling open products and/or ready-to-eat products shall be included.

4.11.8.1. The environmental monitoring programme shall be risk-based and shall include, as a minimum:

• Sampling procedures and the identification of sampling locations.
• Testing frequency and target organisms.
• Testing methods.
• Recording and evaluation of results.

Both the programme and the associated procedures shall be documented.

Environmental air sampling should also form part of this programme and may be carried out using automatic air-sampling equipment. Particular attention should be paid to cleanrooms, where the proper design and control of airflow patterns are critical to preventing cross-contamination. High levels of environmental contamination may result from inadequate surface cleaning. Furthermore, when cleaning equipment generates aerosols or airborne particles, contamination may be dispersed throughout the environment. To complement the cleaning and disinfection of areas, equipment, and surfaces, environmental disinfection may be carried out using authorised airborne disinfectants and dedicated application systems.

4.11.8.2. Control limits and corrective actions shall be defined to address deviations or any upward trend in monitoring results.

4.11.8.3. The programme shall be reviewed by the company at least annually, or whenever any of the following situations occur:

• Changes in processing conditions, process flow, or equipment that may affect the environmental monitoring programme.
• New scientific developments or updated technical knowledge.
• Audit findings that were not previously identified through the environmental monitoring programme.
• Positive product results or consistently negative results that may indicate the need to review the effectiveness of the programme.

Most Common BRCGS Non-Conformities

According to the BRCGS Food Safety Annual Report (2024–2025), the five most frequently identified food safety non-conformities are:

1. Clause 4.11.1: Facilities and equipment are not maintained in a clean and hygienic condition (4,715 non-conformities).
2. Clause 4.6.2: Equipment design and construction do not adequately consider contamination risks and the prevention of product contamination (3,322 non-conformities).
3. Clause 4.9.1.1: Lack of adequate procedures for the use, storage, and handling of chemicals to prevent chemical contamination (3,284 non-conformities).
4. Clause 4.4.8: Internal and external doors are not maintained in good condition (3,007 non-conformities).
5. Clause 4.4.1: Walls are not adequately finished or maintained to prevent the accumulation of dirt, condensation, or mould and to facilitate cleaning (2,933 non-conformities).

These figures show that Clause 4.11.1, relating to the maintenance of facilities and equipment in a clean and hygienic condition, remains the leading source of non-conformities, accounting for a total of 4,715 cases.

This finding highlights the challenges faced by the food industry in maintaining adequate standards of operational hygiene and underscores the importance of regularly reviewing and strengthening cleaning and disinfection procedures.

Conclusion

In this context, Proquimia’s more than 50 years of experience in the field of food hygiene demonstrate that effective compliance with regulatory requirements depends not only on a thorough understanding of the applicable clauses, but also on their correct and consistent implementation over time.

The combination of specialised chemical solutions (cleaning and disinfection products) with the design, implementation, and verification of cleaning and disinfection processes tailored to each facility is essential for minimising risks and ensuring consistent results. This approach not only supports compliance with the requirements of the BRCGS Food Safety Standard, but also helps optimise resources, reduce non-conformities, and achieve higher levels of operational excellence.

Ultimately, adopting a comprehensive approach to cleaning and disinfection—integrating products, processes, and control measures—is the most effective way to ensure food safety, protect brand reputation, and meet the increasingly demanding expectations of the market.

Bibliografía

Brcgs. (2022). BRC Global Standard for Food Safety: Issue 9. British Retail Consortium.
https://www.brcgs.com

Brcgs. (2025). BRCGS Annual Report 2024-25. Https://www.brcgs.com/media/zqxnctso/brcgsannualreport2024-25-screen.pdf