Case Study: Food Manufacturer Chemical Segregation — BRC Audit Failure to Pass

Food Manufacturer Chemical Segregation

BRC Global Standard Audit — Major Non-Conformance to AA Grade Achievement

📍 Yorkshire 🍽 Ready Meals Manufacturer 📋 BRC Global Standard v9 ✅ AA Grade Achieved
BRC Compliance Chemical Segregation COSHH Food Safety COSHH Store Clause 4.8

Executive Summary

A Yorkshire-based ready meals manufacturer supplying major UK supermarket chains received a major non-conformance (NC) against Clause 4.8 (Chemical and Physical Product Contamination Control) during a BRC Global Standard for Food Safety Version 9 audit. The non-conformance cited inadequate chemical storage, the absence of secondary containment, and missing COSHH risk assessments. This case study details the audit findings, the corrective action plan implemented, the COSHH store installation, chemical risk assessment programme, and the outcome of the re-audit — which achieved an AA grade, the highest BRC rating.

Background — The Manufacturing Site

The facility operates as a 24-hour, 7-day production site producing chilled ready meals across 6 production lines. The site employs 340 staff across production, hygiene, quality, and engineering functions. Chemicals on site include cleaning-in-place (CIP) chemicals, manual cleaning and sanitising chemicals, engineering lubricants and hydraulic oils, pest control baits, and laboratory reagents.

The site had held BRC certification for 11 years. However, a change of certification body and the appointment of a more experienced BRC auditor with a specific expertise in chemical contamination control led to significantly more rigorous scrutiny of chemical management during the annual re-certification audit.

📋 BRC Global Standard v9 — Clause 4.8 Chemical and Physical Product Contamination Control

Clause 4.8 requires that companies have documented procedures and controls in place to prevent chemical contamination of products. Key requirements relevant to this case include:

  • 4.8.1: Only chemicals necessary for the operation of the facility shall be present on site; all chemicals shall be approved for use in a food manufacturing environment
  • 4.8.2: Chemicals shall be stored in a designated, locked area and handled by trained personnel only
  • 4.8.3: Chemical containers shall be clearly labelled, and chemicals used in food-contact areas shall be approved for food contact use
  • 4.8.4: COSHH risk assessments shall be in place for all hazardous chemicals in use, and staff shall be trained on the hazards and controls
  • 4.8.5 (implicit): Chemicals shall be segregated from food, ingredients, and packaging at all times; incompatible chemicals shall be stored separately

🔴 Major Non-Conformance — Audit Findings

The BRC auditor recorded the following specific observations leading to the major non-conformance rating:

  1. Chemical above food ingredients: In the ingredients store, 5-litre containers of caustic CIP chemical were observed on a shelf directly above open bins of dried pasta and rice ingredients. This created a direct risk of chemical contamination of food ingredients from leaks, spills, or accidental knockover.
  2. No secondary containment: Bulk CIP chemicals (25L containers and 200L drums) were stored in the chemical store without any secondary containment (bunding or drip trays). A leak or drum failure would result in chemical spreading across the store floor with no containment.
  3. Inadequate COSHH assessments: Of 47 chemical products in use on site, only 9 had current COSHH risk assessments. Assessments for the remaining 38 products were either absent (22) or more than 3 years old and not reviewed (16).
  4. No chemical approval register: No documented register of approved chemicals existed; the auditor was unable to confirm that all chemicals in use had been approved for use in a food manufacturing environment.
  5. No training records: No evidence of staff training on chemical handling, spill response, or COSHH was available for hygiene or production staff.

Classification: Major Non-Conformance against Clause 4.8.2, 4.8.4, and 4.8.5. A major non-conformance results in conditional certification only, requiring satisfactory close-out evidence to be submitted to the certification body within 28 days.

Corrective Action Plan

The Quality Manager engaged our team within 24 hours of receiving the audit report. A corrective action plan (CAP) was developed within 72 hours, covering four parallel workstreams with a 90-day implementation target:

🏗 Workstream 1: Infrastructure

Install dedicated COSHH chemical store, secondary containment, and segregated storage for incompatible chemicals

📋 Workstream 2: Documentation

Produce COSHH risk assessments for all 47 chemicals, create approved chemical register, establish chemical control procedure

👥 Workstream 3: Training

Deliver COSHH and chemical handling training to all relevant staff; create training records

🔄 Workstream 4: Process

Implement chemical approval and review process; establish audit schedule for chemical store

COSHH Store Installation & Product Specification

Item Specification Quantity Purpose
Main COSHH Chemical Store Modular COSHH store unit, 1800W × 900D × 2100H mm, lockable, ventilated (forced extraction fan), yellow powder coat, internal shelving, integrated 250L sump bund floor, ATEX-rated electrical 1 unit Central chemical store for all cleaning chemicals and CIP products
Flammable/IPA Cabinet EN 14727 flammable cabinet, 90-min fire resistance, 100L capacity, self-closing door, earthing provision 1 unit Laboratory IPA and alcohol-based sanitisers (food-contact grade)
Drum Bund Pallets HDPE drum bund pallet, 4-drum capacity, 250L sump, with removable grating 2 units Secondary containment for 200L CIP chemical drums
Shelf Drip Trays HDPE shelf drip trays, 600×400mm, 30mm lip, for 5L–25L container storage 20 units Under containers on COSHH store shelving; captures minor drips/leaks
Incompatible Chemical Dividers Lockable secondary cabinet within main COSHH store (600W, partitioned), for acid/alkali segregation 1 unit Segregates caustic (alkali) CIP chemicals from acid CIP chemicals
Chemical Spill Kit (COSHH Store) Chemical spill kit, 50L capacity, in wall-mounted cabinet within COSHH store, includes nitrile gloves, goggles, neutraliser sachets, disposal sacks 1 unit Immediate spill response within chemical store
Chemical Spill Kits (Production Floor) Chemical spill kit, 20L capacity, wall-mounted at each CIP dosing station 6 units One per production line at CIP connection point
Approved Chemical Signage Chemical store signage pack: COSHH, PPE requirements, emergency contacts, no food or drink, authorised personnel only 1 set COSHH store perimeter and entrance
COSHH Register Boards A2 COSHH chemical register board, lockable document holder for risk assessments, chemical inventory list with SDS index 1 unit Mounted at COSHH store entrance; auditor reference point

Chemical Risk Assessment Programme

The COSHH risk assessment programme was delivered in three phases over 60 days:

Phase 1 — Chemical Inventory: A complete chemical inventory was compiled from procurement records, supplier SDS sheets, and physical walkthrough of all production areas, stores, engineering workshop, and laboratory. The inventory identified 47 products in active use, plus 12 obsolete products still physically present on site (removed and disposed of as part of Phase 1).

Phase 2 — Risk Assessment Production: COSHH risk assessments were produced for all 47 active chemicals, using a standardised format reviewed by an occupational hygienist. Each assessment covered:

  • Substance identification, concentration, and volume in use
  • Health hazards (based on current SDS, CLP classification)
  • Routes of exposure (inhalation, skin contact, ingestion, injection)
  • Control measures: substitution review, engineering controls (ventilation), PPE requirements
  • Monitoring and health surveillance requirements
  • Emergency procedures: spill response, first aid, evacuation triggers

Phase 3 — Approved Chemical Register: A formal approved chemical register was established, requiring Quality Manager sign-off for any new chemical introduced to site. The register confirmed that all 47 chemicals had been reviewed against BRC and food contact requirements, with 4 products replaced by food-grade alternatives (the non-food-grade versions were removed from site).

Key Lesson — Chemical Substitution: The risk assessment process identified four cleaning chemicals that were not approved for use in food manufacturing environments (specifically, they were not produced in conformance with EC Regulation 1935/2004 on materials in contact with food, or did not have food-grade SDS documentation). Replacing these with food-grade equivalents — at no significant cost premium — removed a potential BRC non-conformance risk and improved the site's due diligence position.

Staff Training Programme

A three-tier training programme was delivered to 340 staff across 8 weeks:

  • Tier 1 — All Staff (340 personnel): 30-minute COSHH awareness session covering chemical hazard identification, PPE, what to do if you encounter a spill, and how to raise a chemical incident report. Delivered via toolbox talk format to production shifts.
  • Tier 2 — Hygiene & Cleaning Teams (48 personnel): 2-hour practical training session: safe handling of CIP and cleaning chemicals, correct dilution procedures, PPE fitting and inspection, spill kit use, SDS reading, and emergency response. Practical competency assessment completed.
  • Tier 3 — Supervisors & Quality Team (22 personnel): Half-day COSHH management session: legal responsibilities, chemical control procedures, audit requirements, COSHH register maintenance, and first-response management of chemical incidents.

✅ Re-Audit Outcome — AA Grade Achieved

AA Grade

The BRC re-certification audit was conducted 4 months after the original major NC audit. Results:

  • Clause 4.8 rating: Compliant — "Satisfactory evidence of corrective action. Chemical storage, secondary containment, COSHH documentation, and staff training all found to be in order."
  • Previous major NC closed with full documented evidence accepted
  • No new NCs raised against chemical management during the re-audit
  • Overall site rating: AA — the highest BRC certification grade, awarded where no major or critical NCs are raised and minor NCs are within threshold
  • The auditor specifically commented: "The chemical management programme demonstrates a genuine step-change in approach, with robust documentation, appropriate infrastructure, and clear staff ownership of chemical control responsibilities."
  • The AA grade enabled the manufacturer to retain supply contracts with two major retail customers who require BRC AA certification as a supplier qualification criterion
⚠️ Commercial Impact of BRC Non-Conformance: Two of the manufacturer's major retail customers had supply contracts that required BRC Grade A or above as a minimum qualification. The major non-conformance issued in the initial audit reduced the site's certification to Conditional, which technically triggered a supplier review clause. The 90-day corrective action programme and successful re-audit prevented contract suspension — but the experience underscored the direct commercial consequences of chemical management failures in food manufacturing.

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Frequently Asked Questions

What does BRC Clause 4.8 require for chemical storage?
BRC Global Standard for Food Safety v9 Clause 4.8 requires that all chemicals on site are approved for use in a food manufacturing environment, stored in a designated locked area, clearly labelled, and managed by trained personnel. COSHH risk assessments must be in place for all hazardous chemicals. Chemicals must be segregated from food, ingredients, and packaging, and incompatible chemicals (such as acids and alkalis) must be stored separately. Secondary containment is required for liquid chemicals to prevent spills from spreading and causing contamination. A documented approved chemical register must be maintained.
What is a major non-conformance in a BRC audit?
A major non-conformance (NC) in BRC Global Standard audits represents a substantial failure to comply with a requirement of the Standard that poses a risk to product safety, legality, or quality, or indicates a significant breakdown in the food safety management system. A major NC results in conditional certification only — the site retains BRC status but must provide documented evidence of corrective action to the certification body within 28 days. Two or more major NCs in a single audit, or a major NC on a re-audit visit, results in certificate withdrawal and a full re-audit requirement.
Does a COSHH store need ventilation in a food factory?
Yes. COSHH Regulations 2002 require that chemical storage areas are adequately ventilated to prevent the build-up of hazardous vapours to concentrations that could harm staff. In food manufacturing environments, ventilation from COSHH stores must be directed away from food production, storage, and packing areas to prevent any chemical vapours contaminating food or food-contact surfaces. Typically, mechanical extraction ventilating to atmosphere (away from air intakes) is specified for COSHH stores in food factories. ATEX-rated extraction fans are required where flammable vapours may be present.
How often should COSHH assessments be reviewed in a food factory?
COSHH risk assessments should be reviewed at least annually, and immediately when there is any change to the chemical product (formulation, concentration, or supplier), change to the task or work method, new health evidence, or following a near-miss or incident. BRC auditors expect to see evidence of regular review — assessments that have not been reviewed in more than 12 months may be flagged as an observation or minor non-conformance. In practice, tying COSHH assessment reviews to the annual chemical register review creates an efficient combined process.
What is the difference between BRC Grade A and AA?
Under the BRC Global Standard for Food Safety v9, the grade awarded depends on the number and type of non-conformances raised during the audit. AA grade (the highest) is awarded where the audit is conducted unannounced and no major or critical non-conformances are raised; the number of minor NCs is below the threshold. Grade A is awarded for announced audits with no major/critical NCs and minor NCs below threshold. Grades B, C, and D reflect increasing numbers of minor or major non-conformances. Many UK supermarket and food retail buyers require Grade A or AA as a minimum supplier qualification, and AA specifically is often required for preferred supplier or partnership programmes.

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