Top BRCGS Nonconformances 2024-2025: Close Them Before Audit

4,715 Times, Auditors Wrote Down the Same Finding

BRCGS published its 2024–2025 achievements report with a number that should embarrass the industry: more than 100,000 nonconformities raised under the BRCGS Food Safety Standard Issue 9 in 2024 alone, with manufacturers averaging just under five findings per audit. The single most cited clause wasn’t a complex HACCP calculation or a subtle allergen validation. It was Clause 4.11.1 — premises and equipment shall be maintained in a clean and hygienic condition — with 4,715 nonconformities. Fifty-nine percent of all findings fell under Section 4, the site-standards section covering buildings, equipment, and hygiene. Read that again: after decades of food safety management systems, the thing auditors most often find wrong is whether the place is clean. Your next GFSI audit will probably not be decided by your hazard analysis. It will be decided by a drain, a door, or a cleaning record.

Finding #1: Premises and Equipment Not Clean (Clause 4.11.1)

Clause 4.11.1 fails in practice long before it fails on paper. The documented cleaning schedule exists; the execution doesn’t match it. Auditors find buildup in hard-to-reach areas — behind equipment, inside framework, above the line where nobody looks — and cleaning routines that happen at inconsistent frequencies depending on who is on shift. Closing this finding means making cleaning verifiable rather than aspirational. Write the schedule with specific frequencies, methods, and responsibilities for every area, including the awkward ones. Verify with more than a supervisor’s initials: periodic visual inspection against a standard, ATP swabs on a rotation, and a pre-operational check that actually stops production when it fails. The deeper fix is cultural. When cleaning is the task handed to whoever finishes production first, it gets production-first effort. Facilities that close this finding permanently treat sanitation as a skilled function with trained people, measured results, and management attention — because auditors can tell within an hour which kind it is.

Finding #2: Equipment Design Ignores Contamination Risk (Clause 4.6.2)

Clause 4.6.2 requires equipment design and construction to be based on risk, preventing product contamination — and it drew 3,322 nonconformities. The typical story: new equipment arrives, gets installed, gets commissioned for output, and nobody assesses its hygienic design. Hollow rollers that trap water, rough welds that harbor biofilm, covers that can’t be removed for cleaning, equipment feet that create uncleanable floor junctions. The fix starts at purchase, not at audit: a hygienic design review before equipment is bought, with sanitation and quality at the table alongside engineering and production. For equipment already installed, run the risk assessment now — identify the contamination risks each item presents and document the controls, whether that’s modified cleaning procedures, additional covers, or scheduled deep-strip maintenance. Auditors love asking who assessed a piece of equipment and when. “The installer said it was food-grade” is not an assessment.

Finding #3: Chemical Control Gaps (Clause 4.9.1.1)

Chemical management drew 3,284 nonconformities under Clause 4.9.1.1, and the findings are depressingly basic: unlocked chemical storage, cleaning chemicals stored above or beside production areas, containers with missing or faded labels, no list of which chemicals are approved for use on site. The standard wants processes controlling the use, storage, and handling of chemicals to prevent chemical contamination, which translates into a short, non-negotiable list. Lock chemical storage and restrict access to trained personnel. Keep a current approved-chemical list with safety data sheets, and make sure every container on site matches it. Segregate chemicals from ingredients, packaging, and open product — physically, not just by good intentions. Label every secondary container. Then train the people who actually handle the chemicals, because the most common audit interview failure is a sanitation worker who can’t explain what they’re spraying or where the SDS lives. Chemical control is one of the cheapest findings to close and one of the most common to leave open. That combination tells auditors everything about priorities.

Findings #4 and #5: Doors and Walls (Clauses 4.4.8 and 4.4.1)

Two of the top five findings are literally about the building. Clause 4.4.8 — doors maintained in good condition — collected 3,007 nonconformities: external doors left open, dock doors with broken seals, internal doors that don’t close, gaps that invite pests. Clause 4.4.1 — walls finished and maintained to prevent dirt accumulation, minimize condensation and mold, and permit cleaning — added 2,933: damaged surfaces, flaking paint, condensation dripping in production areas. These are maintenance findings, which makes them management findings. A door seal doesn’t fail overnight; it fails over months while nobody’s job description includes noticing. The close is a preventive maintenance program with teeth: scheduled inspections of building fabric, a defect log with time-bound repairs, and pest-proofing treated as part of door maintenance rather than the pest contractor’s lonely problem. Walk your own perimeter monthly with fresh eyes. Auditors do it once a year, and they always find what daily familiarity hides.

The Pattern: Consistency Beats Systems

Step back from the five clauses and the pattern is unmistakable. None of the top findings is about missing systems — every one of these facilities had a HACCP plan, a cleaning schedule, a chemical procedure, a maintenance program. The findings are about systems that exist on paper and decay in practice. BRCGS data analysts have put it plainly: the number one nonconformity is a consistency failure, not a system failure. Traceability fails in practice, not in policy. Pest issues start with access, not infestation. Here’s the “yeah, but actually” for audit preparation: most pre-audit effort goes into documentation — polishing procedures, filling record gaps, rehearsing answers. Documentation matters, but auditors spend most of their time observing and interviewing, and they write findings on what they see people do. A perfect cleaning procedure that the night shift has never read is worth less than a decent procedure everyone follows. Before your audit, spend less time in the office and more time on the floor at 2 a.m. That’s when your real food safety system is on display.

A 90-Day Countdown That Closes Them

Ninety days out, run a full internal audit against your scheme’s standard — BRCGS, SQF, or FSSC 22000 — and grade it like the certification body would. Sixty days out, every finding gets a corrective action with a named owner, a root-cause analysis that goes past “human error,” and evidence the fix is implemented, not just planned. Thirty days out, verify: re-audit the corrected areas, check that cleaning verification records are complete, walk the building fabric, confirm chemical storage, and interview operators the way an auditor will. In the final week, review management commitment evidence — management review minutes, food safety objectives with progress data, resource decisions — because leadership engagement underpins every clause. And keep one principle through all of it: close findings by changing what happens on the floor, not by changing what the procedure says. Auditors certify reality. Make yours worth certifying.