BRCGS Gap Assessment NZ: Get Ready for a BRC Audit

A BRCGS gap assessment helps a New Zealand food business understand the work needed before its certification audit. Instead of beginning with a new manual or an audit booking, compare the site’s actual arrangements with the applicable requirements and identify where evidence or implementation is missing.

If a customer has asked for a “BRC audit”, confirm the exact standard and scope they mean. This article focuses on preparing for a gap assessment against BRCGS Food Safety and using its findings. It does not reproduce the standard or provide a complete certification checklist.

What should a BRCGS gap assessment answer?

The review should help management make a decision about the next work, rather than simply receive a score. Useful questions are: What have we assessed? What supports our conclusions? Which gaps need action? Who will implement and check the changes?

BRCGS includes gap analysis and action planning in its official route to certification. A gap review is most useful when it explains the difference between what a procedure says, what people do and what the available evidence demonstrates.

Agree whether the engagement is an initial gap assessment, an internal audit or a focused readiness review. These can overlap in methods, but their scope and purpose should be explicit. A short review of one area cannot establish readiness across the whole standard.

If the work is intended to contribute to your internal audit programme, define that explicitly. AFVA’s internal audit support can be discussed as a separate or clearly specified part of the engagement.

Agree the scope and current assessment criteria first

Prepare a short site brief covering products, main process steps, packing, storage, shifts and relevant outsourced activities. Identify the site or sites to be reviewed and explain planned changes. Include the customer request that prompted the work, rather than relying on a general reference to BRC.

BRCGS publishes different standards for different activities. This article concerns its Food Safety standard. A packaging manufacturer, storage business or agent may need a different assessment route. Confirm which standard, issue and scope apply before commissioning a detailed review.

Use the current checklist and position statements

At the research date, BRCGS’s self-assessment checklist page lists the Food Safety Issue 9 tool. Use the applicable version and review relevant current BRCGS position statements as well. BRCGS describes position statements as binding extensions of its standards; an older checklist alone may not reflect the full criteria.

Record the documents and versions used for the gap assessment. Confirm audit-specific criteria and arrangements with the certification body, especially if the audit is being planned for a later date. A blog article should not replace that confirmation.

Make exclusions visible

Ask what the proposal covers: document review, site observation, staff discussions, selected production activities and follow-up. Identify anything that cannot be observed, such as a seasonal process or a shift outside the visit. The report should make those limits clear so management does not mistake limited sampling for a complete assessment.

Prepare evidence that makes the BRCGS gap analysis useful

Start with a document index and a few representative examples. Mark versions, dates, owners and known limitations. Ask the reviewer which files are needed and agree a suitable way to share confidential information before sending a large collection.

The following evidence groups are practical preparation suggestions. Select them according to your operation and review scope; they are not an exhaustive or universally applicable list of BRCGS requirements.

Explain the operation and food safety plan

• A process flow and product or activity summary that describe current work.
• The food safety plan, hazard analysis and relevant supporting controls.
• An index of procedures, specifications and work instructions actually in use.
• The existing certification scope, previous findings and relevant customer requirements, where available.

Identify areas still being developed. If the process flow no longer reflects production, mark it for review instead of presenting it as current. Where the brief includes this work, AFVA’s HACCP and food safety plan support can be discussed alongside the gap assessment.

Show how the system operates

Depending on the agreed review, useful examples could include production checks, cleaning verification, supplier approval, staff competence, maintenance, traceability exercises and complaint follow-up. Include the instructions that explain the record and the person who understands it. A completed form is less useful if no one can explain what a deviation would trigger.

Choose genuine records from routine operations, including examples that needed correction. Explain missing or incomplete evidence openly. Do not backdate records or create an appearance of checks that did not occur.

Bring previous findings and open actions

Include relevant internal and external findings, actions already attempted and recurring issues. Distinguish the immediate correction from the cause investigation and the longer-term change. Note where effectiveness has not yet been checked. This helps avoid repeating an action that looks complete on paper but has not solved the problem.

Look at implementation as well as documentation

A gap assessment should not be treated as a folder inspection. Agree how the reviewer will compare instructions with actual activities and speak with the people doing the work. For example, a selected check can be followed from the instruction, through observation and the record, to the response when a result is outside the site’s own limits.

Use examples relevant to the review rather than staging ideal conditions. A discussion with the person responsible for a task can expose an unclear handover, missing authority or instruction that is difficult to use. Record the specific evidence and its limits so conclusions remain proportionate.

If the review is remote, agree what can be established through documents and discussion and what needs direct observation. Do not describe a limited remote document review as a full site readiness assessment. Make arrangements for any remaining assessment before relying on its conclusions.

Turn gaps into an action plan your team can use

Ask for findings that connect the applicable criterion to observed evidence. A statement such as “improve records” does not tell a manager which record, what is missing or how completion will be demonstrated. Each finding should be clear enough for someone who did not attend the review to understand.

For each agreed action, record the issue, responsible person, proposed completion date, supporting evidence and who will check effectiveness. Set dates around the work actually needed and any confirmed audit arrangements. Avoid copying a generic timeline into a project that needs process changes, training or new operating evidence.

• Clarify the gap: State the relevant requirement or agreed criterion and what the evidence showed.
• Address the immediate issue: Follow the site’s relevant procedures where current operations need control.
• Investigate the cause: Understand why the gap arose before choosing the longer-term response.
• Implement the change: Assign resources, approvals and a named owner.
• Check the result: Review evidence that the change is working, and reopen the action if needed.

Do not wait for an audit date to deal with a current food safety concern. Use the site’s appropriate response procedures and obtain specific advice where needed. A planned consulting review is not a substitute for timely control of an actual issue.

Keep consulting actions separate from formal certification-body findings. If a certification audit has already identified non-conformities, follow the certification body’s applicable process and confirmed deadlines. A consultant can assist with the response; the certification body determines acceptance through its own process.

Before you request a BRCGS gap assessment

A concise enquiry helps establish suitable support. You do not need a polished manual before asking for guidance. Prepare the following information and mark anything uncertain for discussion:

• Business and location: Site address, contact person and relevant food activities.
• Reason for the review: A first audit, customer request, changed operation or unresolved findings.
• Proposed criteria: BRCGS standard and issue, current certification scope if any, and questions still open.
• Timing: Confirmed audit date or window where known, plus operational constraints.
• Starting evidence: Process summary, document index, representative records and known gaps.
• Requested output: Gap report, action plan, implementation support or a focused readiness review.

Before accepting a proposal, agree the review boundaries, deliverables, responsibilities, fee basis, any travel or follow-up costs and how extra work will be approved. Ask how confidential information will be handled. A clear brief makes different proposals easier to compare without assuming every “BRC consultant” offers the same scope.

Common BRC audit preparation mistakes

• Starting with the wrong scope: Confirm the relevant standard and actual activities before reviewing clauses.
• Using an old checklist without checking updates: Record the current criteria and relevant position statements.
• Treating templates as evidence: Review implementation, genuine records and staff understanding.
• Requesting a pass prediction: Ask for supported findings and remaining work instead of an assured grade.
• Closing an action after editing a document: Check whether people use the change and whether it resolves the gap.
• Leaving all ownership with the consultant: Assign site decisions, resources and ongoing maintenance.

BRCGS consulting support from AFVA

AFVA provides BRCGS Food Safety gap assessment, documentation review, internal audit planning and support, corrective action planning, staff awareness and pre-audit readiness support for New Zealand food businesses. The engagement can focus on the area where your team needs help, with scope and deliverables agreed first.

For wider preparation needs, discuss AFVA’s food safety audit preparation service. AFVA provides consulting and readiness support; it does not issue BRCGS certification. Certification assessment and decisions sit with a BRCGS-approved certification body. Availability, competence, scope and any relevant independence considerations need to be addressed for the particular engagement.

BRCGS also operates an approved consultant scheme. Its official consultant directory and role description help readers understand that specific status. Check any claim of BRCGS approval against the scheme’s current records.

Frequently asked questions about BRCGS gap assessments

Discuss the gaps you need to understand

Start with the site, products, reason for seeking help and any known audit timing. Tell us whether you need an initial gap assessment, help implementing actions or a focused review of remaining evidence.

General information only: This article is a preparation aid, not the BRCGS standard, a complete compliance checklist or a certification decision. Applicable requirements depend on the standard, issue, scope, products and activities. Confirm current scheme and audit requirements with the relevant official documents and certification body, and maintain the New Zealand regulatory obligations applying to your business.