When BRCGS published their price increases in June, they indirectly announced that the Additional Voluntary Module 12 for Gluten Free was to be dropped from 1st August 2020.

This got us thinking about why this module was being dropped and this train of thought, took us down a rabbit hole… We’ll explain why.

So, why has this module been dropped?

Our first thought was that it may be due to insufficient uptake of the module. There are as of June 2020, 258 sites worldwide who have this module. Not a great amount, but some.

Then we realised that, as well as there currently being a voluntary module for gluten free, there’s also a certification programme for gluten free. We’re not sure when this was published by BRCGS, but this is the first time we’ve really noticed it – which we thought was odd.

So where has this come from?

Having looked into this, the BRCGS website says that the Gluten Free Certification Programme is on it’s third issue and was published originally in 2009. So, that’s even more strange – that it’s been around for over 10 years and we’ve not even noticed it.

However, after quite a lot of digging – we think we’ve worked it out.

Back in 2018 BRC bought a company called the Allergen Control Group Inc, who were based in Toronto, Canada. Allergen Control Group were the owner of the Gluten Free Certification Programme.

Clearly, BRCGS have taken this Standard, put it into their branding and put it on the website. So, although we’re still not sure when it was first put there, we suspect it’s not been long.

What’s the difference between them?

The voluntary module has to be bolted on to the Food Safety Standard, it cannot be done in isolation. The certification programme for gluten free, can be done on its own. It has its own Standard – just like the Food Safety Standard. But when you look at it – it’s a very much watered down version of food.

So, it makes sense that they shouldn’t have two products – a voluntary module and a certification programme that do the same thing.  Plus, there was probably a conflict of interest too, as the module was written collaboratively with AOECS, who are a European ‘version’ of the Allergen Control Group.

New certification programmes

Historically, we’ve always had 5 main certification programmes:

  • Food Safety
  • Storage & Distribution
  • Packaging
  • Agents & Brokers
  • Consumer Products

But over the years BRCGs have published:

  • Gluten Free (????)
  • Retail (2016)
  • Ethical Trading (2019)
  • Plant Based (2020)

Let’s compare

Having looked at the Gluten Free Standard, we noticed that the way it’s laid out is very different to the main Standards like Food Safety.

Although the 5 main Standards are not laid out exactly the same (which some may say would be sensible) they all have strong themes. Typically we have about 7 sections, plus traded products.

Section 2 is always HACCP and Personnel always comes last. The names of the main sections and the subsections are either the same, or very similar; Complaint-handling or Complaint Handling for example. So, you can link them together quite easily.

However, the new Standards seems to have been written by groups of people with completely free rein to chop everything up however it suits them.

Here are the sections for Gluten Free:

  1. Senior leadership commitment (no idea why we’ve switched management to leadership!)
  2. Prerequisite programmes
  3. Gluten controls
  4. HACCP principles
  5. Records
  6. Documentation
  7. Validation
  8. GFSM maintenance and reassessment
  9. Internal audits

And if you think that’s crazy, take a look at the sections for Plant Based:

  1. Senior management commitment
  2. The food safety plan – HACCP
  3. PBMS maintenance and reassessment
  4. Documentation and records
  5. Internal audits
  6. Supplier and ingredients/inputs approval and performance monitoring
  7. Ingredient and input receipt acceptance
  8. Suppliers of services
  9. Specifications
  10. Traceability
  11. Complaint handling
  12. Product recall and withdrawal
  13. Product development
  14. Approval and control of labels
  15. Product authenticity, claims and chain of custody
  16. Marketing claims
  17. Cross-contamination control
  18. Control of recipes and formulations
  19. Segregation and disposal of obsolete and waste material
  20. Plant-based awareness training

So, if you’re working to the Food Safety Standard and also one of these Standards, then you’ve got to match up the sections and compare and contrast the clauses to see what’s missing or additional.

Why do they have to make it so complicated?


Behind the scenes at Techni-K

Over the past two years we’ve been busy keeping up with the changes in the Standards. In 2018 when Issue 8 was published we updated our documentation packs to the new Standard and developed a Conversion Course from scratch. Last year, in 2019, we created packs for every section of the new Issue 6 Packaging Standard and amended and updated the Conversion Course from Food to Packaging.

Now that the draft of Storage & Distribution Issue 4 has been published, our attention has turned towards getting ready for its publication in November. And during these conversations, we had a bit of a light bulb moment.

When Packaging came out, BRC had put culture into the Senior Management Commitment Section, but left out whistleblowing. So, we took our Senior Management Commitment pack for Food and chopped out whistleblowing so that it worked for Packaging. Seemed a bit crazy, as surely whistleblowing applies to any product or company, but hey ho.

In readiness for Storage & Distribution Issue 4, where both whistleblowing and culture have been added in, we were talking about taking the Food pack and adapting it for Storage & Distribution. And, here’s where we had a brain wave.

Why not create one pack for Senior Management Commitment that meets the requirements for all 4 Standards? Obvious right? Now we look back – it’s totally obvious.

So, we’ve taken all 4 BRCGS Standards and we’re working our way through combining them, to create one Combined Standard. And from this, we’re going to create packs that meet all the Standards, rather than reworking 4 sets of packs each time.

As you can imagine this isn’t an easy task, but the more we work on it the more it makes sense.

For example, in the Storage & Distribution section there is a section about vehicle management. Which doesn’t appear in the other Standards, even though it’s relevant. Some Food and Packaging sites do have their own vehicles and so why would this not be included?

In the Packaging Standard there is a section about artwork control. Which applies to Food and to Agents & Brokers too.

While working our way through this mind bending task, we decided to also try something revolutionary. We’ve taken all of the topics of the Standards and we’ve grouped them so they make sense.

The result of which means we now have 18 topics, as follows:

  1. Senior management commitment
  2. Document management
  3. Continuous improvement
  4. Contingency planning
  5. Hazard analysis
  6. Contamination control
  7. Product development
  8. Supplier management
  9. Inspection and testing
  10. Engineering
  11. Product defence
  12. Training
  13. Personnel
  14. Site standards
  15. High risk facilities
  16. Hygiene
  17. Process control
  18. Storage and distribution

By having this Combined Standard, it means that we can now logically file all of the requirements, for all of the Standards.

Typically, the Food Safety Standard drives the changes and the other 3 Standards follow over the next 3 years. So, by updating them once, it means that our packs and training will always be ahead of the game. So, if you want to work to best practice and not be chasing your tail every time the Standard changes, we’ve got you covered.

So, why mention this?

Well this approach, we believe means that no matter how many Standards BRCGS publish and no matter how they decide to structure them, we can always bring them back into alignment.

Our hope…

Is that one day, BRCGS do this themselves. Work out one structure and stick to it. And, where the Standards can be the same, do that.  It seems crazy to us, that the requirements for Senior Management Commitment for example, differ at all across all of the current 9 Standards. Document control, record keeping, recall, internal auditing (and we could go on and on) should all be the same no matter what product or service you’re providing.


We’d love to know what you think about this and our approach. We know that document structure and numbering can be a very contentious topic. So, please add your thoughts to the comments box at the bottom of the article.

Have your say…

15 thoughts on “How I fell down a BRCGS rabbit hole…

  1. Brilliant idea Kassy – with you all the way on this one. Well done.

    I doubt BRCGS will adopt it however as it’s too sensible ha ha! Seriously, it would trample on too many tore domain wise and set a cat amongst the pigeons in terms of who does what at BRCGS.

    Glad you are there to influence this.

  2. Hi Kassy,

    I agree totally. As a fairly new person to auditing I have always wondered why there are so many differences to the layouts of different standards, written by the same organisation.

    It seems from the outside that this is an institutionalised company with too many traditionalists, fighting against all logic to modern efficient ways of producing products.

    Then there is the ‘interpretation guides’ which just muddy an already murky water, offering ‘extra’ information in several areas that cannot be used in the audit process. Then there is the making money bit.

    Keep knocking the door, even the deaf might hear the vibrations eventually.

  3. Interesting finding through your research – not a coordinated approach by BRC! Similar to all the retailers having their own versions of food safety standards, and pulling them together into one document is a good way of seeing the varying requirements in one place, and easily.

  4. Standardising the topics across the various Standards should have been carried out years ago. What we see now, imo are just more ways to make money whilst moving ever further away from the core tenents of food quality, safety and legality

  5. Kassy
    I’ve been up to something similar myself. We are a tiny 1.5 man company in wholesale packaging and have had an ongoing battle with our CB and BRCGS aka BRC !!! for three years about whether we should be A&B or S&D and in the course of this I have done just such a comparison and came to the same conclusion. The existing frameworks are truly chaotic ! There should be a similar structure and phraseology between all standards to cover similar requirements.
    I come from a legal background and the lack of any definition clause in any standard is in my view a glaring, and fatal omission particularly as frequently many different phrases and words are used to cover the same topic. My criticism relayed to BRCGS was not well received but frankly someone there needs to realise just how poor the standards are as currently drafted. It makes me lose faith in what all of us out here are trying to achieve.

  6. Hi Kassy

    This alignment of all standards makes sense. This is particularly useful where a company deals with several retailers standards or certification standards and I have done this for Quality Management Systems for a number of companies and I would expect I am not alone in carrying out this type of indexing of standards to ensure compliance and gap analysis is facilitated and user friendly.

  7. This makes so much sense. Great idea. Saves so much duplication.
    There is so much information to present at an audit that it becomes a ‘tick box’ exercise.
    It’s about time that only certain clauses would be audited on an ‘unannounced’ basis so procedures could be checked for compliance in depth

  8. I like your idea. I like to keep things as simple as possible so that a company can take control of, and maintain an effective food safety management system with minimum external help other than say keeping up to date with food safety issues and internal audits. I’m of the opinion that when food safety standards are difficult to understand, implement and maintain, the end user looses sight of what the standard is trying to achieve and this reduces the effectiveness of the FSMS instead of enhancing it.

  9. Hi Kassy,
    This idea is the one all standards should have. I only work with food safety standards, and I do the same with BRC/IFS/FSSC, and even comparing them with EU regulations, for companies who don’t want any accreditation (yes, those still exist !).
    And I have 22 sections, cut differently from yours as, for example, all sections regarding people are together (hygiene rules, training, …).
    The only body, I think, trying to get all requirements similar through all standards, is ISO, with their HLS structure. You can now compare ISO 9000, 14000 and 22000 series easily, they are the same. You only need to catch the specific details from each one, by scrolling all standards one page at a time.

  10. Hi Kassy,
    Great article. One point that is rarely spotted is that the BRCGS voluntary modules are Non UKAS accredited. This is why they have a separate certificate issued and are non graded. I think I heard early Spring about the the new AOECS Gluten Free certification program, as I’m a GF auditor – and I now need new training and another exam. The new program can then be accredited, once up and running, and be held as a legal validated due diligence system.

    1. Hi Sarah
      That’s a great perspective – as an auditor. So, from your point of view – do you think this is a move that will add value?

      1. Hi, yes most definitely. To have the scheme accredited – it add complete legal DD, and hopefully adds, more weight to the cross grain symbol on products. Although no doubt this will add cost to a manufactures auditing program, S

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