There are a couple of non-conformances that keep cropping up for BRC Food Issue 8 and so, in this article we’re going to go through them and what you need to do to fix them.

The two non-conformances are:

  • Not detailing in your incident procedure that you’ll notify BRC if you have a regulatory non-conformance

  • Not including radiological hazards in your hazard analysis

Regulatory non-conformances

This one is pretty easy, just make sure that in your incident procedure that you detail that you’ll notify BRC (through your certification body) when you have a recall, and also that if you get a regulatory non-conformance.

When they say a ‘regulatory non-conformance’ they mean if you get an enforcement notice from your Environmental Health Officer or the local authority. So, just check your procedure and make sure you’ve got that covered.


This one is a little bit more tricky.  Radiological was included in the definition of hazards in the glossary of Issue 7, but it wasn’t written in the clause itself, so it wasn’t really noticed. When BRC updated the Standard to Issue 8, they included the list of hazards to align it with the FSMA Act in America.

The FSA, FSS and the Environmental Agency carry out monitoring for radioactive contamination in the UK, to check to make sure it’s not getting into the food supply-chain.  The last report was published in 2017 and this report and the previous reports can be found here:

The report shows that radiation in the areas around nuclear power plants are under the legal limit.

So, what should we do?

In the UK this is pretty straight forward, as the local authority carries out monitoring to ensure that the food supply-chain is protected. This includes radiation that may enter the water systems and also that may contaminate farming. The FDA do similar monitoring exercises in America, so it’s a case of looking for these types of reports in your Country.

If you have this as your evidence, you just need to include radiological hazards in your HACCP. Under your scope, include radiological.

Then at the intake steps of your hazard analysis, make sure you include radiological hazards for water and also for the ingredients you purchase.  For water, your control here would be that you use the reports produced by your local authority, to make sure that the local water supply is not contaminated. For the ingredients you purchase you need to consider where they come from and have the relevant reports for that area.

Irradiated food

Food can be preserved through irradiation, however there are legal requirements for this in the UK.  In the ingredient declaration the words ‘irradiated’ or ‘treated with ionising radiation’ needs to be stated after the ingredient.

So, your ingredient specifications should detail this information.  If you use ingredients that are irradiated, you need to make sure you know that the supply of these materials is controlling this effectively, so request this from your supplier.

Next steps…

If you’ve received a non-conformance for not including radiological hazards in your hazard analysis, it would be great if you could let us know, and let us know how you closed this out with your certification body – by commenting in the reply box below.

I’ll also like to try to build this article, to be a source of information for radiation monitoring, by putting links to the relevant reports below, from around the world. Here’s what we have so far, but if you know of any more, please can you let me know so I can share these too?

Radiation Resources

Have your say…

11 thoughts on “Radiological hazards, a common non-conformance in Issue 8

  1. Thanx for the post! I wonder about the first one and informing BRC in case of regulatory NC whatever this applies to everyone ( also operations outside Uk). We do inform BRC in case of recall but what’s the point of information in case on regulatory NC? This is anyhow handled by local authorities and I wonder what would be BRC actions once the got this info ? Or this is more like FYI?

    1. Hi,
      It does apply to everyone, but it would be based on the system in your local Country. Here in the UK, an enforcement notice is given for serious food safety issues, so it’s not a typical action. So, in theory BRC would look at it in the same way as a recall and may look to carry out a direct audit of the site.

  2. We have 2 lines and 2 hazard analysis, one had radiological as we have installed x-ray equipment the other did not. He noted that we add to the one without but no NC. Column is just all blank at the moment.

  3. Shall I include the radiological hazards as part of HACCP FORM 5,6,7,8 for all ingredients and water .Will that be enough ? We are based in Canada and the radioactivity is limited within the country. But we export to US and that why we have to comply with this cause. We are bakery with low risk profile. I also want to highlight that some ingredients like wheat and spices may be irradiated so we can control the radiological hazards by not exceeding the specified amount. I still need more information so that I can submit a corrective action report.

    1. Hi
      I’m not sure what HACCP FORM 5,6,7,8 is – but you just need to include radiological hazards at the intake step – that way you just have to do it once.
      I hope that helps?

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