Preparing for BRC and IFS Audits: A Foreign Material Control Plan
BRCGS and IFS certificates have effectively become an entry ticket for food businesses selling to European retailers. One of the most critical topics in these audits is the foreign material control plan. In this article we summarize what the auditor looks at, where sorting equipment fits into the plan, and the gaps most often seen in the field.
What Are BRCGS and IFS, and Who Requires Them?
BRCGS (formerly BRC) and IFS Food are two internationally recognized certification standards developed for food safety and quality management. Both are recognized by the Global Food Safety Initiative (GFSI); for that reason European retail chains and major food buyers generally require their suppliers to hold at least one of these two certificates. For a business exporting dried fruit, nuts or pulses, certification is often not a choice but a customer requirement.
One of the areas both standards scrutinize most heavily is foreign material control. That is because a significant share of customer complaints and recalls stem from physical contaminants such as glass, stone, metal and plastic.
What Does the Auditor Look at Under Foreign Material?
The core question the auditor asks is this: has the business systematically identified physical hazards, brought them under control, and can it prove it? Four main topics sit beneath that question:
- Risk analysis (HACCP): What foreign material hazards exist at each step from raw material receipt through to packaging? Have the critical control points (CCPs) been correctly identified?
- Glass and hard plastic policy: Is an inventory kept of breakable materials in the production area? Is there a written procedure for what to do in the event of breakage?
- Equipment verification: Are magnets, sieves, metal detectors and X-ray systems tested regularly? Are the test results recorded?
- Records and traceability: When a deviation is detected, can the affected batches be traced retrospectively?
Color Sorting and X-Ray: Where Do They Stand in the Plan?
Sorting and inspection equipment is the implementation arm of the foreign material plan. A color sorter, with its AI-assisted camera systems, sorts out on the line both visually defective kernels and foreign material that differs in color and shape—for example stone, shell, stalk and glass fragments. In a HACCP plan it is generally positioned as a prerequisite program or a control measure. When performance is assessed, the focus is not only on detection success but also on carryover (the proportion of good product lost to the reject stream); the auditor may ask how you monitor this balance.
An X-ray food inspection machine, on the other hand, works on a density basis: it can detect objects such as metal, glass, stone and high-density plastic—even when the product is already packaged—and remove them from the line. For this reason, in many businesses the X-ray inspection step is defined as a CCP in the HACCP plan. A step defined as a CCP must also have its critical limits, monitoring frequency and the corrective actions to be applied in the event of a deviation set out in writing.
The Records Side: What Will You Show the Auditor?
In an audit it is records, not verbal explanation, that count. Modern sorting and inspection machines make this considerably easier:
- Automatic reject counters: How many ejections the machine has made over a shift and the reject volume can be reported; sudden increases give early warning of a change in raw material quality.
- Image archive: Storing images of the foreign material detected is a powerful tool both in root cause analysis and in presenting evidence to the auditor.
- Test piece verifications: At the start of a shift and at set intervals, certified test spheres (metal, glass, ceramic) are passed through the line; that the machine catches and rejects them is recorded on a form.
In many businesses these records are still kept on paper forms. That is acceptable; what matters is that the records are complete, dated and signed, and that in digital systems authorization and backup are defined.
Common Gaps and Their Countermeasures
The recurring findings under the foreign material heading in audit reports are strikingly similar. The table below summarizes the four most common gaps and their practical countermeasures:
| Common Gap | Countermeasure |
|---|---|
| Missing or irregular verification records | Tie the verification frequency to a written plan; record start-of-shift tests on a form and note any skipped tests with the reason. |
| Test piece without calibration or certificate | Use traceable, certified test spheres; replace damaged pieces immediately and record the replacement. |
| Untrained operator | Create a training record and competency matrix for every operator at the machine; schedule regular refresher training. |
| Reject material mixing back into the product | Label reject containers and keep them in a controlled area; tie the disposal or separate-assessment process to a procedure and record it. |
The common thread among these gaps is this: the equipment may be working correctly, but if there is no record to prove it, then as far as the auditor is concerned there is no control. Because the current versions of the standards and regulatory requirements can change, always refer to the current standard text and your consultant during preparation.
The SAGE Makine Approach
At SAGE Makine, we commission the machine, train your operators, and hand its record-keeping system and image archive over to your team. The spare parts stock we hold at our facility in Manisa and our service team are aimed at keeping your verification tests running without interruption. For a quotation suited to your needs, you can reach us through our contact page.