Mandla started Inkonjane Cold Chain in Riverhorse Valley, Durban, with one frozen chamber and two second-hand reefers. Fourteen years later it holds chilled and frozen food for six brand owners, runs its own reefer fleet, hires extra hauliers every December and rents space in another cold store when the peak outgrows its chambers. When a ready-meal brand made BRCGS Storage and Distribution certification a condition of a new contract, Mandla handed the project to Lwazi, the QA manager, and asked Retha, the finance director, to budget for the audit. Lwazi’s gap review surprised them both. The quality policy carried the signature of a general manager who had left two years before. The only objective anyone tracked was on-time delivery. No driver could say how to raise a concern without giving his name. The December hauliers and the rented cold store were on no approval list. None of those gaps could be closed from the QA office. Under the Standard they sit with senior management.
In short
- Section 1 of BRCGS Storage and Distribution Issue 4 places product safety with the people who can commit money and staff, and the auditor judges their commitment from evidence.
- Directors sign and communicate the quality policy, set measurable objectives reported upwards at least every quarter, and fund what the system needs.
- A product safety and quality culture plan with measures, dates and a review of what worked is required, and so is a confidential route for staff to raise concerns.
- Management review takes place at least once a year, operational meetings at least once a month, and every key role has a documented deputy.
- Customer requirements are agreed before the service starts, and new work is accepted only if the site can deliver it safely.
- Subcontracted hauliers and stores, peak-season ones included, need a written agreement, approval, a place on the register and a performance review.
Why BRCGS Storage and Distribution management responsibilities start in the boardroom
The Standard is built on three ideas, and leadership comes first. In a logistics business, product safety depends on the dock, the yard, the workshop, the transport office and finance, so it cannot be parked with one quality person. That is why section 1 speaks to senior management. In the Standard’s terms, senior management means the people who set strategy or run operations at a high level and can sign off spending and staffing. In an owner-managed third-party logistics provider (3PL) that is the owner and directors; in a group it includes the site general manager.
The statement of intent that opens section 1 expects leaders to prove they are fully committed: by funding the system, communicating, checking how well it works and following up on ways to make it better. An auditor cannot interview commitment. What can be inspected is a signature and a date, a budget line that was spent, minutes with owners and deadlines, and the answers a night-shift picker gives when asked who to call. Our guide to BRCGS Storage and Distribution certification explains scope, modules and how the audit runs. This one is about the decisions only directors can take. When those decisions are tested at audit, our guide to the BRCGS Storage and Distribution audit grade explains what each grade means for the business, from the 28-day clock to the unannounced year.
| Accountability | Clauses | Evidence a director should be able to put on the table |
|---|---|---|
| Quality policy | 1.1.1 | A current, signed and dated policy that people on every shift can explain |
| Culture plan | 1.1.2 | Activities with measures and dates, and a written judgement of whether they worked |
| Resources | 1.1.3 | Money that was actually spent, and review actions funded through to closure |
| Objectives | 1.1.4 | Numeric targets at every location, reported upwards each quarter |
| Speaking up | 1.1.5, 1.1.6 | A named person for problems, a known confidential route, and a record of each concern |
| Review and meetings | 1.2 | Review minutes, an action log, and monthly operational meeting minutes |
| Structure and cover | 1.3 | A current organisation chart, job descriptions and written cover for key staff |
| Customers and subcontractors | 3.4, 3.5 | Requirements agreed before work starts; hauliers and stores contracted, approved and reviewed |
Policy and objectives: the targets you sign
Clause 1.1.1 asks for a quality policy: a short statement of how the business intends to keep the goods it stores and moves safe and legal, and what it commits to its customers. A senior manager with the right authority approves it and puts a signature and date on it, it is reviewed from time to time, and it is explained so thoroughly that staff understand their part in it. The real test is not the frame in reception but whether a reach-truck driver can say in a sentence what the company promises and what that means for his own job. At Inkonjane the fix was small but visible: Mandla rewrote the policy with Lwazi, signed it himself, and talked it through at every shift change for a week, including the 04:00 driver briefing.
Objectives turn that promise into numbers (clause 1.1.4). They protect product safety, legality and quality, carry a target or clear yardstick, reach the staff concerned at every operating location, and are tracked, with the results put in front of company and site leadership every quarter at the latest. On-time delivery is a good service measure, but it says nothing about whether the yoghurt arrived cold. Inkonjane replaced it with four objectives of its own:
- Alarm response: every cold store alarm acknowledged by a person within 15 minutes, day or night.
- Vehicle temperatures: fewer than one out-of-range load per 500 chilled deliveries, each closed with a recorded root cause.
- Shelf life on dispatch: no pallet sent out with less remaining life than the receiving customer’s stated minimum.
- Held stock: no pallet on hold or in quarantine dispatched by mistake.
Each objective has an owner, and every quarter the figures go to the directors and are pinned up where the drivers take their breaks. The management review must also ask why any objective was missed and carry that lesson into the next set (clause 1.2.2).
The culture plan and a confidential way to speak up
Clause 1.1.2 asks the site’s leaders for a documented plan to develop and strengthen the product safety and quality culture. Culture here means the shared attitudes on site: how seriously people take product safety, and whether they have faith in the controls meant to protect it. Expect the auditor to look for activities in four areas: messages to staff, training, listening to staff, and measuring performance on safety tasks. Every department that can affect product safety takes part, not only the warehouse. For each activity the plan states the action, the yardstick for success and the deadline; afterwards, leaders decide whether it made a difference and record their verdict.
The trap is activity without evidence: events that nobody measured and nobody reviewed. Inkonjane’s first plan fitted on one page:
| Activity | Area | Measure of success | Due | Review |
|---|---|---|---|---|
| A two-minute voice note to drivers every Monday, in isiZulu and English, on one product safety topic | Communication | Drivers asked at random can name last week’s topic | From February | Spot checks reported monthly |
| Dock supervisors taught to lead a root cause analysis on their own incidents | Training | Each supervisor leads two analyses signed off by QA | End of June | Discussed at the mid-year review |
| A quarterly “stop and fix” walk: one director and two pickers walk the chambers and agree fixes | Listening to staff | Every agreed fix completed within 30 days | Each quarter | Fixes tracked in the review action log |
| Near-miss reports counted and answered | Measurement | Reports rise in the first six months, and every report gets a reply within a week | Monthly | Trend reviewed by the directors each quarter |
A rising count of near-miss reports is a deliberate early target: it shows people trust the system enough to use it. Our Food Safety and Quality Culture course for management and supervisors goes further into designing and measuring culture activities.
Speaking up has two layers. Clause 1.1.5 expects everyone to know which manager to tell when something threatens product safety, legality, quality or integrity. Clause 1.1.6, a firm requirement in this Standard, adds a confidential route for raising concerns, staff told plainly how to use it, and a senior management process for assessing every concern and recording the assessment and the action taken. A route designed for office staff misses drivers, night pickers and agency workers. Inkonjane put the number on vehicle key tags and in the agency induction pack, and made Retha, not the QA manager, the person who receives reports, so a concern about QA itself has somewhere to go. A log with nothing in it is not a finding; a route that nobody on the night shift has heard of is.
Resources: the decisions behind the budget
Clause 1.1.3 is short. Leaders must fund the staff and spending the Standard demands, including whatever improvements the management review signs off. Auditors rarely cite it alone; they meet it as a finding that keeps returning because nobody approved the money or people to fix it. Repeat findings also cost twice: clause 1.1.11 makes leaders answerable for curing the root causes of the last audit’s findings, so a cure that failed is a fresh finding.
| Spending decision | What it protects | Clauses |
|---|---|---|
| Repairs to dock doors, cladding and chamber panels | Pest proofing and a building that cannot damage stock | 4.4; 6.6 |
| Racking inspections and replacement of damaged uprights | Safe storage and fewer crushed pallets | 6.1.2 |
| Calibration of probes and loggers against a traceable reference | Temperature readings you can rely on | 6.3 |
| Store mapping, alarms and a call-out system that reaches a person | Proof that chambers hold product within its specification | 7.3.2; 7.3.3; 7.3.7 |
| Vehicle temperature recording, driver alerts and seasonal validation | Control of the load in transit | 5.4 |
| Induction and task training for agency staff before their first shift | Competent people from day one | 8.1.1 |
Retha now builds Inkonjane’s budget from the review action log rather than last year’s spend, each line naming the objective or finding it answers. Module 3 of our BRCGS Storage and Distribution Issue 4 for Management course treats the building, equipment and contractors as investment decisions in the same way.
Management review and the monthly operational meeting
Management review (section 1.2) is the meeting at which leaders judge the whole system and decide what to change and what to pay for. It is planned in advance and held at least yearly, and in this Standard “yearly” means a gap of 12 months at most, not once in each calendar year. A review that slips from October to January of the following year has missed it, however good the meeting was. The review measures the site against every part of the Standard and against its own clause 1.1.4 objectives.
Clause 1.2.2 sets a minimum list of inputs. Grouped the way a board pack would group them, they look like this:
- Looking back: actions and deadlines from the last review, and the reasons any objectives were missed.
- Audits: internal audits (prerequisite programmes included), customer audits and certification audits.
- Customers: KPIs and feedback, complaints, rejections and returns.
- What went wrong: incidents, wastage and non-conforming materials, and the corrective and preventive actions they led to.
- Plans: how well the HARA, culture plan, fraud vulnerability plan, product defence plan and security assessments are working.
- What is coming: resource needs, and the effect of changes in the law or in the certification scheme.
Outputs matter as much as inputs (clause 1.2.3). The meeting is recorded and updates the objectives; actions go to named people with deadlines; and the record shows when each one closed. A favourite audit trail starts in last year’s minutes: pick one decision, then ask for the invoice, the revised procedure or the training record that proves it happened.
Between reviews, clause 1.2.4 calls for a provable routine of monthly (or more frequent) operational meetings that carry product safety concerns up to senior management. Inkonjane did not add a meeting; it gave its monthly operations meeting a fixed product safety slot, chaired by Mandla, with an owner minuted for every issue.
Leaders also need a dependable way to hear about new legislation, emerging product safety concerns and changes to industry codes, and to pass that news to other depots (clause 1.3.4). Keep a current, genuine copy of the Standard, bought rather than borrowed, and track the changes BRCGS issues (clause 1.1.7), including the binding position statements in its SD404 document. Name the person who checks brcgs.com.
Structure, deputies and who sits in the audit meetings
Section 1.3 asks for a current organisation chart that shows any hub, satellite or head office responsibilities (clause 1.3.1), employees who know what they are responsible for, with management able to check that they do it (clause 1.3.2), and job descriptions and clear accountability for key staff, with documented cover for when they are away (clause 1.3.3).
Cover is where owner-managed businesses are most exposed. At Inkonjane only Lwazi could open the HARA files or run a trace. The fix was a deputy matrix naming a trained second person for each key role, checked against the leave roster every month. It costs nothing but planning, and it matters on audit day. Clause 1.1.8 puts the top operational manager at the site in the first and last meetings of the certification audit, with heads of department or their stand-ins on call in between; when that manager really is absent, the named deputy sits in and the audit carries on (Part III 2.8.5). With an unannounced audit due at least once every three years, the matrix will be tested on a day nobody chose.
Senior management must also back the hazard and risk analysis (HARA) plan and its procedures (clause 2.6); if a consultant leads the HARA work, the company still runs the system and names an internal deputy team leader (clause 2.3). If local law requires the business, its premises or its vehicles to hold a registration or approval, have the documents ready for the auditor (clause 1.1.9).
Customer contracts: only promise what the site can deliver
Each customer’s storage and distribution requirements, including special handling such as temperature, humidity, stack height and compatibility with other goods, are agreed and documented before the service begins (clause 3.4.1); if the customer has no specification, you may issue your own. Then comes the hard part: the business has to be capable of delivering all of it without risk to product safety, legality or quality (clause 3.4.2). Changes to agreements are agreed, documented and passed to the staff who need them, with a review of the customer’s needs where the customer asks for one (clause 3.4.3), and there are KPIs for customer requirements, measured and shared with staff (clause 3.4.4).
Clause 3.4.2 is the one that belongs in the sales meeting. Winning a new frozen dessert account for December is also a decision about chamber capacity, alarm cover, vehicle validation and overflow space. Inkonjane’s ready-meal customer specified a chilled range that, according to the last mapping study, two of the older chambers could not hold on hot afternoons. Mandla accepted the contract for the two newer chambers only and wrote that limit into the service specification.
One more check belongs to whoever signs customer contracts. Clause 3.5.3 asks a logistics business for a fraud vulnerability assessment plan that looks at its customers: can it trust that the businesses it stores for are real and lawful, and that their stock is what it claims to be? Trading history, how fraud-prone the product is and an approval step for new customers are typical considerations; high risks need mitigation, and a formal review happens yearly.
Hauliers and subcontracted stores: the work moves, the responsibility stays
The Standard separates vehicles and drivers you directly manage, even when a third party supplies them, from subcontracting, where another company both provides and runs the service. Section 3.5.2 expects every subcontractor that does in-scope work to be bound to the parts of the Standard and the law that apply to that work. Stores and hauliers brought in for the peak can be covered by your arrangements, as long as they satisfy those subcontractor rules.
Every subcontractor needs a contract or written agreement that sets, according to risk and your customer contracts, the requirements for safe handling, storage and transport, such as the temperature band, special handling, security, keeping incompatible goods apart and the type of vehicle (clause 3.5.2.1). Approval is documented and risk-based, using one or more of three routes (clause 3.5.2.2):
| Approval route | What it involves | When it fits |
|---|---|---|
| Certification | A current BRCGS certificate, or one to another GFSI-benchmarked scheme, whose scope includes the products or steps you hand over | Hauliers and stores you rely on all year; check the certificate and its scope before the first load |
| Audit | An audit of product safety, traceability, HARA review and good handling practice by a demonstrably competent auditor; if someone else did it, you check the auditor’s competence and the scope, and review the full report | Uncertificated providers carrying or storing chilled, frozen or sensitive goods |
| Questionnaire | Questions on the same four topics, refreshed at least every 3 years and judged by a competent person | Only providers you have rated low risk, with that rating justified on paper |
Approval is not a once-off: performance criteria are set and tracked, and the process is reviewed each year (clause 3.5.2.3). Every approved subcontractor goes on a register, including those used only for peak season or breakdown cover, and the people who book them can see it (clause 3.5.2.4). A documented procedure covers exceptions, for example when a customer insists on its own haulier or approval information cannot be obtained, and customers are told about exceptions that involve their branded product (clause 3.5.2.5). When transport is subcontracted, every haulier agreement carries the section 5 vehicle requirements, and the site then picks one of two routes: its own documented checks that each haulier really performs the safety-critical tasks, or hauliers that already hold this certificate or a GFSI-recognised equivalent (clause 3.5.2.6). And where a haulier’s controls are part of your own HARA, someone competent reviews them unless the haulier’s accredited certification already covers them, with any significant change to be flagged before it happens (clause 2.15).
The director’s decision is who may break the rule at 21:00 in December. Inkonjane’s planners now book only from the register; an unlisted haulier needs a director’s recorded approval and is either approved properly within a week or not used again. Lwazi audited the rented cold store before the peak, its contract now sets temperature, security and segregation terms, and the annual traceability test, which must include subcontracted storage and haulage where used (clause 3.6.4), will follow a pallet through it. Our article on the floor checks auditors make first shows what an auditor then looks for on vehicles, and the Internal and Supplier Auditing Practices course covers approval audits of providers like these.
Service providers who never touch a pallet, such as pest control, cleaning, maintenance and racking inspection, follow the same logic: risk-based approval, a contract or specification covering their product safety risks, a contract review at least every 3 years, and performance monitoring (clause 3.5.1). The cheapest quote is fine only if the contract still covers what your risk assessment needs.
Five things to do this week
- Find out who signed your quality policy, and when. If that person has left or the date is old, review it and sign it again, then explain it at the next shift briefings.
- Put your culture plan on one page under the four areas, and give each activity an owner, a measure and a date.
- Ask three drivers and two night-shift pickers how they would raise a product safety concern without giving their name.
- Diary the next management review within 12 months of the last one, and give the monthly operations meeting a standing product safety slot.
- List every haulier and store used in the last 12 months, including December and breakdown cover, and compare the list with your approved register and contracts.
Related course: BRCGS Storage and Distribution Issue 4 for Management
A four-hour, self-paced course for owners, directors and senior managers of 3PLs, cold stores, hauliers and distributors. Five modules, each with a case study, a knowledge check and a scenario game, cover leadership’s own obligations, the culture plan and management review, the site, people and subcontractors, operations, temperature control and recall, and how the audit is graded, with a final assessment and an ASC course certificate on passing.
See the BRCGS Storage and Distribution Issue 4 for Management course (4 hours, online, R1,195). Training a team? Choose “EFT or company invoice” at checkout, or WhatsApp us for a quote.
Common questions
What are the senior management responsibilities in BRCGS Storage and Distribution?
Section 1 of Issue 4 expects senior management to sign and communicate a quality policy, run a measured culture plan, provide resources, set objectives reported at least quarterly, offer a confidential reporting route, hold an annual management review and monthly operational meetings, and keep documented deputies.
Is confidential reporting required under BRCGS Storage and Distribution Issue 4?
Yes. Clause 1.1.6 requires a route through which staff can report product safety, legality, quality or integrity concerns in confidence, plain instructions on using it, and a senior management process that looks into each concern and records what was decided and done.
How often must a BRCGS Storage and Distribution site hold a management review?
On a planned schedule, with no more than 12 months between reviews. Objectives are reported to senior management at least quarterly, and operational meetings that raise product safety issues with senior management are held at least monthly.
Do subcontracted hauliers and cold stores need to be approved?
Yes. Any haulier or store that could put product safety, legality, quality or integrity at risk needs a written agreement and a risk-based approval: a relevant certificate, an audit by a competent auditor, or, for low-risk providers only, a questionnaire. Approved subcontractors, peak-season ones included, go on a register and are reviewed.
Who attends the opening and closing meetings of a Storage and Distribution audit?
The top operational manager at the site sits in on both, and heads of department or their stand-ins stay on call during the day (clause 1.1.8). If that manager is genuinely away, a nominated deputy takes the seat and the audit goes ahead.
Next step. If your directors and managers need a common view of what the Standard asks of them before the audit, the BRCGS Storage and Distribution Issue 4 for Management course works through it as a series of management decisions, with South African logistics case studies. Supervisors and floor teams can start with the Introduction to BRCGS Storage and Distribution Issue 4 course, and for the wider BRCGS family see our BRCGS certification and training hub for South Africa.
This article is general guidance for South African warehousing, cold storage, transport and distribution businesses. It is not a substitute for the Standard: a site is audited against the BRCGS Global Standard for Storage and Distribution (Issue 4) together with any position statements in force. Check brcgs.com for the current issue and position statements, and check which registrations, approvals and licences the law requires for your premises and vehicles. Clause numbers are given so you can navigate your own copy. ASC Food Safety Training is independent of BRCGS: this article and our courses explain the Standard in our own words, are not endorsed by BRCGS, and lead to an ASC course certificate, not a BRCGS qualification.