Charmaine, QA manager at Kwaggaspan Distribution in Brits, North West, spent the week before the audit tidying the quality manual. The auditor leafed through it and asked to go to the dock. In the first ninety minutes she watched Kagiso, the dock supervisor, receive a trailer of yoghurt and asked him how he knew the seal was the one that had left the dairy. She read the chiller chart for the night of a four-hour power cut, pulled a short-dated pallet of maize meal from a pick face, and walked the dry store’s outside wall checking the roller doors. Kwaggaspan, a multi-temperature distribution centre with its own reefer fleet, had its paperwork in order; the auditor wanted to know whether the floor matched it. That is how a warehouse food safety audit works under the BRCGS Global Standard for Storage and Distribution: the documents describe the system, and the dock, the cold store, the yard and the vehicles show whether it runs.
In short
- Typically at least 30% of a BRCGS Storage and Distribution audit happens on the floor, on vehicles and in interviews with staff. If transit evidence is thin, the auditor rides with a vehicle.
- At goods-in, temperature, load condition, seals and remaining shelf life are checked before anyone signs (clauses 7.1.1 to 7.1.4).
- Temperature-controlled stores need alarmed recording, or written manual checks typically every 4 hours, plus mapping and time limits for product outside temperature control (clause 7.3).
- Power cuts belong in the business continuity plan (clause 3.8.4), and the release of any affected stock is decided with the product owner (clause 7.3.5).
- Vehicles are inspected before loading, set points are verified and loads are locked or sealed (clauses 5.1.4, 5.4.3, 5.2.5).
- Traceability and recall procedures are each tested at least annually. A trace runs both ways, reconciles quantities and should be complete within 4 hours (clauses 3.6.4, 3.7.4).
Where the auditor goes first, and why
An audit has set stages, but the auditor may take them in any order, and many start on the floor. The audit protocol expects typically at least 30% of audit time to be spent in and around the storage areas, on vehicles and in conversation with staff (Part III 2.2). Where distribution is in scope and evidence of what happens in transit is otherwise lacking, the auditor rides along with a vehicle. The traceability exercise is a vertical audit: one product is followed through every linked record, from the delivery note and goods-in check to the storage location, pick, load sheet and vehicle temperature record. If you are still working out what certification itself involves, our guide to BRCGS Storage and Distribution certification explains the scope, modules, audit options and grades.
Questions go to the person doing the job: a forklift driver may be asked about a broken pallet, a picker who to tell about droppings, a driver what the reefer alarm means. Our article on the questions auditors ask food handlers shows the style. The table shows a route we often see on a first walk.
| Stop | What the auditor often looks at first | Clauses |
|---|---|---|
| Dock and goods-in | A delivery being received: seals, temperatures, load condition, shelf life | 7.1.1 to 7.1.4 |
| Cold store and chiller | Temperature records, alarm history, mapping, staging time limits, probe calibration | 7.3; 6.3 |
| Pick faces and racking | Rotation, short-dated stock, damaged racking, product on the floor | 7.5; 6.1.2; 7.2.4 |
| Perimeter and dry store | Gaps under doors, the clear strip along walls, bait stations, stored-product insects | 4.1.3; 4.4.9; 6.6 |
| Yard and vehicles | Pre-load checks, set points, seals or locks, load restraint | 5.1.4, 5.1.5; 5.2.5; 5.4.3 |
| The records trail | The trace test, recall test and continuity plan | 3.6.4; 3.7.4; 3.8.4 |
The clause column is the Standard; the order and the examples are our experience of logistics audits. Module 2 of our Introduction to BRCGS Storage and Distribution Issue 4 course covers each stop with South African warehouse and transport examples.
Goods-in: the checks that happen before anyone signs
Goods-in is the cheapest place to stop a problem. Once a driver has a signature, a warm pallet or a broken seal becomes your stock and your problem, so the Standard wants product confirmed as within specification before it is accepted.
| Check | What good practice looks like | What the auditor asks to see |
|---|---|---|
| Seal and security (7.1.3) | The seal number is read against the delivery note before the doors open; a broken or mismatched seal stops the unload | Seal numbers on the receiving record, and what happened the last time one did not match |
| Temperature (7.1.1) | Product probed, or the reefer download read, against the owner’s specification before signing | Acceptance limits at the dock and readings on the receiving record |
| Load condition (7.1.2) | Pallets checked for pests, contamination, leaks, odour and crushed or wet cases | The inspection checklist and the rejection log |
| Shelf life (7.1.4) | Remaining life checked against each customer’s minimum and entered in the system | A recent short-dated receipt and the decision taken |
At Kwaggaspan the seal question exposed a gap. Kagiso checked that a seal was present but did not compare its number with the dairy’s paperwork, because the seal-number column had disappeared when the receiving form was reprinted. The correction took ten minutes. The root cause, a form changed with no record of why, sits under document control, which asks for the reason behind every change to an important form (clause 3.1.2.3).
Put the acceptance limits where the receiver can see them, taken from the product owner’s specification. The Standard sets no temperatures of its own. At Kwaggaspan the dairy customer’s contract accepts chilled yoghurt at 5 °C or below and the frozen-vegetable owner asks for −18 °C or colder, so those are the figures the dock works to, and a load outside them is held and the owner contacted rather than quietly accepted.
Temperature control: the records behind the readings
A thermometer on the wall is not temperature control. Where products depend on a controlled environment, the site has to keep it under control and monitor, record and verify it throughout handling and storage (clause 7.3). In practice an auditor tests six things.
- Recording and alarms. Temperature-controlled stores need alarmed recording equipment, or manual checks written down typically every 4 hours, or frequently enough to step in before product leaves its limits (clause 7.3.2). Test that the call-out reaches someone who answers at 02:00.
- Capacity. The store must be able to hold product within its specified range (clause 7.3.3), including in the hottest weeks of the year.
- Mapping. The site must know how evenly temperature is spread through each controlled room, prove it and repeat the check at a risk-based frequency (clause 7.3.7). Mapping often finds warm spots near doors or high in the racking.
- Time out of temperature. Written limits for how long each product type may sit outside temperature control at loading, unloading and staging, allowing for local heat, humidity and condensation (clause 7.3.4).
- After changes. When an evaporator is replaced, a door moved or the store re-racked, capability is re-established where appropriate (clause 7.3.8).
- Accurate instruments. Probes and loggers are on a register with unique IDs and next calibration dates, checked at a risk-based frequency and traceable to a recognised national standard (clauses 6.3.1 to 6.3.3). When one is found reading wrong, the site records what it did about product that relied on it (clause 6.3.5).
Power cuts and generators: a risk assessment, not a footnote
For a South African cold store, a long power cut is a foreseeable event, and the Standard expects it to be planned for. Clause 3.8.4 asks for contingency plans for major incidents, and loss of key services such as energy, water and staff is on its list alongside fire, flood, sabotage and cyber attack. Clause 3.8.5 sets out what the plan must hold: the incident team and its roles, a current contact list with after-hours numbers, fallback arrangements that keep customers served, and how customers and, where needed, regulators will be told. Kwaggaspan’s auditor tested the plan against its four-hour outage; these are the questions to ask yourself first.
| Power-cut risk | What we would expect to see | Clauses |
|---|---|---|
| The generator fails to start or runs dry | Planned maintenance, recorded test runs, and fuel deliveries for nights and weekends from an approved supplier | 6.2.1; 3.5.1; 3.8.4 |
| Loggers and alarms lose power | Loggers and alarm dialler on backed-up supply, so recording and call-outs continue | 7.3.2 |
| Docks keep working with doors open | Staging time limits enforced, and loading paused if limits would be broken | 7.3.4 |
| Reefer trailers parked on yard power | A plan for plugged-in trailers during an outage, with checks before dispatch | 5.4.4; 5.4.6 |
| The warehouse system goes down | Backed-up records, protected servers and a manual fallback for receiving and dispatch | 3.8.4; 3.1.3.2 |
| Product may have gone out of limits | Stock held, each owner told, release decided with the owner and recorded | 3.8.2; 3.8.3; 7.3.5 |
The Standard demands no particular backup design; it asks you to recognise the risk, choose controls and show they work. Run the power-loss part of the plan as an exercise: time how long the generator takes to carry the load, confirm the alarm call-out still goes through, and record what you learned. If an outage does affect product, the incident procedure takes over and affected stock stays on hold until the investigation is finished (clauses 3.8.1, 3.8.2). A significant product safety incident must be reported to the CB within 3 working days (clause 3.8.6).
Stock rotation, shelf life and release
Rotation problems show up quickly on a walk: a newer batch in the pick face with an older one behind it, or a pallet that has sat in a top location for months. Three things make rotation work: date information captured on receipt documents or labels (clause 7.5.1), a location system that shows where every batch is (clause 7.5.2), and a rule that nothing leaves with less shelf life than the customer has asked for (clause 7.5.3). Warehouse systems can apply first-expired-first-out (FEFO) or first-in-first-out (FIFO) rules. A common finding is a picker overriding FEFO to finish an order faster, and a short-dated pallet going out below the customer’s minimum. A weekly override report catches both.
Some stock must not move until someone says so. Where positive release applies, product stays on hold until every criterion is met and release is authorised, with records (clause 7.6.1); where the owner’s authorisation or a legal clearance such as customs is needed, the system confirms it before dispatch and keeps the proof (clause 7.6.2). Held, damaged and returned stock is clearly identified, blocked in the system or physically separated so it cannot ship by accident, and stored where it cannot deteriorate further or contaminate good stock (clauses 3.9.1, 3.9.2). Chilled returns that have been out of temperature and go straight back into saleable stock remain a classic finding.
Pest control the auditor can verify
Pest control is judged on evidence an auditor can see in minutes, and proofing comes first. External doors must close tightly or be proofed, dock doors that stay open for operations need other precautions and are shut when not in use, and canopies are protected from roosting birds (clause 4.4.9). A clean, unobstructed strip along the outside walls of storage buildings, with no stacked pallets or scrap, removes harbourage (clause 4.1.3). Inside, staff must know the signs of pests and report them (clause 6.6.1). Where stored-product insects are a risk, as with flour, maize meal, rice, nuts, dried fruit and pet food, the programme includes measures against them (clause 6.6.2), and when activity is found, at-risk product goes straight into the non-conforming product procedure (clause 6.6.3).
| Pest evidence | What the auditor checks | Clauses |
|---|---|---|
| Contract and competence | A contract matching the site’s activities, a competent contractor or trained staff, and inspection frequency set by risk assessment | 6.6.4, 6.6.5 |
| Device map and records | A current plan of bait stations and monitors, products used, activity seen and treatments carried out | 6.6.6 |
| Recommendations | Each recommendation recorded and acted on without delay | 6.6.9 |
| Trend analysis | Trap and monitor data reviewed at least annually, or after an infestation, to find problem areas | 6.6.8 |
| Expert survey | An in-depth survey of the whole building, yearly as a minimum, with advice on stock that moves slowly | 6.6.10 |
The site, not the contractor, owns the recommendation log (clause 6.6.9), so “gap under door 4” two months running is your finding, and your own inspections, at least every 3 months (clause 3.2.5), should have caught it first.
Segregation, spills and contamination
A multi-client warehouse holds things that should never meet: detergents and flour, strong-smelling goods and chocolate, leaking product and clean outer cases. The auditor looks for enough segregated space to keep incompatible products apart (clause 4.3.3), chemicals in suitable, controlled storage where they cannot affect product (clause 4.3.6), and battery-charging bays with adequate extraction, separated from storage (clause 4.3.5). Staff need to know which goods need special handling or segregation (clause 7.2.1), and stock is always kept off the floor on pallets or racking (clause 7.2.4). Kwaggaspan keeps one client’s detergents and another’s maize meal in separate aisles and never stacks chemicals above food.
Spills test the whole arrangement. Any spill or breakage with the potential to contaminate stock goes into an incident report (clause 7.4.2). In a sealed-goods warehouse the main allergen risk is a torn sack of nut flour or a leaking bag of milk powder dusting the outer packaging of other stock, so the allergen procedure considers fragile packs and powders (clause 7.7.1) and the clean-up method is validated and checked routinely (clause 7.7.3). Cleaning chemicals are bought from an approved list, labelled at all times, kept in a restricted store and used only by trained staff, and strongly scented products are avoided (clause 7.4.3). Glass and brittle items such as light covers and forklift mirrors are listed on a register and checked (clause 7.4.1). Snap-off blade knives are not allowed at all (clause 6.1.6).
Vehicles: pre-load checks, set points and seals
Vehicle paperwork is a common home for tick-and-flick records. Before loading, the load space is inspected and the result recorded (clause 5.1.4): it should be clean, with sound walls, floor and ceiling and no exposed insulation, intact door seals, no sign of pests, no odour that could taint the load and no excess humidity that could cause mould, and any drain holes, strip curtains and interior lights should be clean and intact. Straps, load-lock bars and other restraints must be sound and sufficient to keep the load stable (clause 5.1.5).
For chilled and frozen loads, the company has to show its vehicles hold product temperature in all weather, through the hottest and coldest months and at full and light loads (clause 5.4.1). Set points are verified by trained staff before loading and dispatch, trailers are pre-cooled or reach air temperature within a set time (clause 5.4.3), the load space is recorded for the whole journey (clause 5.4.2), the driver is alerted when temperature drifts (clause 5.4.5), and a procedure decides what happens to a load after a refrigeration failure before it reaches the customer (clause 5.4.6).
In November Tshepo, Kwaggaspan’s transport manager, booked an owner-driver’s reefer for a peak-season run, and at the bay Andile found the unit still set at 12 °C from a fruit load. The set-point check caught it, but the auditor asked more: was the haulier on the approved subcontractor register, which includes peak-season and breakdown hauliers (clause 3.5.2.4)? Was there a written contract setting temperature, security and vehicle type (clause 3.5.2.1)? And how does Kwaggaspan confirm that each haulier actually carries out the safety-critical work, say by looking over temperature downloads and pre-load sheets, or does it use hauliers certificated to this Standard or an equivalent GFSI-recognised one (clause 3.5.2.6)? Our Internal and Supplier Auditing Practices course covers approving and reviewing providers like these.
Security completes the picture. Enclosed load areas are locked once loaded, and where seals are used their integrity is checked before unloading (clause 5.2.5); curtain-siders need other measures, such as tamper-evident tape, that make any access obvious (clause 5.2.6). A documented transport threat assessment covers theft and tampering on the road, at multi-drop deliveries and when returns travel on the same vehicle, reviewed at least annually (clause 5.2.1), and hijacking and cargo theft belong on it. Our Food Fraud and Food Defence course covers threat assessment in more depth. When a trailer leaves dirty or a seal goes unchecked, “the driver forgot” is not a root cause; our article on why human error is not a root cause explains what to look for instead.
Traceability and recall tests that stand up
Products and pallets must be identifiable and traceable at all times, and the written procedure explains which records carry product identity, how one leads to the next and which to pull in a test (clause 3.6.1). Vehicle load records link products to the trailer that carried them (clause 3.6.2), and damaged packs, returns and stock sent for disposal stay traceable too (clause 3.6.3). The system is put to the test at least once a year, following a product from the party that sent it, through the warehouse and transport, to whoever received it, and back again, reconciling quantities (a quantity check, or mass balance), with any subcontracted storage or haulage included (clause 3.6.4). A complete trace should take no more than 4 hours, and auditors treat that as the expectation. “Annual” here means within 12 months of the last test.
| Trace step | Kwaggaspan record | Cases |
|---|---|---|
| Received from the dairy, batch 2611 | Goods-received note with seal number and probe reading | 1,200 |
| Put away | Warehouse system locations | 1,200 |
| Dispatched to 14 stores on 6 vehicles | Load sheets, trailer numbers, temperature downloads | 1,140 |
| Still in stock | Location report | 36 |
| Damaged and written off | Damages log and disposal record | 24 |
| Balance | 1,140 + 36 + 24, complete in 2 hours 40 minutes | 1,200 |
A recall test is a separate exercise. The procedure names the recall team, explains how to choose between withdrawal and recall, keeps after-hours contact numbers, plans communication, the recovery or destruction of stock and its reconciliation, records timings, and ends with root cause analysis (clause 3.7.1). It must work at any hour of any day (clause 3.7.3) and be tested at least annually, with records kept (clause 3.7.4). A withdrawal brings product back from customers before it reaches consumers; a recall brings it back from consumers. For most 3PLs the brand owner leads the consumer recall, and the warehouse locates, isolates, holds and returns or destroys stock on the owner’s instructions. When the warehouse itself finds a safety or quality problem with an owner’s product, it notifies the owner formally and keeps a record of the agreed action (clause 3.7.2). Ring the after-hours numbers, run the test outside office hours and time every step. A recall affecting the site must also be reported to the CB immediately.
Five things to do this week
- Walk the route in the first table with a supervisor and note what an auditor would see first at each stop.
- Pull last night’s cold store record and alarm history, and test that the alarm call-out reaches a person who answers.
- Diary a power-loss exercise covering generator fuel, power to loggers and alarms, and the fallback if the warehouse system goes down.
- Check five pre-load sheets from last week against the trailers they name, looking for blanks, ticks without readings and missing set points.
- Run a timed trace with a mass balance on a product received last month, then ring every after-hours number on the recall list.
Related course: Introduction to BRCGS Storage and Distribution Issue 4
Five hours, self-paced, in three modules and twelve lessons. Module 2 covers the controls in this article, from goods-in, temperature control and stock rotation to pest management, vehicles, traceability and recall, with South African warehouse and transport examples. Module tests and a 25-question final lead to an ASC course certificate.
See the Introduction to BRCGS Storage and Distribution Issue 4 course (5 hours, online, R1,195). Training a team? Choose “EFT or company invoice” at checkout, or WhatsApp us for a quote.
Common questions
What does an auditor check first in a warehouse food safety audit?
Many auditors start where product is handled: goods-in, the cold store, pick faces, the perimeter and the yard. Under the BRCGS Storage and Distribution Standard typically at least 30% of audit time goes on the floor, on vehicles and in staff interviews, and the traceability exercise follows one product through every linked record.
How often must cold store temperatures be checked?
Clause 7.3.2 of BRCGS Storage and Distribution Issue 4 asks for alarmed temperature recording, or manual checks written down typically every 4 hours, or frequently enough to step in before product leaves its limits. The limits themselves come from the product specification or the product owner, not from the Standard.
Do power cuts need to be covered in our food safety system?
Yes. Clause 3.8.4 requires contingency plans for major incidents, including the loss of key services such as energy. In practice that usually means a maintained generator with secure fuel supplies, monitoring and alarms that keep working without mains power, time limits for product outside temperature control, and release decisions made with the product owner.
How long should a warehouse traceability test take?
Clause 3.6.4 expects a full trace to be possible within 4 hours. The test runs at least annually, follows a product from the sender through storage and transport to the recipient and back, reconciles quantities with a mass balance, and includes any subcontracted storage or haulage.
Do subcontracted hauliers have to meet the vehicle requirements?
Yes. If you subcontract distribution, the section 5 vehicle requirements are built into each haulier arrangement. You either confirm that hauliers actually carry out the safety-critical work, for example by checking their temperature downloads and pre-load records, or use hauliers certificated to the Standard or an equivalent GFSI-recognised scheme.
Next step. If your supervisors need a shared picture of what the Standard expects on the floor, the Introduction to BRCGS Storage and Distribution Issue 4 course works through sections 1 to 9 with South African warehouse and transport examples and a test after each module. 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.