What was the plant’s starting point?
A plant in good standing with the food safety authority, with a HACCP plan, but which had never been through a GFSI audit. This is a composite case: it brings together situations our teams meet in Moroccan fruit and vegetable plants, without describing any client.
The site freezes strawberries, raspberries and blueberries bought from growers in the Loukkos region, in north-western Morocco. The fruit is sorted, washed, frozen in a continuous process, then packed in bags for retail or in cartons for industrial customers. Production is concentrated in the harvest season; the rest of the year, the plant repacks from its cold stores. A UK importer that supplies a major retailer announces that it will require a BRCGS Food Safety certificate for the next season.
The starting point, as established at the gap analysis:
- sanitary approval from ONSSA and a HACCP plan built for inspections, not for a GFSI standard;
- growers known for years, but approved on a simple list;
- documentation in French, which shift leaders rarely read;
- a largely seasonal workforce, hired at the start of the season;
- no food safety culture plan, and no vulnerability assessment for food fraud;
- a small trading activity in frozen fruit bought abroad and resold without repacking.
Sanitary approval remains the regulatory prerequisite. It is issued by ONSSA under the procedure described on its page for food establishments. BRCGS comes on top of it, as the buyer’s commercial requirement.
Which certification decisions were taken before work started?
Six decisions, all written down and signed off by management before the first day of work. They set the scope, the audit programme and the calendar, and therefore the cost and the risk.
Decision | Options | Choice in this case | BRCGS rule that applies |
|---|---|---|---|
Standard | Food Safety or another BRCGS standard | Food Safety Issue 9, requested in writing from the importer | Food Safety is for food manufacturing organisations |
Product scope | All lines or only some | Sorting, washing, freezing, packing, cold stores | Each HACCP plan defines its products and processes |
Traded products | Full chapter 9 or exclusion | Exclusion, recorded on the report; products segregated and controlled | All or nothing for chapter 9; out-of-scope products stay under control |
Risk zones | Chapter 8 applicable or not | Documented assessment presented to the auditor at the opening meeting | Clause 4.3.1 and Appendix 2 of the standard |
Audit programme | Announced or unannounced | Announced, fully on site | Blended audit not permitted for an initial audit; first audit announced unless the site asks otherwise |
Date | Off season or in season | Peak season, all lines running | The audit assesses observed practices |
The risk zone question deserves a word. The standard does not let the site decide by instinct: clause 4.3.1 requires an assessment based on the definitions in Appendix 2, and clause 4.3.2 requires the zones to be shown on the site map. In this case, the HACCP team documented its reasoning, based on the process and on how consumers use the product, and presented it to the auditor at the opening meeting. That assessment is what decides whether chapter 8 applies.
What gaps did the gap analysis reveal?
The heaviest gaps concerned the fundamental requirements, and almost all of them came from the same place: a system designed for the season and for inspections, not for continuous evidence.
Fundamental requirement | Gap at the start | Action taken |
|---|---|---|
1.1 Senior management commitment | No culture plan, objectives never communicated | Culture plan led by the managing director, objectives tracked every quarter |
2 HACCP plan | Flow diagram never verified during the season; microbiological hazards linked to wash water and handling poorly analysed | Diagram verified on the line at peak season, hazard analysis redone |
3.5.1 Suppliers | Growers approved without a risk assessment per raw material | Risk assessment (residues, microbiology, foreign bodies) and risk-based approval |
3.9 Traceability | Intake lots not linked to frozen lots: test well beyond 4 hours | Lot coding from intake, test repeated until it met the target |
4.11 Housekeeping and hygiene | Cleaning of the freezing tunnel not verified | Cleaning and disinfection procedure with recorded verification |
5.3 Allergens | "We have no allergens", with no written assessment | Assessment of raw materials for cross-contact, list of materials handled |
6.2 Labelling | Bag checks at start-up only | Checks at start-up, during the run and at each change of packaging batch |
7.1 Training | Seasonal workers trained on the job, with no record | Training before starting work, visual aids, check of understanding |
For the growers, the certification question was settled grower by grower. The standard allows three approval routes: certification to a BRCGS or GFSI-benchmarked standard covering the materials purchased, a supplier audit, or a questionnaire for a supplier assessed as low risk, with a justification. A grower certified to GLOBALG.A.P. IFA v6 must therefore be checked for its edition (Smart or GFS, the latter being the one designed for GFSI recognition) and for the scope of its certificate. The others are audited or followed up by questionnaire, depending on risk.
Two points specific to frozen products also weighed in. First, the retention period for records must take account of the product’s shelf life (clause 3.3.2), with a minimum of the shelf life plus 12 months: for a frozen product, it is extended accordingly. Second, labelling and allergens are judged against the law of the country of sale: for bags sold in the United Kingdom, UK legislation applies, and the site must keep track of it (clause 1.1.8).
How was the audit planned and carried out?
As a first audit: announced, fully on site, at peak season. The contract with the certification body was signed early, to book a date when every line is running.
The plant sent its planning file to the certification body: expected season dates, shift schedules, organisation chart, site plan, process flow diagram, list of CCPs and of products in scope. On audit day, the operations director opened and closed the audit, as clause 1.1.11 requires, and the managing director presented the culture plan in person. The auditor chose a lot of bags shipped to the United Kingdom; the team traced the growers, the frozen lot, the packaging and the customer within the 4 hours set by clause 3.9.3.
A few non-conformities were confirmed at the closing meeting, none of them critical. Within 28 days, the site submitted the correction, root cause analysis and preventive action plan for each one. The method for this file is detailed in our article on preparing the BRCGS certification audit. The certification body then made its decision, and the certificate was issued within 42 calendar days of the first day of the audit.
What does seasonality change for later audits?
Almost the whole calendar. The next audit is due twelve months later, or six months for a site graded C or D, and the first unannounced audit will take place in one of the following two years. The BRCGS079 protocol sets specific rules for seasonal sites.
BRCGS079 rule for seasonal sites | What the plant put in place |
|---|---|
Expected season dates are communicated to the certification body and kept up to date | Dates sent as soon as they are known, updated whenever they slip |
If the season is shorter than the four-month window, non-audit days are reduced pro rata | Non-audit days kept for justified cases only |
If the audit due date falls early in the season, the window may be extended up to six weeks after it, by concession | Risk of a period without a certificate anticipated and flagged to the importer |
Intermittent production: the certification body is informed every week | Weekly off-season repacking schedule sent to the certification body |
A C or D grade would have created a concrete problem: an audit six months later could have fallen outside the season. That is one more reason for a seasonal site to aim for a good result at its first audit. The effect of the grade on the budget is detailed in our article on what drives the cost of BRCGS certification in Morocco.
What lessons for other fruit and vegetable exporters?
The main one: treat certification as a calendar as much as a system. The rest follows.
For the full framework, read our guide to BRCGS certification in Morocco. For the place of GLOBALG.A.P. upstream of the plant, see our GLOBALG.A.P., SQF and PrimusGFS page, and for other sectors, our food and beverage sector page.