Where do you start when preparing a cold store for the audit?

With a flow map, not with procedures. Take a warehouse in the logistics zone of Tanger Med, Morocco’s port complex on the Strait of Gibraltar, that receives frozen seafood, frozen berries and dairy products, then consolidates reefer containers for Europe. It runs several cold chains under one roof, and the auditor will follow each of them.

Five actions open the project:

  1. Check the approval. The sanitary approval or authorisation from ONSSA (Office national de sécurité sanitaire des produits alimentaires, Morocco’s national food safety office) must cover the warehouse and the storage activity. Certification comes on top of this legal obligation.
  2. Map the flows. Intake, frozen rooms, chilled rooms, picking area, dispatch docks, container park, returns and damaged goods area, contract operations (freezing, tempering, defrosting).
  3. Assess yourself. BRCGS publishes a self-assessment checklist for Issue 4, SD401, in English only: plan a working translation for your French- or Arabic-speaking dock supervisors.
  4. Analyse the hazards. Clause 2.1 requires prerequisite programmes to be in place before the risk analysis, HARA or HACCP, and to be built into it.
  5. Appoint a project lead and a deputy. A warehouse that runs around the clock cannot depend on a single person on the day of an unannounced audit.

The flow map becomes the basis of the hazard analysis. The table gives the outline for a cold store.

Area

Main hazard

Expected control

Intake dock

Too long out of refrigeration, damaged pallet, pests

Intake check (temperature, condition, identification), written maximum waiting time

Frozen room

Temperature rise, doors left open, refrigeration unit failure

Continuous recording, alarm followed up, door instructions

Chilled room

Temperature deviation, incompatible products side by side

Storage plan, product segregation, recording

Open product area

Contamination by staff or equipment

Section 9 requirements: handwashing, headwear, risk assessment

Dispatch dock and containers

Dirty, badly set or non-compliant container or truck

Documented check before loading

Returns and damaged goods

Non-conforming product shipped by mistake

Identified area, hold, owner’s decision

Equipment and cleaning

Trucks or utensils carrying contamination

Movable equipment restricted to designated areas (6.1), cleaning equipment identified and stored off the floor (6.4.5)

How do you prove temperature control day and night?

By showing three things: written limits for each room and each customer, continuous recording, and a proven response to every alarm, at any hour. The first two are common; the third is often missing.

Written limits. The temperature range comes from the product owner’s specifications and is written into the contract (clause 3.5.2.1). The same warehouse may hold different limits for two customers in the same room: either the stricter limit applies to the whole room, or the products are separated.

Continuous recording. The cold chain is one of the prerequisite programmes of clause 2.1. For section 17 contract operations (chilling, freezing, tempering, defrosting of pre-packed products), clause 17.3, updated on 10 August 2026, requires process parameter recording linked to an automatic failure alarm, or manual checks frequent enough to intervene before limits are exceeded. The guidance in SD404 gives a benchmark: without automatic recording, checks continue at weekends and on public holidays, normally every two hours for chilled and every four hours for frozen products, unless otherwise justified. Records are kept for the product’s shelf life plus one year.

An alarm that is followed up. The auditor will ask what happened at the last night-time alarm: who was called, how quickly, what action was taken, what decision was made on the products.

Evidence

What convinces the auditor

Common mistake

Temperature curves

Continuous, read every day, deviations annotated

Curves archived without being read

Alert chain

Up-to-date call list, deputy, dated test on a non-working day

Alarm routed to a phone nobody answers

Temperature distribution

Probe positions justified by a temperature map of each room

A single probe next to the evaporator

Probe checks

Periodic, recorded comparison with a reference thermometer

Probes never checked since installation

Dock discipline

Written and measured maximum waiting time

Pallets left on the dock while another container is loaded

Contract operations

Parameters in line with the owner’s specifications, alarms set for the process

Defrosting run “by experience”

How do you pass the traceability test on a real pallet?

By running it the way the auditor will: a pallet picked at random, traced upstream and downstream, quantities included, stopwatch in hand. A multi-client warehouse must also prove, at any moment, which customer owns each pallet.

  1. Pick a reference at random in the warehouse management system, not a lot prepared in advance.
  2. Trace it back to intake: date, haulier, temperature on arrival, check carried out, owner.
  3. Follow its movements: successive locations, any contract operation, any change of room.
  4. Trace it forward to dispatch: delivery note, truck or container, seal number, consignee.
  5. Reconcile quantities received, stored, dispatched and remaining.
  6. Measure the total time and note the blockages.

According to the official SD401 self-assessment tool, the system is tested at a predetermined frequency, at least once a year, from consignor to final consignee and back, including subcontracted storage and transport; full traceability should be achievable within 4 hours. For comparison, IFS Logistics version 3 requires a test at least once every 12 months, mass balance included, with the customer’s timeframe when it is under four hours (requirement 4.4.3).

How do you protect product integrity?

By covering each threat with a prerequisite programme or a written assessment: damage, pests, allergens, malicious acts and fraud. Clause 2.1 lists the prerequisites expected of a warehouse; clauses 3.5.3.1 and 4.2.1 cover fraud and security.

  • Damaged goods, waste and returns. A procedure says who holds the product, where, and who decides. A crushed carton of frozen prawns does not leave without the owner’s decision.
  • Allergens. Even for packed products, the allergen management plan is one of the prerequisites: a split bag of nuts in a mixed cold room is an incident to handle.
  • Pests. The contractor, its bait plan, its reports and your actions are all checked, docks and container park included.
  • Malicious acts. The site-specific assessment of internal and external threats is reviewed at least once a year and after any incident (4.2.1). It covers products in storage and on vehicles: site access, waiting drivers, visitors, seals, cold room keys.
  • Fraud. The fraud vulnerability assessment plan covers the customers for whom you store (3.5.3.1): trading history, nature of the products, approval process for a new customer. The team that carries it out must understand the principles of vulnerability assessment.
  • People. Agency workers hired for a season know their responsibilities and where to find instructions (1.3.2): the auditor will talk to them.

Which contracts and service providers will the auditor ask about?

All those that touch the products. Since 10 August 2026, clause 3.5.2.1 requires a contract or written agreement, signed by both parties, with each subcontractor. Based on risk and customer contracts, it sets the temperature range, special handling requirements, product security, segregation of incompatible products and vehicle type. The subcontractor must operate to at least the same standards as the audited site.

Service provider

What the contract must set

Evidence to keep

Temperature-controlled haulier

Temperature range, vehicle, segregation, security, traceability

Signed contract, temperature records for each round, ATP certificate for international transport

Overflow warehouse

Same standards as the site, temperatures, traceability

Signed contract, result of its latest assessment

Pest control, cleaning, maintenance

Expected service, risks addressed, training of on-site staff (3.5.1.2)

Contract or specification, service reports

Product owner

Handling requirements carried over from its contract

Reviewed contract, written agreement before any outsourcing

For trucks, the ONSSA page on perishable foodstuff transport refers, for the international carriage of perishable foodstuffs, to the ATP Agreement: an inspection before the vehicle enters service, a check of its sanitary characteristics every three years and a check of its qualification at least every six years.

Which checklist should you sign off before the audit, and which mistakes should you avoid?

Sign off these points with your operations director, on the floor rather than in a meeting room.

Five mistakes keep coming back in the mock audits we run: an alarm routed to a single phone, manual readings missing on Sundays, an occasional haulier without a contract, a container loaded without a documented check, and traceability that stops at the dock because nothing links the pallet to the container number.

The full certification framework, with scope, modules and audit programmes, is in our BRCGS Storage and Distribution Issue 4 guide. And if your customers require two standards, see our BRCGS S&D vs IFS Logistics case study of a multi-client cold store near Tanger Med.