Non-Conformance & CAPA Management for Food Manufacturers

A workflow for logging non-conformances, finding the real root cause and closing corrective and preventive actions with evidence.

By the SoftSpec team · Updated

Key terms

TermMeaning
Non-conformity (NC)Any failure to meet a requirement — a specification limit, a procedure, a legal requirement or a customer standard.
Non-conforming productProduct that does not meet its specification. It must be identified, segregated and controlled so it cannot be used or dispatched by mistake.
CorrectionThe immediate fix: quarantining stock, re-cleaning a line, relabelling.
Corrective actionAction that removes the cause of a non-conformity so it does not happen again.
Preventive actionAction that removes the cause of a potential non-conformity before it occurs.
CAPACorrective and preventive action — the combined process of finding causes and preventing recurrence.

In BRCGS Food Safety, corrective and preventive action and the control of non-conforming product are covered in sections 3.7 and 3.8. Auditors look for a documented procedure, evidence it is followed, and proof that actions are effective.

A seven-step NC and CAPA workflow

  1. Raise it. Anyone should be able to log a non-conformity — from goods in, production, hygiene, internal audit, a customer complaint or a supplier issue. Capture what, where, when, which product and batch, and who found it.
  2. Contain it. Take immediate correction: quarantine and label affected product, stop the line if needed, and assess whether product already dispatched is affected. Decide whether the incident procedure or a withdrawal is required.
  3. Assess risk. Grade the non-conformity (for example minor, major, critical) so high-risk issues get faster attention and senior management visibility.
  4. Decide on the product. A competent, authorised person decides what happens to non-conforming product — release under concession, rework, downgrade or disposal — and the decision is recorded.
  5. Find the root cause. Use a structured method (see below). "Operator error" is rarely a root cause on its own.
  6. Act. Assign corrective and preventive actions to named owners with due dates. Update procedures, training, specifications or HACCP where needed.
  7. Verify and close. Check the actions were completed and worked — for example, no recurrence over a defined period — before closing, and keep the evidence.

Root cause analysis that holds up at audit

The 5 Whys

Keep asking "why?" until you reach a cause you can control. For example: Metal detector failed its check → the test was not done at start-up → the new starter was not trained on the check → the training matrix did not include metal detection → the matrix is not updated when roles change. The corrective action is to fix the training process, not only to retrain one person.

Fishbone (Ishikawa) diagram

For more complex problems, look at every category of possible cause: people, methods, materials, machines, measurement and environment. This helps teams avoid jumping to the first explanation.

Signs a root cause is not good enough

  • It restates the problem ("the label was wrong").
  • It blames a person without asking why the system allowed the error.
  • The corrective action is only "retrain" or "remind staff".
  • The same issue recurs within weeks.

Closing BRCGS audit non-conformities

After a BRCGS Food Safety audit, sites normally have 28 calendar days to send the certification body objective evidence that each non-conformity has been corrected, together with a root cause analysis and a preventive action plan. Late or weak evidence can delay certification or affect the grade, so:

  • log every audit finding in your NC system on the day of the audit;
  • assign owners and due dates well within the 28 days;
  • collect evidence as you go — photos, revised procedures, training records, test results; and
  • check the preventive action plan is realistic and has dates.

KPIs and trend analysis

Individual NCs tell you what went wrong; trends tell you where your system is weak. Useful measures include:

  • number of NCs raised by source (internal audit, goods in, production, supplier, complaint);
  • average time to close, and number of overdue actions;
  • repeat NCs on the same process, product or supplier;
  • proportion of NCs where the root cause was systemic rather than individual; and
  • complaint rate per million units, linked back to NCs.

Review trends at management review and use them to raise preventive actions. Supplier-related trends should feed your supplier performance monitoring.

SoftSpec records complaints, internal audit findings and non-conformances in one place, with owners, due dates, evidence and trend analysis, so you can show an auditor the full history of any issue. See how it fits into BRCGS compliance management.

Frequently asked questions

What is the difference between corrective and preventive action?

Corrective action removes the cause of a non-conformity that has happened; preventive action removes the cause of a potential non-conformity before it happens.

How long do you have to close BRCGS audit non-conformities?

Normally 28 calendar days after the audit to submit objective evidence of correction, with a root cause analysis and preventive action plan.

What is root cause analysis in food manufacturing?

A structured way to find the underlying reason for a problem, using tools such as the 5 Whys and fishbone diagrams.

Manage specifications and suppliers in one place

SoftSpec replaces spreadsheets and email chains with digital specifications, supplier approval workflows and a full audit trail for BRCGS.