BRCGS Issue 9 training requirements: building a training matrix and proving competence

Every BRCGS audit samples training records, and most training findings come from the same place: a pile of attendance registers that shows people sat in a room, but not that they can do the job. A BRCGS training matrix linked to competence checks fixes that. It shows at a glance who needs what, who has it, and who is overdue.

What BRCGS Issue 9 asks for in training and competence

Training for staff in raw material handling, preparation, processing, packing and storage areas sits in section 7.1 of BRCGS Food Safety Issue 9. Read the standard’s own wording for your site, but in plain language the expectations are:

• All personnel, including agency-supplied and temporary staff and contractors, are appropriately trained before they start work and adequately supervised while they work.
• People working on CCPs and other control measures receive relevant training and have their competence assessed.
• The site has documented training programmes that identify the competencies each role needs, provide the training, review whether it was effective, and deliver it in a language the trainee understands.
• All personnel, engineers, agency staff and contractors included, receive general allergen awareness training and training in the site’s allergen-handling procedures.
• Relevant staff are trained in the site’s labelling and packing processes.
• Training records show at least the trainee’s name and confirmation of attendance, the date and duration, the title or content, the training provider and, for internal training, the work instruction or procedure used. Where an agency trains on your behalf, you still need its records.
• The site routinely reviews the competence of its staff and provides refresher training, coaching or mentoring where needed.

Training is one of the fundamental requirements of Issue 9, so a serious gap here puts the whole certificate at risk. Notice that the records requirement asks for attendance and content, not proof of competence. Competence comes from the CCP requirement and the routine competence review, which is why your matrix needs a competence column as well as a training date.

Training also appears elsewhere in the standard. The HACCP team needs specific knowledge of HACCP and of the products and processes, and the internal audit, food defence and food safety culture requirements all depend on people who understand their part. Your matrix should cover these too, not only the production floor.

Mapping roles to the training each one needs

Start with roles, not names. List every role on site, then decide what each one needs to know to do the job safely. A typical food manufacturer will have:

• Production operators and packers
• CCP monitors, such as metal detector checkers or cooking operators
• Hygiene and cleaning staff
• Stores, receiving and dispatch staff
• Engineering and maintenance technicians
• QC and laboratory staff
• Supervisors and team leaders
• HACCP team members and internal auditors
• Senior management
• Agency workers, contractors and visitors

For each role, list the topics: hygiene induction, personal hygiene, allergen awareness, foreign body control, glass and brittle plastic, cleaning and chemical handling, CCP monitoring, labelling and pack checks, traceability, pest awareness, food defence and food safety culture. Not every role needs every topic, and not to the same depth.

Building the BRCGS training matrix: roles, topics, levels and refresher dates

Use two linked tables. The first is the requirement matrix: roles down the side, topics across the top, and in each cell the level required and the refresher frequency. The second is the people matrix: names down the side, the same topics across the top, and in each cell the date trained, the date competence was confirmed and the date the refresher is due.

Keep the levels simple. Four are usually enough:

Level	Meaning	Evidence
A: Awareness	Knows the rule and why it exists	Induction record, short quiz or verbal questions
T: Trained	Has been shown how to do the task	Training record with content and trainer
C: Competent	Does the task correctly without help	Observation checklist signed by an assessor
I: Instructor	Can train and assess others	Assessor sign-off and trainer training

Set refresher frequencies on risk. The standard does not give you a fixed period for most topics, so decide and write down your reasons. Many sites refresh hygiene and allergen awareness yearly and reassess CCP monitors yearly, and also after any deviation caused by the way the check was done, after a change in equipment, or after a long absence. Whatever you choose, the matrix should flag overdue items automatically, or at least be reviewed monthly.

A worked example

A snack manufacturer in Gauteng had one training spreadsheet with 140 names and 30 columns, most of them blank. They rebuilt it as a role matrix first. Operators needed seven topics, CCP monitors ten, and cleaners six, which made the gaps obvious. The QA coordinator then built the people matrix from the role matrix, so a new operator automatically inherited the seven required topics. Within two months every CCP monitor had a signed competence assessment, and the overdue list fitted on one page.

Agency, temporary and new staff

Agency and temporary staff are where training systems most often break down, particularly on sites that bring in extra people for seasonal peaks. The rules are simple:

• No one enters production without a site hygiene induction, whatever training the agency says they have had.
• Induction is in a language and format the person understands. Use pictures, demonstrations and a translator from the team where literacy or language is a barrier.
• New and agency staff work alongside an experienced person and are not given CCP or other critical tasks until they are signed off as competent.
• The induction record is kept on site, with the person’s name, date, content and trainer.
• Your agreement with the agency states what they must provide and what you will do on site.

Keep a separate daily list of agency workers on each shift. Auditors often ask for it and then pick two names to trace.

Proving competence: observation, questioning and sign-off

Attendance is not competence. Competence is shown when a trained assessor watches the person do the task and asks questions that show they understand it. For a metal detector check, for example, the assessor watches the operator:

1. Select the correct test pieces for the product.
2. Pass each test piece through the detector in the right position in the pack.
3. Confirm the reject mechanism works and the rejected pack goes to the locked bin.
4. Record the result correctly.
5. Explain what to do if a test piece is not detected, including what happens to product made since the last good check.

The assessor signs and dates the checklist and the operator signs to confirm. That signed checklist is your evidence. Repeat it at the reassessment frequency on your matrix.

What the auditor samples, and the gaps they find

Auditors usually pick people they see on the floor and ask for their records, rather than starting from your files. They often talk to the operator directly about what they do and why. Expect them to check:

• CCP monitors on shift that day and their competence records.
• Agency workers on shift and their induction records.
• Allergen awareness records for engineers, cleaners and contractors, not only operators.
• Training content and whether it matches current procedures.
• The competence of the trainers themselves.
• HACCP team training and experience.
• Whether refresher training is up to date.

The gaps we find most often are attendance registers with no content or trainer recorded, CCP monitors with training but no competence assessment, agency staff working without a site induction, refreshers long overdue, and training material still describing a procedure that changed last year. An internal food safety audit that samples from the floor, the way a certification auditor does, will show you these before the auditor does.

Training is also one of the clearest signals of your food safety culture. A site that invests in competence, rather than just attendance, usually shows it in every other part of the audit.

What to do this week

• List every role on site and the topics each one needs.
• Pick three CCP monitors and check whether each has a signed competence assessment.
• Check that today’s agency workers all have a site induction on record.
• Agree four competence levels and write them at the top of your matrix.
• Set refresher frequencies and write down the reason for each one.

If you are setting up or upgrading a BRCGS system, our Implementation of BRCGS Issue 9 for Food Manufacturing course works through the standard section by section, training and competence included. The BRCGS Issue 9 document templates toolkit gives you a starting set of procedures and records, and our BRCGS implementation consulting can help on site.