BRCGS Food Safety Issue 9 expects every temperature-controlled store to have recording with alarms or manual checks about every four hours, calibrated and traceable instruments, validated temperature distribution in cold stores and freezers, and records kept for shelf life plus 12 months. Storage and Distribution Issue 4 adds vehicle recording, driver alerts and time limits outside control (paraphrased).
Why it matters
Certification asks for more than the law
For manufacturers, cold stores and distributors that supply retailers, the BRCGS audit is often the stricter test. The law says monitor 'effectively'; BRCGS says how often a manual check must be, what a CCP record must contain, how long to keep it and what to do when a sensor is found out of calibration.
The standards are licensed, so we paraphrase them here and cite the clause. Clause numbers were checked against the published standards and BRCGS position statements on 19 October 2026.
What the standards say
Food Safety Issue 9
From Food Safety Issue 9 (paraphrased):
- 4.15.3 Storage: where temperature control is needed, stores hold product within specification, with either temperature recording equipment and suitable alarms on all storage facilities, or recorded manual checks, typically at least every 4 hours or often enough to intervene before product goes out of limits.
- 4.16.2 and 4.16.3 Transport: vehicles able to maintain temperature requirements; temperature-controlled transport holds product within specification at minimum and maximum load, shown by data loggers or by records of refrigeration operation. 4.16.5 asks for procedures for breakdown and refrigeration failure, and 4.16.1 lists controlling the temperature of loading docks and vehicles among the procedures to consider.
- 2.10 CCP monitoring: monitoring that detects loss of control in time to act; records with date, time and result, signed, and verified where appropriate by an authorised person; evidence that electronic records were checked. 2.11.1 asks for a documented corrective action, including what happens to product made while out of control.
- 6.1.5 Temperature distribution: where conditions can vary within equipment critical to safety or quality, its characteristics are validated and verified at a frequency based on risk and performance; the examples include temperature distribution in freezers and cold stores. This is the Issue 9 basis for mapping. 6.1.6 asks for procedures to establish the safety of product after equipment failure.
- 6.4 Calibration: a list of measuring devices with location, identifier and due date; checks at a risk-based frequency, traceable to a national or international standard where possible; uncertainty considered against critical limits; action on product when a device is found out of limits.
- 3.3.2 Records: kept for a defined period that considers legal and customer requirements and shelf life, at minimum shelf life plus 12 months.
Storage and Distribution Issue 4, and SALSA
Storage and Distribution Issue 4 goes further for warehouses and fleets (paraphrased). Its temperature rules sit in the core requirements, not in an optional module: environment control in storage (7.3) and vehicle temperature controls (5.4). Clause 7.3.2 mirrors the alarm-or-4-hourly-check rule. Clause 7.3.4 asks sites to set maximum times product may spend outside temperature control, including at loading, unloading and staging. Clause 7.3.5 asks for equipment-failure procedures that settle the product's status with its owner before release. Clause 7.3.7 requires the uniformity of temperature in controlled stores to be 'established, validated and verified at a frequency based on risk', which is a mapping requirement, and 7.3.8 asks for performance to be re-established after equipment changes. Section 5.4 covers vehicle validation in all weather and at minimum and maximum load (5.4.1), automatic load-space recording (or recorded manual checks where there is no such equipment, 5.4.2), pre-cooling (5.4.3), driver alerts (5.4.5) and equipment failure (5.4.6). Calibration (6.3) matches Food Safety 6.4 but requires traceability to a national standard for devices measuring product safety, legality and quality, and the product owner told when a device is found inaccurate. Goods-in checks temperature before acceptance (7.1.1). Records are kept for a defined period 'but shall never be less than 1 year' (3.1.3.1). The optional modules add their own rules: cross-docking (11.4), e-commerce packaging validated to hold temperature (12.5) and contract chilling and freezing (section 17).
Position Statement 20, effective 10 August 2026, rewords clause 17.3 for contract chilling and freezing sites (section 17): alarm settings must suit the process, and for sites relying on manual checks it gives a general guide of every 2 hours for chilled and every 4 hours for frozen unless otherwise justified. The checks continue at weekends and holidays and may be less frequent while doors stay shut. Records are kept for shelf life plus one year. SALSA Issue 7, used for all SALSA audits from 1 September 2026, asks for monitored temperature controls with records, calibrated probes and recorders, and records kept for shelf life plus one year, without BRCGS's frequencies.
| Control | BRCGS FS 9 | BRCGS S&D 4 | SALSA 7 |
|---|---|---|---|
| Alarms or 4-hourly manual checks | ✓ | ✓ | · |
| Temperature mapping of stores | ✓ | ✓ | · |
| Time limits outside temperature control | · | ✓ | · |
| Load-space recording in vehicles (automatic, or recorded manual checks) | · | ✓ | · |
| Calibration traceable to a national standard | ✓ | ✓ | · |
| Records: shelf life plus 12 months | ✓ | · | ✓ |
Paraphrased from BRCGS Food Safety Issue 9, Storage and Distribution Issue 4 and SALSA Issue 7. A tick means the standard states it explicitly.
What good looks like
What the auditor will ask to see
Expect to be asked where each limit comes from, to show a week of records including nights and weekends, to show who receives the alarm at 3am and proof they did, to produce the calibration certificate for the sensor in front of the auditor, and to walk through your last excursion and the product decision. A record that shows the excursion, the response and a named sign-off is usually stronger evidence than a record with no excursions at all.
More on how this plays out on site is on our BRCGS explainer.
Worked example
An out-of-calibration sensor at audit
This is an illustrative example; readings are invented. During its annual calibration a cold store's sensor in chill room 3 is found reading 1.2 °C low. The room's limit is 5 °C and the records show readings up to 4.6 °C over the last year.
What S&D 6.3.5 (and Food Safety 6.4.4) asks for: a recorded action, with at-risk product kept off sale and, under S&D, the product owner told. The site works out that the true temperature may have reached 5.8 °C, identifies the dates and the product stored, tells the product owners, and records their decisions. It adjusts the sensor, re-verifies it, and moves that room to a six-monthly calibration. At audit, the record of what was done is what the auditor wants: the out-of-tolerance finding itself is not the non-conformity.
Where it is unclear
Two-hourly or four-hourly, and unit records
Position Statement 20's 2-hour figure is written for section 17; whether auditors will apply it to general chilled storage under 7.3.2 is unclear. Food Safety 4.16.3 accepts refrigeration operation records for transport, while Storage and Distribution 5.4.2 asks for load-space recording (or recorded manual checks where there is no such equipment). And the standards do not say how often electronic records must be reviewed. These are compared under BRCGS and the law.
Inspection findings
What audits find most
BRCGS does not publish a primary list of top non-conformities that we could find. A certification body datasheet based on more than 72,000 audits puts hygiene (4.11.1) first, then chemical control, equipment, doors and pest prevention, fabric and traceability; calibration and storage temperature are not in its top list. Temperature findings still occur, but the published data do not say how often.
In summary
The short version
- BRCGS Food Safety 4.15.3: alarms on every controlled store, or recorded checks about every 4 hours.
- Risk-based validation of temperature distribution (mapping): Food Safety 6.1.5 names cold stores and freezers; Storage and Distribution 7.3.7 covers every controlled store.
- Calibration under 6.4 is risk-based and traceable; act on product when a device is out of limits.
- Records: shelf life plus 12 months (Food Safety), never under 1 year (S&D), shelf life plus one year (SALSA).
- Position Statement 20 (contract chilling and freezing, section 17): where checks are manual, as a guide every 2 hours chilled and 4 hours frozen, continuing at weekends and holidays, and possibly less often while doors stay shut.
- Clause numbers checked against the standards; wording paraphrased.