BRCGS 3.5.4 - Outsourced Process Management

The question is, did you rent the space and still manage the processes and the people and the transactions through the building? If that's the case, it is not considered an outsourced process for this clause.

If this process was its own company that you hired to ship product to, them store things, and then ship back to you, then it would be.

Tony-C IFSQN Fellow · Answer 2 · 2025-12-03T07:13:23+00:00

Hi Alutka_120

If your storage is being managed by a separate organization then section 3.5.3 applies:

There shall be a procedure for the approval and monitoring of suppliers of services. Such services shall include, as appropriate:

• transport and distribution

• off-site storage of ingredients or packaging (other than at the supplier’s facilities) prior to delivery to the site

Clause 3.5.4 Management of outsourced processing doesn’t apply

Where there is additional storage or processing of raw materials prior to their initial arrival on site, this is not considered outsourced processing, but should be managed by the site using supplier approval, raw material risk assessments and raw material specifications.

If you are renting and managing this extra storage facility yourself then most likely it needs to be added to the scope.

You might find this this topic here useful: Do I need to include a new offsite storage facility in scope?

Kind regards,

Tony

marco89634 IFSQN Active · Answer 3 · 2025-12-03T16:31:01+00:00

According to BRCGS, "outsourced processing" in Issue 9 refers to any intermediate stage (production, processing, or even just storage) performed by a third party or at another site, after which the product returns to the plant for further processing or packaging.

In this sense, your case fits perfectly, if I understand correctly: you purchased frozen raw materials, initially stored them on-site, and, due to space constraints, moved them to a rented warehouse, from which they then returned for processing. This time in the external warehouse isn't just logistics, but a true intermediate stage in the production process, and therefore falls within the scope of clause 3.5.4.

Il flusso effettivo è qualcosa del tipo: ricevere le materie prime in loco → magazzino congelato in un magazzino esterno → tornare sul sito → ulteriori operazioni.

For BRCGS, the external warehouse, in this scheme, isn't just a generic service provider, but performs part of your preservation process; For this reason, it must be managed as outsourced processing and not just under 3.5.3.

A specific "frozen storage in an external warehouse" phase must therefore be included in the HACCP flowchart, with a related hazard analysis (exposure to unsuitable temperatures during loading/unloading and transport, failures of the third-party refrigeration system, stock rotation errors, etc.).

This also informs the operational requirements of 3.5.4: supplier approval and monitoring according to GFSI-equivalent criteria, a written service specification that clearly defines storage and handling conditions, an acceptance procedure for returning raw materials to the site, and the guarantee of complete traceability throughout the product's out-of-plant life.

Regarding the question of whether the time spent by frozen raw materials in the rented warehouse should be considered under 3.5.4, the answer is yes: it constitutes an outsourced phase of the process and must be managed as such, with HACCP, specifications, and adequate controls.

Only in a different scenario, where the product leaves your factory, goes to a third-party warehouse and from there directly to the customer without ever returning, would we be talking about a service provider pursuant to 3.5.3 and no longer about outsourced processing.

BRCGS 3.5.4 - Outsourced Process Management

Alutka_120

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