Equipment questions under BRCGS: not in use, old kit and new purchases
BRCGS 4.6 answers: equipment not in use or obsolete, old equipment with no specification, buying food-grade parts, testing kit near the line.
Section 4.6 of the BRCGS Food Standard Issue 9 raises lots of practical questions. Here are our auditors' answers.
Q: Do we need to distinguish obsolete equipment from equipment temporarily out of use?
Yes. Clearly mark obsolete equipment and remove it as soon as you can. For equipment temporarily out of service, document how it is managed, cleaned and stored until it's back in use. If there's no evidence that kit is obsolete, and it isn't maintained or calibrated, that's an NC waiting to happen.
Well-organised sites log the status of each item on their maintenance system: obsolete, awaiting repair, out of calibration, with planned works. With the equipment stored appropriately (covered, for example), there's no reason to raise an NC.
Q: Do we need a 4.6.4 procedure even if we're not moving equipment?
Yes. The clause says "a procedure shall be in place", not "should" or "based on risk". The key is making sure equipment not in use is cleaned and stored so it doesn't create a contamination risk and is ready when needed.
Q: What's best practice for equipment not in use?
Clean and disinfect it before storing; keep it in a clean area away from production; label it "out of use"; keep records of when it went out of service and any cleaning and maintenance; and check it periodically while it's stored.
Q: Our equipment is very old and the original specification is gone. What now?
Show it's still safe and fit for use: carry out a risk assessment, keep records of repairs and updates, keep it clean and maintained, and follow industry guidance. A sensible risk assessment is hard to argue with. If it's really outdated, plan for replacement. For new equipment, both BRCGS Food Issue 9 and Packaging Issue 7 now require an equipment specification and evidence of suitability, such as food contact statements, so you don't end up in the same position again. Equipment design (4.6.2) is a top Issue 9 non-conformity; we cover it on our BRCGS Food Safety Issue 9 Sites Training.
Q: Is a supplier questionnaire enough when buying a food-grade belt?
Not on its own. You need a documented purchase specification setting out your requirements (food contact compliance with a declaration of conformity, intended use, materials it will handle), and proof from the supplier that it meets them before supply. Then inspect, test and install it so it can be cleaned and maintained, and keep records.
Q: Can testing equipment (pH, CO2, visual tools) sit next to the line?
Yes, as long as it's clean, maintained, doesn't create a contamination risk and doesn't get in the way of safety or production flow.
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Reviewed by Cathy Gladwin, Director & BRCGS ATP Trainer, STC · November 2026
These Q&As share general best practice from our trainers and auditors. They aren't consultancy advice for your site. For support specific to your site and systems, we can refer you to our sister company QTC.
Learn more: BRCGS Food Safety Issue 9 Sites Training and the course calendar. For a gap audit of your equipment controls, contact QTC.