Five Reasons Your Training Compliance Project Cannot Afford to Wait

For many regulated food and packaging businesses, training compliance is on the list. It has been on the list for some time. The case for going digital with training records, SOP management and competency evidence is well understood internally, and yet the project keeps landing behind others that feel more urgent, more visible, or more politically easy to advance. HR system implementations, ERP upgrades, capital investment programmes: the queue ahead of it is rarely short.

The problem with this thinking is that it has become considerably more expensive to get wrong. Several developments in how major food safety certification schemes now treat training have changed the risk profile of delay in ways that deserve a closer look, regardless of where the project sits in the current technology roadmap.

1. Training is now a Fundamental requirement under BRCGS Issue 9, and Fundamental findings carry a different category of consequence

Training has been a requirement under the BRCGS Food Safety standard for as long as most operations have been certified. Under Issue 9, however, it sits alongside 11 other clauses classified as Fundamental Requirements, and that classification carries specific implications that were not in play under earlier issues.
A non-conformity against a Fundamental clause triggers automatic Major non-conformance status as a minimum. For any operation supplying major UK grocery retailers, most of whom have made BRCGS Issue 9 certification a condition of supply, a Major finding against Clause 7.1 puts the certification grade directly at risk. Operations managing training records on spreadsheets and paper filing systems do not have the audit evidence layer that Clause 7.1 now requires, and the exposure that creates is commercial as much as it is operational. A downgraded certification grade has customer relationship consequences that a delayed digital project does not.

2. The direction of travel has been set at a level above any individual scheme

BRCGS is the most visible standard for food manufacturers and packaging businesses in the UK and Ireland, but the frameworks that govern it sit higher up. GFSI, the Global Food Safety Initiative whose Benchmarking Requirements underpin BRCGS, FSSC 22000, SQF and IFS, published a significantly revised set of Benchmarking Requirements in December 2024, with all Certification Programme Owners required to align their own standards accordingly.
The most significant change in the GFSI BMRs v2024, and the one that carries the longest consequence for training management, is the embedding of food safety culture as a hard requirement across every GFSI-recognised scheme. Food safety culture, as GFSI now defines it, requires demonstrable evidence: structured workforce training, measurable competency, and a clear pattern of continuous improvement in how people across the operation understand and apply food safety practice day to day. Every scheme your operation holds certification under will reflect this as programme owners complete their alignment. Training compliance has moved from a scheme-specific requirement to a direction of travel set at the global framework level, and that distinction matters when deciding which projects to defer and which to advance.

3. Sequential project planning assumes the compliance gap is static ( and it is not)

The logic of addressing training compliance after other digital priorities have landed is reasonable on its surface. Get the foundational systems in place first, then layer training management on top. The problem with this sequence is that the remediation task does not wait. New starters are onboarded on incomplete records during the gap. SOPs are revised and the associated retraining goes uncaptured. People change roles and their competency history stays in the folder of the team they left. By the time the training compliance project reaches the top of the queue, it arrives carrying the accumulated weight of everything that happened while it was waiting, and the task of rebuilding an accurate training picture across the workforce is considerably larger than it would have been at the point the decision was first deferred.
One more point that rarely features in project pipeline conversations: every month that passes without a structured training evidence system in place is a month in which auditors could arrive. The gap does not pause because a different project is live.

4. When budgets are under review, the investments that underpin certification belong in a different category

UK food and drink manufacturers are managing a set of cost pressures in 2026 that have already prompted more than a quarter of producers to cancel or pause planned investment, according to the Food and Drink Federation. When that review happens internally, training compliance projects frequently appear in the same column as other technology initiatives, assessed on cost and implementation time without good consideration given to the specific function they serve and problems they solve. The distinction worth drawing is this: BRCGS certification is a commercial requirement for supplying the major grocery retailers, and the training compliance system sits directly under Clause 7.1 of that certification, one of its 12 Fundamental requirements. Measured against the cost of a Major finding on a Fundamental clause, a failed re-audit, a slip in grading, or the remediation required to recover from any of these, the systems offering protection from same offer significant value and  ROI  . Training compliance functions as revenue protection in the same way that product liability insurance does: a visible cost covering a risk that only gets noticed when it arrives.

5. The implementation timeline could be shorter than you might think

The belief that going digital on training compliance is a long, complex and operationally disruptive project is the assumption that most commonly holds the decision back, and while affected by a wealth of factors, as an assumption it is factually inaccurate and rarely black and white.

Origin Pharma Packaging, a specialist pharmaceutical and healthcare packaging business with a team of under 50, moved from paper records and spreadsheets to a fully digital training and SOP management system in just 90 days, working to an internal Q1 deadline their Quality Manager Joanne Davies had set at the start of the year.

Within weeks of meeting that deadline, auditors arrived and commented specifically on the team's preparedness and efficiency. The business now runs consistently above 99% training compliance, with Joanne describing the outcome as a system that "runs itself" once correctly set up and adopted.
The project many operations have classified as a significant future initiative and a time-sink, has the potential to be considerably shorter in practice than the queue it is sitting behind. If the assumption driving the deferral is that implementation takes longer than the programmes ahead of it, that assumption is worth some additional discovery before the next audit cycle begins.

For Quality, Technical and Compliance teams who already know the training compliance gap exists, the question is rarely whether to address it. The question is whether the conditions that once made deferral reasonable still apply, given what BRCGS Clause 7.1 now requires of Fundamental findings, and given the direction GFSI has set for every scheme that follows its framework.
If you would like to explore what a 90-day implementation looks like for an operation of your size, the Origin Pharma Packaging story is a practical starting point. [Download the one-pager.] Or if you'd prefer to talk it through directly, we're easy to reach.