BRCGS Issue 9 Indonesian Seafood: 2025 Audit Checklist

An auditor-ready, 60-minute mini-audit for Clause 4.5 (water and ice) tailored to Indonesian seafood processors that rely on external ice and variable water sources. Exactly which records, tests, and checks to have on hand before a 2025 audit, plus a concise verification routine.

We went from multiple water and ice nonconformities to an AA grade in 90 days using the exact system below. Clause 4.5 looks short on paper, but auditors go deep because seafood is high-risk and many Indonesian plants depend on external ice and mixed water sources. Here’s the focused, auditor-ready checklist we use across our lines, including sashimi-grade items like Yellowfin Saku (Sushi Grade) and IQF fillets such as Grouper Fillet (IQF).

The 3 pillars of passing BRCGS Clause 4.5

In our experience, you only need three things truly nailed:

Proven sources. Documented approval for every water and ice source, including external ice factories. Risk assessment, specs, and COAs that match your process risks.
Controlled distribution. Hygienic storage, dedicated utensils, protected transport, condensate control, and segregation of melt water. This is where auditors love to walk the floor and find gaps.
Ongoing verification. A risk-based testing schedule, trend reviews, and rapid corrective actions when results drift. If you can show trends and actions, auditors relax.

Weeks 1–2: Map and validate sources (use these tools)

Start with a one-page schematic of all water and ice routes through your site. Include bore wells, municipal water, on-site RO/UV systems, and every ice contact point. Then build the approval file for each source.

What to have ready for an external ice supplier approval file:

Signed supplier agreement stating ice is produced from potable water, food-grade equipment and bins, and protected transport. Include change notification requirements.
Supplier questionnaire and a recent audit or visit report. If no GFSI certificate, do a basic GMP audit checklist yourself.
COA for water used to make the ice showing potable compliance. E. coli absent in 100 ml, total coliforms absent in 100 ml, and aerobic colony counts within your spec or national limits.
COA for ice microbiology (melted ice). Same acceptance as potable water for contact ice.
Photos or records of ice truck cleaning, food-grade liners, and covered bins. Last wash/disinfection record.
Material specs for shovels, scoops, and bins. Food-grade, dedicated and color-coded.

For on-site water sources, bundle:

Source description, treatment steps (filtration, chlorination/UV/RO), and maintenance logs.
Potable specification and acceptance criteria aligned to local regulation or WHO potable standards. We typically use E. coli 0/100 ml and coliforms 0/100 ml. Trend aerobic colony count and Pseudomonas aeruginosa where high care or ready-to-eat is handled.
A Legionella risk assessment for any system creating aerosols or with holding tanks and dead legs. Cooling towers and misting systems require specific controls and, in some cases, targeted testing.

Takeaway: If your approval file reads like a story from source to scoop, you’re 50% there.

Weeks 3–6: Build the in-plant control routine

Here’s the thing. Most nonconformities aren’t about missing tests. They’re about the last meter of handling.

Daily/shift controls we standardize in seafood plants:

Ice receiving. Check truck cleanliness, last wash record, bin covers in place, no foreign odours, and last cargo was food-grade ice only. Record time, supplier lot, and temperature of ice core (near 0°C). Use a short pre-receipt checklist and keep it with the delivery note.
Ice storage sanitation. Dedicated cold room or insulated bins with lids. Clean-and-disinfect schedule with visible sign-off. No cardboard, wooden pallets, or chemicals stored nearby. Dedicated scoops on hangers.
Melt water segregation. Ice melt drains away from product areas. No standing water around cutting tables. Auditors often follow the drain lines, so make this obvious.
Condensate control above product. Insulate cold pipes, install drip trays where needed, and run a weekly condensation inspection log. Clause 4.5.3 trips up otherwise clean sites.

For on-site ice makers:

Use potable water feed only. Maintain and document sanitation of the ice maker. We’ve seen best results with a weekly quick clean and a monthly full disassembly and sanitization, validated at least annually.
Swab high-touch points quarterly for indicator organisms when making ice for direct contact with fish.

Takeaway: If you can walk an auditor from receiving to storage to line use without touching a non-dedicated tool or stepping over melt water, you’ll avoid the classic majors.

Weeks 7–12: Verification that actually satisfies auditors

We recommend a risk-based potable water testing schedule for Indonesian seafood plants handling raw and sushi-grade products:

Incoming water at point-of-use. Monthly for E. coli and coliforms (absent in 100 ml). Monthly aerobic colony count trending at 22–37°C with in-house alert limits. Add Pseudomonas aeruginosa where you handle RTE/sashimi.
Ice used for direct product contact. Monthly melted-ice tests for E. coli and coliforms. If using multiple suppliers, rotate weekly across suppliers until you have 6 months of stable data, then move to monthly per supplier.
Seawater use controls. If using seawater for initial wash of whole fish, test seawater at least monthly for E. coli absence and periodically for Vibrio species during warmer months. Final rinse prior to filleting or packing should be with potable water. For sashimi-grade lines, we do not use seawater at any rinse stage.
Chemical verification. Residual chlorine checks if applicable. RO/UV performance verification weekly. Filter change records by hours/pressure differential.

Note: BRCGS sets a performance expectation rather than fixed global limits. Use national regulations where stricter. Our default acceptance limits that auditors commonly accept for potable water and ice contacting fish are E. coli 0/100 ml, coliforms 0/100 ml, with aerobic counts trending to demonstrate control.

Trend results quarterly in management review. If results drift upward, show documented actions, not just repeat testing.

What will a BRCGS auditor look for in our ice sourcing and storage?

An approved supplier file with water and ice COAs, transport hygiene proof, and a signed spec.
Receiving checks per delivery plus traceability of ice to production batches.
Clean, dedicated storage with closed bins and hygienic scoops. Melt-water drains away from product zones.

How often should we test water and incoming ice?

Risk-based. For Indonesian seafood plants we support, monthly microbiology on point-of-use water and monthly melted-ice testing per active supplier works well. New or seasonal suppliers should be increased to each delivery until trends are stable.

Are we allowed to use seawater for rinsing fish and what controls are required?

Yes for raw whole fish pre-wash when risk-assessed and microbiologically acceptable. Final rinses that contact fillets or product surfaces should be potable. Add increased Vibrio surveillance during warmer months and never use seawater on sashimi-grade production.

Which documents prove an external ice supplier is approved?

Supplier agreement, questionnaire/GMP audit, potability COA for water, microbiological COA for ice, transport cleaning records, and proof of covered, food-grade bins and utensils. Keep copies of their licenses and any third-party certificates.

What microbiological limits apply to potable water and ice?

Align to local regulation or WHO potable water standards. The acceptance criteria we and most auditors use for contact water/ice: E. coli absent in 100 ml, coliforms absent in 100 ml, with aerobic colony counts trended. Add Pseudomonas aeruginosa criteria where RTE/sashimi products are present.

How do we show the ice transport truck is clean and hygienic?

Keep a receiving checklist with last wash/disinfection record, pictures of covered bins/liners, dedicated ice-only transport, no mixed loads, and a quick visual inspection note per delivery. Record core ice temperature and reject criteria.

What corrective actions satisfy auditors if water or ice fails testing?

Immediate product hold for affected lots and stop-use of the source.
Investigate. Source contamination, treatment failure, transport hygiene lapse.
Correct. Shock chlorination or UV lamp replacement, filter change, deep clean of ice maker or trucks, supplier corrective action request.
Verify. Re-test and only release after two consecutive acceptable results. Trend and raise the testing frequency temporarily.

The 60-minute mini-audit we run before any 2025 audit

Set a timer for one hour. Pull these records and walk the route with an auditor’s eyes.

Desk pack: Water/ice risk assessment, potable spec, Legionella risk assessment, latest 12 months of water and melted-ice COAs and trends, calibration for chlorine/ATP/temperature devices, filter change logs, UV/RO service.
External ice file: Signed spec and agreement, audit/visit report, COAs for water and ice, transport cleaning record, and last 3 delivery checklists with temperature.
In-plant control: Ice storage sanitation records, color-coded scoop procedure, melt-water drainage map, condensate inspection log, maintenance sign-offs for pipe insulation.
Floor check: Follow an ice batch from receiving to line use. Look for uncovered bins, shared scoops, pooling water, and condensation risks above product. Fix anything you wouldn’t defend to an auditor.

If you run high-spec lines like Yellowfin Saku (Sushi Grade) or premium IQF portions such as Mahi Mahi Portion (IQF), add quarterly environmental swabs around ice handling stations and a stricter verification cadence.

5 costly mistakes we keep seeing (and how to avoid them)

Assuming supplier COAs are enough. They’re necessary but not sufficient. Do your own periodic testing of melted ice and verify transport hygiene.
Final rinsing with non-potable water. Use potable only for final rinses and contact ice. Seawater is fine for pre-wash with controls, not for ready-to-pack fillets.
Neglecting condensate. Clause 4.5.3 is a frequent hit. Insulate, capture, and document weekly checks.
No Legionella thinking. Even if you don’t sample, you must show a risk assessment and controls for any aerosol-generating or stagnant systems.
Great tests, poor trending. Auditors want to see you notice small drifts and react before failure. Plot the data and set alert/action levels.

Resources and next steps

If you need a quick, tailored gap-check on your Clause 4.5 controls, we’re happy to walk your team through this 60-minute mini-audit and leave you with a punch list. Need help with your specific situation? Contact us on whatsapp. If you’re reviewing specifications against product risk, our product pages show how we translate these controls into premium outputs. Start here: View our products.

One last thought. The best water and ice programs are boring. Consistent checks, clean storage, clear records. When auditors see “boring,” they move on. And that’s the goal.