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audit duration

The BRC have recently published an updated position statement for F806: Audit Duration Calculator. In this article we’re going to go through what the audit duration changes are and what that means for your site.

If your audit is on or after the 1st April 2020, your audit duration will change.

How to work out your audit duration

The first step is to establish how many staff you have and the size of your manufacturing facility.  The size isn’t the whole site, it’s just the manufacturing facility – so don’t fall into the trap of counting the staff in the whole site.

Employees

Size of manufacturing facility

Less than 10,000m²

Between 10,000-25,000m²

Greater than 25,000m²

1-50 Was: 16 hours

Now: 18 hours

Was: 16 hours

Now: 18 hours

Was: 18 hours

Now: 20 hours

51-500 Was: 18 hours

Now: 20 hours

Was: 20 hours

Now: 24 hours

Was: 24 hours

Now: 26 hours

501-1500 Was: 20 hours

Now: 22 hours

Was: 24 hours

Now: 26 hours

Was: 28 hours

Now: 30 hours

More than 1500 Was: 20 hours

Now: 22 hours

Was: 28 hours

Now: 32 hours

Was: 32 hours

Now: 34 hours

So, you can see that most audits have now increased by 2 hours as a minimum (shown in green).  And a couple of the 10-25m² facilities have increased by 4 hours (shown in red). Once you’ve got your base audit duration, you then need to consider if you need to add any more hours onto your audit.

Consider the number of HACCP plans you have…

  • If you have more than three HACCP plans you need to add additional time onto your audit. For 4-6 HACCP plans, you need to add on another 4 hours. This means there is no increase in time from the previous version of the calculator.
  • If you have 7 or more HACCP plans, you need to add on 8 hours. This means that there is an increase of 1 hour from the previous version of the calculator.

Now, here we have a recommendation for you. Many times we go to sites and they have a separate HACCP plans for different production lines or products, where it’s really not necessary. If you can combine your HACCP plans, this will reduce the number down.  This is especially important if you have more than 3 HACCP’s, to ensure that you don’t have to add additional time onto your audit – when it may not be necessary.

If you have more than 3 HACCP’s and are wondering if you can combine them, we’d be happy to look at them for you and let you know if we think they can be combined.  Please feel free to email us – kassy.marsh@techni-k.co.uk

Applicable sections of the Standard…

There are now 2 new sections to the Standard that will now increase your audit duration:

  • Section 8: High risk, high care and ambient high care
  • Section 9: Traded products

Section 8

If the high risk, high care and ambient high care section is applicable to you, you now need to add on an extra 2 hours per area. So, if you have a high care area and a high risk area, that would be 2 hours per area – so this is a total of 4 hours.

If you have more than 1 of these areas, you need to add on 2 hours per area.  So, for example: If you have 2 high risk areas on site, it would be 2 hours per area –  a total of 4 hours.

We really don’t understand why they have added on extra time for this.  The Standard hasn’t changed, they’ve just moved the requirements, so they all sit together in one section.  So really, there is no justification for the increase in time.

Section 9

As traded products are now in the main Standard, if you’re going to go for this (it’s still voluntary, so you don’t have to) you now also need to add 1 or more hours. 1 or more hours is very vague, and they have not provided any clues as to how many hours over 1 should be added, or how this would be calculated.

Additional modules…

If you want to bolt on additional modules to your audit, you also need to add time for this to your audit duration. There are no changes here from the version 3 of the position statement, with the exception that they’ve also included the time for the ethical audit, if you want to do that.

  • Module 10: Global G.A.P – add 1 or more hours (Again, no clues as to how this is calculated.)
  • Module 11: Meat supply chain, Module 12:  Gluten free, Module 13: FSMA and the new Ethical module – add on 2-4 hours.  (Again, no clues as to how you work out if you should be 2, 3 or 4 hours.)

An audit day…

The BRC say that an audit day should be between 8 hours and 10 hours, but this doesn’t include breaks. So, if you’re a site that needs a 24-hour audit, you can do this in 2 x 10 hour days, and an additional day of 4 hours or 3 x 8 hour days.

We don’t know about you, but audit days are tiring enough without having to do 10 hours without a break. We feel it is quite unethical as well, to expect an auditor or an auditee to work 10 hours without a break. So, let’s say you have a 15 minute break in the morning for coffee, a 30 minute break at lunch and a 15 minute break in the afternoon – it’s not a great deal of time for breaks, but that then makes it an 11-hour day. Which would mean a start time of say 8:30am and finishing at 7:30pm.

We don’t think that’s an acceptable norm. The auditor will be expected to probably do 2 audits in a week, so that means we’re asking them to work 4 x 11 hour days and write up 2 audit reports in the fifth day.  So, by the fifth day, with a day of work left to do, they’ve already done 44 hours, that doesn’t include travel time between sites and back home.

On the fifth day, the auditor needs to write up the 2 audits, which BRC say should take between 4 and 8 hours each.  So, if we go with the minimum time of 4 hours, that means that they need to do 8 hours. This takes their working week to 52 hours as a minimum. If we take an average of 6 hours an audit report, then it could even be 56 hours!

The working time directive states you can’t work more than 48 hours a week on average. You must also have at least 11 hours break between work periods.

What is really crazy…

Not only does the law state that this is not ethical, the new BRC Standard for Ethical Trade and Responsible Sourcing, actually has a section in it about working hours and it says:

Clause 3.8.2: The working hours must include the provision of breaks.

Clause 3.8.3: Ordinary working hours must not exceed 48 hours a week.

We find it quite unbelievable that BRC have not considered their own compliance to these clauses and have not given thought about what they are asking of their Certification Body auditors and also the sites that need to host these audits.

The resulting audit duration…

Given that a Certification Body cannot expect their auditors to complete 11-hour day audits as a normal practice, it would be sensible to assume that this means that the number of days for audits will increase.

This means that for the smallest site, which does not need to do section 8 or 9 and doesn’t require any additional modules, will have an audit of 18 hours. 18 hours, based on an 8-hour audit day (with breaks would be 9 hours) would require 2 days full days and a third day of 2 hours to complete.

The result of the third day means that the cost of an audit is going to increase and the expenses incurred will be more, as the auditor will need to stay over an additional night in a hotel.

A mid-sized site, with about 100 employees, with a high risk or high care facility, is now going to need a 26-hour audit. Which will be 3 x 8-hour days plus 2 hours on a fourth day.

What are your thoughts on this?

You can probably tell we are not a fan of this change. We can totally appreciate that audit durations may need to increase, but there needs to be really robust justification for it and the implications of the increase need to be properly considered. You would expect there to be some sort of consultation about the change, due to the increase in the costs involved. We wonder how many of the Certification Bodies were consulted?

We love to know your thoughts, you never know the power of the people may have an impact!

13 Comments

  • Paul Robinson says:

    I’ve never agreed with the arbitrary duration calculator. As a site with three times as much storage area as production area we are now expected to have 18 hours for the audit. This means we should spend, in theory nine hours (if the presence in the factory is still meant to be 50% of the audit) looking at manufacturing with only two lines running. This gives an unfair balance of the intensity of the audit against smaller, simpler production units when compared to larger factories with more lines. I would rather have the BRC consider complexity and number of production lines then the size of the plant.

  • Avis Baden says:

    Far to long for simple flow products, i.e. frozen vegetables, the machinery is huge making the sites larger but it doesn’t take any longer to audit the factory or packing areas. If the audit is undertaken on the shop floor including the paperwork side and we don’t have to go through it all again in the office that is fine but it will just be duplication of what they have already seen and had explained in the live scenario, making our working days longer which means as most Technical staff are already over the time limits it will be excessive .

  • Andy KERRIDGE says:

    And there is a shortage of auditors!!!

  • THe cost of this change is more than meets the eye. With some sites already swamped with customer and retailer audits the quality team in even a small site is having to be increased in size adding more cost on the business with little gain in food safety. I do not see how this can be justified with BRC not explaining their reasoning behind this. The working time directive is an important piece of legislation that should remove the risk of abusing people’s working time, however, myself, like the majority of UK employees have waived this right. That factor alone should not encourage employers to negate their duty of care to employees. BRC of all bodies, should be squeaky clean in this respect due to their ethical stance but this makes a mockery of their own standard.

  • Rebecca says:

    The BRC audit is very paper based as it is, especially for small growing and packing sites where you can’t physically spend hours in the facility because there’s not much to see.. Due to childcare requirements etc many of us can’t stay past 6pm on site so dragging the audit out to 2 full days and a part day is going to be even more “do you have these exact words in this policy”.
    I understand why there’s minimum hours, but this needs more thought and consultation.

  • John Figgins says:

    I would like to highlight that there are a couple of mis-understandings within this article that may help and feel that some background might also assist.
    Issue 8 of the Standard has been audited for approximately 8 months (since 1st February 2019) and we have received a large amount of feedback. One of the repeated messages was that the audit was too short and some extra time was required to ensure a complete and consistent audit occurs.
    Regarding audit days – we totally agree that shorter audit days are better for both auditors and sites, however, the Standard is used in over 130 countries worldwide, and we have to recognised that in some countries the cultural norm is for longer working days. In the UK and Europe we wouldn’t expect an audit day to be longer than 8 hours, other than in exceptional situations. Our instruction to certification bodies is that they must not change the current rules regarding the length of an audit day. This has been in place for many years.
    Regarding high risk and high care this is again a mis-understanding of the text. If a site has multiple high risk areas with the same management systems it is not necessary to add 2 hours per high risk area. The auditor will not need that amount of time – it will be 2 hours added. However, if the site has a high risk area AND a high care area then the controls/management systems are likely to be significantly different and 2 hours for high risk and 2 hours for high care are likely to be needed.

    The calculation is partly based on numbers of employees but it is not only the number of employees in production – the article is incorrect in this assumption. The reason is that non-production staff have a role in product safety and often have an important input into the audit, for example, goods receipt, specification and supplier approval management, management of staff training, etc.

    Finally, I note there are several comments regarding small sites and simple production such as fresh produce. The audit duration calculator does explain the provisions for these sites, for example, there are specific provisions for very small sites and very well organised sites. Further guidance from fresh produce sites is also available in the specific Fresh Produce Guideline available on BRCGS Participate which is freely available to all certificated sites.

    Can I also highlight that it is the responsibility of the certification body to calculate the audit duration.

  • Tracy says:

    We all work hard – all year round – to ensure our factories maintain the expected Standards.
    To have further demands placed on us without proper thought and reasoning, contradicts all that the BRC Standard stands for (we would receive a few NCs if we rolled out similar thinking in our business!).
    Its outrageous that BRC can make changes like this, without proper consultation, and regulation of its actions.
    To disregard ethics and its own clauses seems a step beyond acceptable. Maybe people power should consider opening up communications with the Authorities who regulate BRC.
    A strong voice can always be heard.

  • Amy Brooks says:

    Our auditor struggled to even audit us for the MINIMUM amount of hours he could as we are such a small site. This will be interesting.
    I’m pleased my audit is 23rd March 2020. Hopefully they sort this out for the next one!

  • Amy Brooks says:

    Also, if Kassy has ‘misinterpreted the text’ then how do BRC think anyone else is going to interpret it? Maybe there should be better clarification taking in concerns people will naturally have provided around changes such as these rather than leaving it for us to interpret it?

  • David Wag says:

    I am not sure if the new time calculations will also relate to Agents & Brokers, but will be absolutely incensed if it does. The audit for our type of business is nearly entirely paper based, making it a very tedious and tiring experience. We are a small office only business of less than 30 permanent employees and yet we are already expected to have a 10 hour audit, which is ridiculous. An audit should be of reasonable duration for the type of business and level of detail required, and the overall duration should be determined by the auditor themselves. Last year our auditor insisted on taking the full time of 10 hours, which meant those of us involved didn’t get away until almost 7;00 pm (with a 50 mile drive home, this was not appreciated by myself!) and our Sales Director was waiting around, twiddling his fingers, just to attend the close-out meeting. He took it very well, but wanted to get to the Pub – it was Friday after all! Personally, i think the BRC need to lake a long, hard look at themselves and the whole thing needs rethinking and revamping, now that there is no British retail affiliation, and all the major retailers are undertaking their own audit programmes left, right and centre (which is the very thing the BRC standard was created to do away with). There is to much pressure on Technical Teams these days and all the additional audits and continually updating existing formats with more and more stringent requirements only increases this.. yes, there is a need for an accepted Global Standard, but that is not what we have at present and i for one and becoming more and more disillusioned with it all.
    it is no wonder that there is a shortage of auditors available and those that have been doing it for some time are dropping out. it is also no wander that there is a shortage of god, experienced Technical Staff in the Food Industry. they are being ground down and moving on.

    • Polly Day says:

      I totally agree with David – spot on with your comments. The auditor has an audit plan, everything is covered- what more can they audit?
      I have hosted many BRC audits – they are tiring and to be there for 10 hours is too much – when we are tired we become irritable and make mistakes (Auditors and Technical staff) is this really conducive to a good amicable outcome? I know a couple of BRC auditors who have just burnt out and moved away from the job.
      The pressure is immense for Technical staff and auditors alike – I wonder how long it can continue

  • Shabd says:

    Hello Everyone,
    I agree with all of the comments shared above, thank you to all who voiced their opinion. I am from a company in the US, and we too are accustomed to an 8 hour workday, although management is not always confined to just 8 hours! Indeed, we in the food safety & quality fields work tirelessly all year long to ensure all employees are trained and trained again, and that policies and programs are written and enforced to comply with our chosen certification standards. This increase in auditing hours will absolutely add cost to every audit, as already mentioned. Cost for the audit itself, cost for additional time that the auditor will spend in a hotel, on a rental car, on food & expenses and cost for companies to “host” the auditor, so coffee, lunches and snacks. This does not take into consideration the additional cost to employees working the audit, so child care/parental care/animal care and so on. I happen to live an hour away from the plant I work at, so I already add an additional 2 hours in commuting time, without additional time being added to the audits, so, for me, that now means that I would have to stay a few nights in a local hotel to accommodate this increase in audit time. Having come from an SQF environment prior to working in a BRC environment, I can say that while the auditing schemes are different, they aren’t so different that a company would have much difficulty switching to another auditing scheme. If there are reasonable justifications for this move by the BRC, then it should have been vetted out correctly, not simply launched without participant’s input and feedback. For those who suggested that more time was needed for their audits, I would ask why that wasn’t requested from your auditor at the time of your audit? If a company is going through the expense, time, effort and commitment of seeking BRC Certification to begin with, then they are already making the commitment to increased quality & food safety standards within their operations. BRC pushing an increase like this, is not only unreasonable, but uncaring as well. We should be treated like the professionals we are, and not “caged” into spending more time and money to accommodate the BRC’s whim of increased auditing times.

  • Carrie says:

    I take on board John Figgins’ comments and I think Amy Brooks’ point is very valid. We are expected to give clarity and justifications for our processes and procedures, why should BRCGS be any different? I can’t get past the feeling that BRCGS is now about making money for the mother company that has effectively ‘bought’ a global food standard (like me, are you all having a stream of ‘purchase this additional book to help with…not sure of how the changes affect your site? here is a course….). Doesn’t have the same feeling of impartiality any more. I understand that training is needed but the advertising (because that’s what it is) plays on how vulnerable you feel on whether you have the right information or not. Some sites may feel staff require greater detail regarding training and knowledge level but when you are bombarded, well it just feels like money making and not providing a service.
    We’ve just gone through our version 8 audit. We are a small site with very simple processes (1 HACCP plan) but we still had a full 16.5 hours of audit time over 2 very full days. Yes, every clause, sub-clause and line of the standard was assessed! We don’t take coffee breaks, we have those as we work and stopping for lunch is as much time as it takes to eats a sandwich and some fruit which in our case is about 10- 15 mins! Like Shabd, I also have at least an hours commute to and from work so, it makes for an exhausting experience. No wonder there is a shortage of auditors and technical people!
    The very people who established BRC in the first place are now insisting on their own audits in addition, so what is the point of BRCGS? I am completely perplexed at the current level of joined up thinking (or lack of it) to make the industry safer and give and maintain our customers’ confidence because as all technical bods will attest to, we are the gate keepers of food safety and quality but it’s a big load to carry. Are brains on ration……? (apologies for having my cynical hat on).

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