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.
Size of manufacturing facility
Less than 10,000m²
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 – email@example.com
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
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.
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.
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!
We've tagged this article as: BRC audit protocol
If you've enjoyed this post why not try these related articles…
BRC Service package fee – What do you think?
We look into the fees and how they’ve increased since 2014, to ask if you think what you’re paying is warranted?
BRC certification body – FIVE essential things you need to know
FIVE essential things you need to know about the processes that can have a massive impact on your audit.
Thousands of Food Techies all over the world read and trust our blog.
Join them and get our bi-weekly articles direct to your inbox - for free!