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Although we normally only focus on our part of the process when doing a BRC audit, there’s a lot more to it and there are a number of processes that your BRC certification body follow, which you need to be aware of.

In this article we’ll go through them, as they may have a massive impact on your site and affect your audit…

(1) audit expiry

If you have an announced audit, it’s your responsibility to make sure your audit is done before your audit window expiries. You can find the audit window on your certificate.

However, if you have an unannounced audit, then it’s your responsibility to instruct your BRC certification body to do the audit, but it’s the certification body’s responsibility to make sure it’s done before the audit window expires.

There has been an issue recently where a site had requested that an unannounced audit to be completed, but certification body didn’t schedule it and therefore the site missed their audit window.  If you don’t do your audit before your audit window expires, you will automatically get a major at your next audit.  This means that you will start your audit on a B grade. So, if you’re on an unannounced audit, keep a close eye on the date and don’t let it get too close to the expiry date, before you call the certification body and check to make sure they are coming.

(2) audit result

The auditor cannot tell you what audit score you’ve got at the closing meeting.  This is because a technical review will take place, before the number and grade of non-conformances can be confirmed. This is a really key point, as you may find that the number of non-conformances change and also the grade of the non-conformances may change.  So, there is potential for this to change the grade of your audit.

What this means, is that you have 28 days to close out your non-conformances, but during this time and even after your 28 days, you may be given more non-conformances to close out. There have been a number of issues around this, where sites have had non-conformances added from the technical review, but this either hasn’t been communicated to the site or it has been communicated very late.

Although it’s the responsibility of the BRC certification body, it’s in your interests to check with them regularly until they can confirm that the technical review has been completed and that they can confirm your audit grade.

(3) the report

The audit must always be provided to you in English.  Translations are allowed, but English must be provided with the translation. Don’t let your BRC certification body or your suppliers tell you that they can’t provide an audit report in English, as this is not the case.

(4) exclusions from scope

We’ve talked a lot about the logo recently, and I’ve been updating the post I did, to keep it up to date.  BRC have now said that the new logo must be used by sites by Feb 2020.  This doesn’t give you much time to get anything that you’ve got to the logo on, switched over.  I’m especially concerned about vehicles with logos on, so I’ve asked BRC if this date still stands for expensive changes like this; but unfortunately, they have chosen not to reply.

In all of the standards, the BRC are very clear that if you exclude anything from the scope of your audit, you cannot use the logo.  However, they have published one document, which is shown here, which states that this doesn’t apply to traded products excluded from scope.  I think this is a mistake, but again BRC have chosen not to reply to my query on this.  My suggestion would be to err on the side of caution and not use the logo if you exclude traded products from your scope. I would imagine, behind the scenes BRC are updating this document – which I imagine will be published on BRC Participate.  If anyone sees that the document has been re-issued, please can you let me know so I can update this article?

(5) re-audits

If you want to improve your audit score, or if you need to complete an audit following a failed audit, you must have this audit with your current certification body.  If you don’t want to use your current certification body, you have to apply to your certification body, who will request this through the formal concession process.  If you don’t get formal approval of this concession in writing, then any audit that you do with another certification body will not be accepted by BRC.

This means, that if you fall out with your certification body for any reason, and you want to re-do your audit, you need them to agree that you can move to another certification body. You can see that there’s a conflict of interest here, so I would recommend if you find yourself in this position that you make a formal request directly to BRC and not just to your certification body.

To do this, send the details to BRC at enquiries@brcgs.com and make sure you include:

  • Site details – name, address, site code, etc
  • Site contact details
  • Certification body details
  • Details of the complaint – accompanied by any objective evidence available

As always, if there are any other points you’ve learned about the BRC certification body audit process that you think others will benefit from knowing, please add them to this article using the reply box below.

12 Comments

  • Sharon Tomlinson says:

    Great info and advice. Thank you.
    I thing I have come across when choosing a CB is that there is a scale of credibility for CB and we have been asked by our customers to ensure we have a CB listed as 5 with the BRC. I cant remember where this list is , I hope you know what i mean and can elaborate for your readers.
    Similarly an issue I came across with our suppliers. Some have hygiene standard such as EN 15593 & Nch 2861 HACCP which are great hygiene standards. We initially though these HACCP /hygiene certificates were enough when choosing a supplier, BUT they are NOT GFSI (in BRC eyes) and therefore we have had to preform other evaluations of these suppliers on top of their certification verification i.e. questionnaires, audits etc. all of which annoys those supplies as they believe there certification is enough. In some cases it is but as it has not yest been evaluated & added to the list by the BRC we have to ask for more information.

    • Alan W says:

      If you look on the BRC directory it will allow you to search for an auditing body by the star rating they hold. One side of the search engine is for certified sites and the other is for certification bodies. I believe the reason that the HACCP/Hygiene certification is not recognised is that it does not cover the full range of a GFSI certification such as traceability /recall / internal audits.

    • Alan Gibson says:

      Hi,
      I am a BRC auditor, In answer to Sharon Tomlinson’s post I can assist in pointing people in the direction of the BRC Certification Bodies star rating system, which is easy to find when you know what you are looking for… call up the BRC Directory web-site at https://brcdirectory.co.uk/ then look on the right hand side of the web-page beneath the ‘FIND A BRCGS CERTIFICATION BODY’ header you can search the list of CB’s by selecting the BRC Rating – 1 star or higher, 2 star or higher….up to 5 star. Also you can search for ‘unrated’ and ‘suspended’. Currently there are 4 pages of ‘unrated’ CBs and 1 ‘suspended’.
      On the second point Sharon makes about BRC/GFSI-benchmarked standards, there is sympathy here. The BRC have really tightened-up this section of the standard (BRC section 3.5.1.2), which now leaves no leeway to satisfy yourself that a suppliers technical standards are suitable if not BRC/GFSI, other than audit (with caveats) or questionnaire for low risk, with a risk-based justification.

      • Kassy Marsh says:

        Hi,
        Thank you for replying to Sharon, that’s very kind of you.
        On the non GFSI certificate point, if the audit covers food safety, HACCP review, GMP and traceability it should suffice as an acceptable audit. As long as they have the audit report (to prove it covers these things) and the close out of any corrective actions. Sharon – does it cover this?
        Thanks
        Kassy

      • Sharon Tomlinson says:

        Thanks Alan,
        I work in a food packaging company. I have just read the relevant section for our industry (3.7.2) V6 and I can see that this now elaborates on what to ask for if the supplier is not GFSI certified. i.e. based on risk a questionnaire can be used with scope including product safety, traceability, HARA, GMP. Its the “initial approval” that worries me, although it does look like (in 3.7.3) that approval by questionnaire continues to be acceptable if as in 3.7.5 traceability is proven every initially & every 3 years. I think this is more prescriptive than before and is an improvement.

        • Kassy Marsh says:

          Hi Sharon
          The initial approval means that’s it’s not final forever as such. You could risk assess a supplier as low this year, and then carry out supplier monitoring on them and then so, when you do next years review of the risk assessment and put their monitoring data in, they then may become not low risk. But if they stay low risk that’s fine too.
          Does that make sense? You’re right this has been clarified in issue 6.
          Kassy

  • PHILIP M. NGUGI says:

    This and other articles are very helpful and informative. I have been receiving such important articles and I really appreciate the analytical approach from the author.

  • Trevor Larson says:

    I would accept non-GFSI certified suppliers under the second bullet point of Clause 3.5.1.2 of the Standard.

    • Kassy Marsh says:

      I agree Trevor, as long as it covers food safety, GMP, HACCP review and traceability. 🙂

      • Sharon Tomlinson says:

        Thanks Kassy,
        I work in food packaging. It sounds like our standard has not been as prescriptive as the Food version and it was not obvious what areas we needed to question for a non GFSI company. I think V6 helps

    • Sharon Tomlinson says:

      Thanks Trevor
      I work in food packaging. It sounds like our standard has not been as prescriptive as the Food version and it was not obvious what areas we needed to question for a non GFSI company. I think V6 helps

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