Update on BRC remote audits – 24th March 2020
GFSI publish updated and enforced position statement: https://mygfsi.com/news_updates/update-on-temporary-audit-measures-during-covid-19-pandemic
Essentially, what this says is that BRC carrying out remote audits is not compliance with their requirements and as such, GFSI will not recognise any remote audits or any certificates issued on this basis. Therefore, if you have had a BRC remote audit – this is null and void.
What GFSI are saying that should happen – is that your certificate can be extended for 6 months based on risk assessment. This also means that any remote audits that have been booked, should now be cancelled. However, there is no feedback from BRC on this position. Apparently remote audits are still going ahead tomorrow.
Any remote audits that happen will not be valid in GFSI’s eyes and (therefore you could say) are a waste of everyone’s time.
Please add your thoughts on this to the comments section of this article. We would like to get the power of the people, to get BRC to rethink their position and cancel the remote audits – in line with GFSIs instructions.
In this article, we’re going to cover how to complete a remote audit in compliance with BRC072 BRCGS Audits impacted by Covid-19.
Where the local government has imposed a travel ban, a remote audit will be completed, if:
- The site can complete and provide their certification body with a self assessment
- There is the ability of the site to allow the certification body to complete a remote audit
- An on-site audit can be completed within 6 months of the remote audit
The above can also be applied, where the site states that the audit cannot come on site, due to a justified company policy to restrict visitor access. In this case, the certification body must be able to review the policy, to ensure that it is justified.
This means, if your company creates a policy that stops visitors and contractors coming on site, you can ask for your audit to be carried out remotely. Your certification body must review the policy and determine if it is justified. Unfortunately, no guidance has been provided on what ‘justified’ means – so it’s likely that your certification body won’t be able to say your policy is unjustified.
So, let’s go through what you will need to do, if your audit is carried out remotely.
Your certification body will ask you to complete a self assessment, to the BRC Standard that you’re working to.
This needs to be on the BRC template, which you can find here:
- Food: https://www.brcgs.com/brcgs/food-safety/help-and-guidance/
- S&D: https://www.brcgs.com/brcgs/storage-and-distribution/help-and-guidance/
- Packaging: https://www.brcgs.com/brcgs/packaging/help-and-guidance/
- A&B: https://www.brcgs.com/brcgs/agents-and-brokers/help-and-guidance/
Your certification body will also be able to provide you with a copy.
The self assessment must completed prior to the remote audit and no more than one month in advance.
The self assessment must be a thorough audit and reference the documents that have been used. Copies of these documents must also be provided to the certification body.
Where non-conformances are raised during the self assessment, these must be closed out and evidence provided, prior to the remote audit.
The remote audit will be carried out on an agreed date. Unannounced sites, will also have an agreed date and will still receive an unannounced audit score.
The remote audit will be made up of two parts:
- Review of the self assessment (desktop exercise)
- A virtual audit of the practical aspects
Review of the self assessment
The self assessment must be provided to the certification body to review. The review must take place by the audit due date. Where this is not possible, it must be completed within one month of the audit due date and in this situation, the site will not get a non-conformance for the late audit. Sites must make sure that they submit their self assessment as soon as is possible, to give the certification body time to review within the month timescale.
The audit will be conducted as a typical audit, however where the auditor needs to go into processing and storage areas, they will do this through live video. The auditor will need to be able to speak to personnel in these areas. The typical opening and closing meetings will also take place.
Additional modules will be completed as required.
A GMP audit must take place within 6 months of the remote audit, where travel restrictions are lifted. The GMP audit will be unannounced, where the site is unannounced – and will take place within 2 months of the travel restriction being lifted.
Where a GMP audit cannot be completed within the 6 months period, BRC will be notified and another remote audit should be completed. A site cannot do more than 2 remote audits, without BRC approval.
As you would imagine the GMP audit will be very practical and BRC are going to issue a GMP audit template for certification bodies to use.
Where the audit has been carried out remotely, this will appear on your certificate.
Questions and answers
Can I refuse a remote audit?
Yes – but your certificate will expire and you will receive a major non-conformance on your next audit.
What if I don’t have live video capability?
Your certificate will expire, but you won’t receive a major non-conformance on your next audit.
If you have any other questions regarding remote audits, please add them to the comments box below and we’ll answer them for you.
Working from home
We have had a number of requests about eLearning courses, as people are obviously wanting to complete courses while they are working from home. Typically, we would suggest an in-house course where are a number of people from one company wanting to complete a course, as this is a more cost effective option. However, given the situation, we appreciate that this isn’t a viable option.
Therefore, to support you during this time, we have discounted our eLearning courses and distance learning eBooks by 40% so that they are in line with the cost per person, of an in-house course.
Coronavirus (COVID-19) resources: Coronavirus and the food industry
The war on Coronavirus #keeptheshelvesstocked
We have published an article on how we need to take a different approach, to ensure that the shelves stay stocked: https://techni-k.co.uk/uk-food-industry-war-on-coronavirus/
We've tagged this article as: BRC audit protocol
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