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:

  1. The site can complete and provide their certification body with a self assessment
  2. There is the ability of the site to allow the certification body to complete a remote audit
  3. 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.

Self-assessment

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:

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.

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:

  1. Review of the self assessment (desktop exercise)
  2. 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.

Virtual audit

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.

GMP audit

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.

Certification

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 CoronavirusFood Industry and 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/

Have your say…

9 thoughts on “BRC remote audits during the coronavirus pandemic

  1. If the site can not conduct a live virtual video audit due to WIFI capabilities then would the site receive an updated certificate?

    1. Hi Stuart
      No, your certificate would expire, but you would not receive a major NCN on your next audit.
      Thanks
      Kassy

  2. My initial reaction is that this is both un-realistic and not supportive at all to the food industry.
    1 – BRC are assuming they will have sufficient auditors of the right food category skill to be able to carry out these audits and assessments
    2 – What training with the auditors have received to undertake this different approach? Can we see this training?
    3 – Each factory over all departments WILL have staff off due to the virus. Those remaining will be focusing on keeping the factory running and supplying food. To then be distracted with a new format audit is unreasonable added pressure on the remaining colleagues.
    4 – At this unprecedented time, just what is the justified reason for this approach when BRC had previously announced suspension of audits?
    5 – It will not highlight unscrupulous suppliers because they will not take part! But how many such suppliers does BRC find through their audits anyway?

    VERY disappointed by this announcement.

    1. BRC is not a legal requirement but a standard that has come to be expected. My site were due their Soil Association audit on 30th March which is completed to meet a legal standard but even this is now going to be delayed.
      I like the idea of the self certification and remote audit in principle but the timelines at the moment are not realistic. Suspension until a set date would be a better start as the industry will need time to get back on its feet.

    2. 100% with this view. Many food businesses are struggling to meet important orders that will feed the population during these unprecedented times and businesses need to be allowed to get on with this crucial work. Suspend the requirement for 6 months

  3. Our audit was due 23/24th March. We are not allowing visitors on site and are undertaking a remote audit.
    We are a very small business. Our HACCP team leader is an external consultant who is not now allowed on site. We have 3 staff already self isolating.
    The self assessment document is very long as is going to be quite involved to fill out. We will then have a day taken over to complete the remote audit. During this entire time frame, schools are to be closed, staff will have to stay at home to look after children. Additional people may be self isolating. As Carol has stated, we could and should be focusing our attention elsewhere at the moment.
    It does not feel as though this is the right solution.

  4. we are also opting for self assessment, I work for a fairly large organisation so have the technical capabilities to do this. However to put it in perspective we had 75 people go home from production yesterday for various reasons so really struggling.
    I have another question to ask? I have been asked to create a protocol for controls around a deep clean if there has been someone in the site that we know has the virus or likely to have been contagious. I have consulted with our cleaning company and they are suggesting 35% hydrogen peroxide dry vapour in the production areas. I know that this is what is used in biological safety cabinets where potentially hazardous micro-organisms are handled and require a clean down.
    Does anyone have any experience with this chemical and have been developing something similar for their company?

  5. In line with GFSI announcement it seem ridiculous for BRC to continue with remote audits, what is the point? surely a risk assessment to ensure your site is still operating the same as the last audit with should suffice. it seems to me to be another money making excersise for them. Surely in this critical times just extend the expiring date by 6 months to get companies through this time???

  6. Remote audits, in my eyes, are a pointless endeavour – and I agree with the GFSI on this.

    Some retailers are pressing ahead with non-critical audits but done remotely as a desktop/remote audits. It seems counterproductive when the nation needs food, when the workers need protecting, that we waste time and resources on remote audits which will give very little to the businesses.

    The BRC pressing on with remote audits was a stupid move. Luckily, they have back-tracked: https://www.brcgs.com/about/news/2020/brcgs-announces-revised-guidance-for-sites-affected-by-covid-19/

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