Audit protocol

This article explains the key points of the audit protocol section of the BRCGS standards.

This article is written to meet the following sections of the Standards:

BRCGS Food Safety Issue 8Part III – audit protocol
BRCGS Packaging Issue 6Part III – audit protocol
BRCGS Agents & Brokers Issue 2Part III – audit protocol
BRCGS Storage & Distribution Issue 4Part III – audit protocol
FSSC22000 Version 5.1n/a
IFS Food Version 7n/a
SQF Edition 9n/a

Are you a technical manager or consultant?

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All the practical information you need to know is in this mini training – managing your certification standard. This course is a definite must for technical managers and consultants, you’ll be amazed at what you learn.

Choosing an audit option.

There are 3 main options for BRCGS audit:

  1. Announced audit.
  2. Unannounced audit.
  3. Blended audit.

Let’s look at the three audit options…

1. Announced audit

Announced audits, are where the audit date(s) are planned and agreed in advance. However, to comply with GFSI, one audit must also be unannounced every three years.

This rule doesn’t apply to Agents & Brokers.

2. Unannounced audit

There is no change to the current unannounced audit protocol.

When will my unannounced audit not be?

  • On a weekend!
  • On any of your nominated non-audit days.
  • When the site is not operating, such as bank holidays, days the site is closed, during out of season periods, or when production is not running.

What is a ‘nominated non-audit’ day?

You can nominate up to 10 dates when you don’t want the audit to happen. If you’re a C or D grade site, you’re only allowed to nominate up to 5 dates. Where your site is seasonal, the non-audit days will be prorated based on 10 days for a 4 month window.

Your nominated days do not need to include any dates when the site is not operating (as detailed above). But you must notify your Certification Body of the dates when the site is not operating, so they know.

There are rules about what can be classed as an acceptable nominated non-audit date. The following table shows acceptable and unacceptable non-audit dates.

AcceptableNot acceptable
Customer visitsStaff holidays

Booking dates with no valid reason, for example; booking one particular day per week, over 10 weeks.

When you book the non-audit dates you must provide a valid reason for each one.

Pre-organisation of the unannounced audit

Your Certification Body will ask you to provide information in readiness for the audit. If you want to request information from the Certification Body, such as shoe, coat size or food preferences then you must do this in advance.

On the day of the audit

You must ask the auditor to prove who they are. You are also within your rights to call the Certification Body to confirm their identity before you let them on site. However, this should not be used as a stalling tactic, as the auditor needs to be in the operational area within 30 minutes of arriving at site.

Changing Certification Body

You can change Certification Body, but if you decide to do so – you will need to let your new Certification Body know:

  • When your last unannounced audit was (if any)
  • If your next audit has been organised as unannounced

If you’ve already agreed with your Certification Body that your next audit is going to be an unannounced, you need to make sure that they know that it’s cancelled because you’re switching Certification Body. If you don’t, they may still turn up and you will most likely be charged for it.

Also, if you don’t have your unannounced audit within the 3 year period because you’ve moved Certification Body and not told them you need an unannounced audit, or not given them enough time to organise it – your certificate may lapse and you will be uncertified.

Watch outs

Your unannounced audit cannot take place after your audit due date. So, if it’s getting close to that date and your unannounced audit hasn’t happened, you should worry! You’ll need to contact your Certification Body to make sure that something hasn’t gone wrong and it’s been forgotten.

If you don’t allow an announced audit to go ahead when the auditor arrives, your certificate will be suspended. The only exception to this, is in case of emergency. This is at the discretion of the Certification Body and if the timings mean that the audit due date lapses, a derogation (approval to deviate) from BRCGS would also be required.

If the site is not operational during the unannounced audit, then the audit cannot be completed. In this instance, another unannounced audit will need to organised. As before, you will be at risk of your certificate being suspended or lapsing if it can’t be done before the due date.

3. Blended audit

A blended audit is a blend of an on-site audit and a remote audit. This type of audit is GFSI recognised. BRCGS have published a position statement that explains this option: BRCGS080 Procedure for Blended Audits-Remote Auditing using ICT.

On-site audit
An on-site audit looks at all the practical aspects of the operation. This part of the audit is carried out with the auditor at site, so they can look around the site.

Remote audit
The remote audit will look at all the documentation aspects of the operation. This part of the audit is carried out using IT systems, so that the auditor doesn’t need to be on site. The remote audit cannot be more than 50% of the allocated time for the overall audit.

A blended audit is only available for BRCGS Food Safety, BRCGS Packaging and BRCGS Storage & Distribution audits. Blended audits for BRCGS Agents and Brokers can be 100% remote, if the risk assessment confirms that a practical audit isn’t needed.

You CAN’T have a blended audit if:

  • You’ve not already got a BRCGS certificate.
  • You’re on the unannounced audit option.
  • Your CB says so (based on their risk assessment).

You CAN do a blended audit if:

  • It’s a re-certification audit.
  • You’re on the announced audit option.
  • No matter what grade your current certificate is.

Blended audit rules:

  • A blended audit is not compulsory, so you have to choose to do it.
  • Your CB must complete a risk assessment to say a blended audit is suitable for you.
  • The remote part of the audit must not be more than 50% of the overall audit.
  • The auditor must not take screen shots during the remote audit of personnel and must get permission for any other screen shots.
  • The remote audit is done first.
  • There must be no more than 28 days between the remote audit and the on-site audit.

Selecting a certification body.

You can use the following directories to find a suitable certification body:

BRCGS Directory: https://directory.brcgs.com/

IFS Database: https://www.ifs-certification.com/index.php/en/industry-en/certification-bodies-en

SQF certification body list: https://www.sqfi.com/how-to-get-certified/find-a-certification-body/certification-bodies-list/

FSSC 22000 certification bodies: https://www.fssc22000.com/partners/certification-bodies/

Audit duraction

Your certification body will ask you for relevant infomration to work out how long your audit needs to be, using the BRCGS calculator documents.

Audit calculators for each standard can be found on the relevant website as follows:

BRCGS Food Safety Issue 8BRCGS Packaging Issue 6BRCGS Agents & Brokers Issue 2BRCGS Storage & Distribution Issue 4
F806: Audit Duration Calculator (.doc format)P606 – Calculating Audit Duration (.pdf format)AB305: Audit Duration Calculator (.pdf format)SD402: Audit Duration Calculator (.pdf format)

What to do, if you don’t agree with a non-conformance raised during an audit

It can be difficult to know what you can do when you don’t agree with a non-conformance at audit, so here’s some guidance…

Auditor etiquette

Auditors should always make you aware of what they’re finding during the audit. Non-conformances should not be a surprise to you at the closing meeting. That being said, it does still happen so we’ll cover what to do in this event.

In the opening meeting for the audit, you should request that the auditor makes you aware of anything they find – as they do the audit. Agreeing these ground rules up front at the beginning, will help to reduce any issues at the closing meeting and will help create an open working relationship with the auditor.

Ask

During the audit you’ll most likely be aware when the auditor sees something, especially during the factory tour. Don’t be afraid to question the auditor about what they’re thinking. Asking “what are you thinking?” will help to open up a dialogue between you and will help to make sure you’re both on the same page.

Disagreements

If the auditor raises an issue with you that you don’t agree with there are a number of things you should do…

  • How you behave in this situation is really important. Don’t get upset. Getting upset, cross or annoyed will only cause friction and you need to work with the auditor to come to a resolution you both agree on. If you’re not speaking to each other, this won’t happen.
  • Calmly, repeat back to the auditor what you think they see as the non-conformance and ask them to confirm to you, that you’ve understood. You could say something like. “Ok, can I just check with you, that I’ve understood what the non-conformance is?” Then explain it in your own words and then say… “Is that right? Have I understood correctly?”
  • Make sure that you are empathetic to the auditors point of view. You really need to try and see things from their perspective – if you don’t do this, you’ll not be able to work together to resolve it. Remember, the auditor is not doing this to be a pain, they’re just doing their job – just like you’re just trying to do your job. You could say something like “I can see what your saying and I understand where you’re coming from.”
  • You can ask the auditor to show you the specific part of the clause in the Standard, which they don’t think you’re complying with. This will help to resolve the issue, as it may be obvious from the clause whether you are compliant or not. Remember to keep calm – no matter what the outcome. Remember, you and the auditor are working together (not against each other) to come to a resolution. If looking at the clause shows you’re right, don’t blag. And, if looking at the clause shows the auditor is right, accept it graciously and say, something like “Yes, you are totally right, I agree.”
  • If however, looking at the clause doesn’t provide a resolution, then it’s up to you to put your point of view across in a professional manner. This is not an argument and your point of view must only be based on facts, which are provided in the form of evidence.
  • If you’re starting to feel stressed in this situation, or you think your behaviour is becoming unprofessional, then excuse yourself from the room. Ask the auditor if they’d like a drink and say you’ll go make one, or excuse yourself to go to the bathroom. Do not leave them for a long period of time – five minutes maximum. If you need longer than that, ask someone else to keep the auditor company for you.
  • If when you’ve presented your evidence in a professional manner, you and the auditor still can’t come to a resolution – then you need to let them know you don’t agree. Ask them at this point, if there’s anything you can do or provide that will help to resolve the issue. If there is, get someone else to gather this evidence for you and carry on with the audit. If the auditor can’t provide you with any way of resolving it, then explain in a professional manner that you don’t agree and that you will raise it in the closing meeting. At this point, you need to put the issue to the back of your mind and carry on. Wipe the slate clean and don’t hold a grudge.

Closing meeting

We’ll cover two situations:

  1. Challenging non-conformances you’re aware of.
  2. Challenging non-conformances you’re not aware of.

Challenging non-conformances you’re aware of

The first thing to do when the auditor gets to the non-conformance you don’t agree with, is to make sure you and the auditor agree that you’ve provided all the evidence you can to remove the non-conformance. If you’ve not provided the evidence, do it now.

If you have provided the evidence, you need to both agree to disagree. Tell the auditor in a professional manner that you’ll be appealing the non-conformance they have raised. Every certification body has an appeals procedure. Ask the auditor to provide this to you, so you can follow it.

When it comes to signing the audit report, make sure that the person signing, writes on it that they don’t agree with the non-conformance. If you don’t, you’re signing to accept the non-conformance, that’s the point of signing.  Also photocopy or scan the signed audit report so you can refer to it during your appeal.

Challenging non-conformances you’re not aware of

As we said earlier, it’s unprofessional of the auditor if they do this. However, if it happens, you need to keep calm and be professional. Two wrong’s don’t make a right. First, explain that you haven’t been made aware of this non-conformance. Ask to pause the closing meeting and then follow the steps above by providing the evidence now.

If you need to, politely excuse yourself and the rest of the management team out of the room, so that you can discuss the NCN before going back into see the auditor. Do not argue about it, in front of the auditor.

If you can’t come to a resolution with the auditor, again make sure you say this clearly but in a professional manner and ask for the appeals procedure. Remember to document this on the audit report before signing it. And, take a copy of the signed audit report.

Appealing non conformances

As the certification bodies are all accredited, they all need an appeals procedure, which they should be able to provide you.  The standard also provides you with details about the appeal process.

You need to follow the appeals process given to you by your certification body.  Make sure that you provide as much background and detail as you can.  Everything you want to say has to be written down, as the appeal will only be based on the written information provided.  Do not leave any details out.  Keep all written information very factual and provide as much evidence as you can. Also, make sure that you keep a copy of all the communications that you have with the certification body, in case you need to refer to it later.

When to appeal

When appealing non conformances, you can appeal at two points in the process…

  • Within the 28 days that you have to complete the close out of the non-conformances. If you do this, you need to get the appeal in as fast as possible, because the certification body has up to 30 days in theory to complete the appeal.

For example, let’s imagine that you appeal on day 1 and the certification body takes 30 days to complete the appeal.  That would take you over the 28 days. In this instance you would need to submit all of your evidence for all of the other non-conformances within the 28 days. The certification body has until 42 days from the audit, to be able to close out the audit and upload it to the BRC portal. Therefore, the time between 28 days and 42 days would be used to resolve the appeal and if necessary (if it wasn’t upheld) close out the non-conformance.

You need to make sure that you submit the appeal though, ideally on day one.  Leaving it until the last minute will put unnecessary pressure on the certification body, which will cause friction and therefore, in theory they may be less likely to give your appeal due consideration.

  • You can appeal after you’ve got your certification, but you only have 28 days from the issue of your certification. Again, the certification body has up to 30 days to complete the appeal, so you can see that you need to submit it as soon as you can.

Non-conformance grading

Fundamental

A major non-compliance against fundamental section can result in non-certification. The fundamental sections of the standard are those that are deemed by BRCGS to be critical.

BRCGS fundamental sections are shown below.

BRCGS Food Safety Issue 8BRCGS Packaging Issue 6BRCGS Agents & Brokers Issue 2BRCGS Storage & Distribution Issue 4
Senior management commitment and continual improvement (1.1)

The food safety plan – HACCP (2)

Internal audits (3.4)

Management of suppliers of raw materials and packaging (3.5.1)

Corrective and preventive actions (3.7)

Traceability (3.9)

Layout, product flow and segregation (4.3)

Housekeeping and hygiene (4.11)

Management of allergens (5.3)

Control of operations (6.1)

Labelling and pack control (6.2)

Training: raw material handling, preparation, processing, packing and storage areas (7.1)

Senior management commitment and continual improvement (1.1)

Hazard analysis and risk assessment (2.2)

Specifications (3.4)

Internal audits (3.5)

Corrective and preventive actions (3.6)

Traceability (3.11)

Housekeeping and cleaning (4.8)

Process control (5.4)

Labelling and pack control (6.2)

Training and competence (6.1)

NoneNone

Keeping up-to-date with certification.

At Techni-K we check the position statements for you and provide you with all the information you need.

Position statements can also be found on the relevant scheme website:

BRCGS Food Safety Issue 8BRCGS Packaging Issue 6BRCGS Agents & Brokers Issue 2BRCGS Storage & Distribution Issue 4
Food Safety Help and GuidancePackaging Materials Issue 6 GuidanceAgents and Brokers Certification HelpStorage and Distribution Certification help
Managing your Certification Standards eLearning

Have your say…

59 thoughts on “BRCGS Part III – audit protocol

  1. Very informative. I didn’t actually know about the appeals process, hopefully it will never be needed but useful to know that is is there. I only once had a disagreement with an auditor about the order in which hands should be washed and PPE put on, but the TPPS standard clashed with the supplementary information and it was such a minor point at our approval audit I eventually just accepted the NC.

  2. Really interesting examples. Hopefully that will help give sites the confidence to challenge and, in turn, improve the system.

  3. I think you “nailed it” there is not much left to be said. I always encouraged my customers to feel comfortable challenging my findings and to discuss any concerns they have before escalating it to the “appeal level”.
    The secret is clarity and objectivity so: state the requirement as per the clause, describe what was observed and contrast it against the requirement, then grade the non-conformance.
    The more serious the non-conformance use audit trails to provide solid evidence that the grade ( e.g Major vs minor ) is warranted. One certainly should not double-dip ( assign the same NCR twice), audit against the guidance document or audit based on personal opinion or preference. Similarly, remove the stress the audit should be about making your system better not just getting a “cert”.

  4. I found this topic interesting and well covered. I think there are times when auditees might like to disagree with a statement but don’t wan’t to because they think it will make things worse. or the auditor will find more NC’s. I have challenged a NC and it wasn’t up-held by the auditor at the time, but by the person who checks the audit later on. They telephoned me to tell me it had been removed from the NC list.. Result!

  5. I successfully appealed against 3 of the 7 minor non-conformances raised by an EU auditor who was flown in to audit us. Ist was that HACCP applied to the functionality of a tray, 2nd was a suppliers scope didn’t cover the wording rPET eventhough it contains the word PET which covers both Apet & rPET. 3rd was a supplier who is ISO9000 certified hasn’t got a HACCP system which is not required! All 3 were thrown out so we retained the AA certification.

  6. 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.

  7. 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 .

  8. 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.

  9. 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.

  10. 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.

  11. 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.

  12. 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!

  13. 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?

  14. 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.

    1. 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

  15. 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.

  16. 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).

  17. The changes occurring suggest that pencil pushers with limited experience of working for manufacturing sites and being auditors are now making decisions. Audits are intended to be a sampling exercise and the previous 1.5 days standard audit duration gave ample time for this, and made audits more sensible (as opposed to being a royal pain in the neck causing much business disruption).
    The comments by John Figgins show a lack of background knowledge and experience in The Standard and duration guidelines, since previous literature stated on durations, they were based on numbers working in the manufacturing facility (if this changed it should have been made clear surely?). Looking at his LinkedIn profile confirmed this is case (studied chemistry at a polytechnic then worked in “science” and “chemistry” roles before joining BRC).
    To elaborate further upon the point:
    “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”
    The statement is not thought through at all.
    Let’s consider a multi-site operation where audits are carried out on a per site basis, against a one-site business: for the multi-site, a number of functions such as specifications, purchasing, sales and supply chain may be centralised meaning a shorter duration based on this fact. Does this make sense?
    Some sites may have large training team to promote compliance and some sites may have nobody directly working as trainers – should the former be subjected to increased durations for expending a greater amount of resource on promoting food safety?
    Kassy’s interpretation of the duration regarding risk areas was as the document reads – because the writers are not able to make clear information perhaps the document should be reviewed by somebody new and the document updated?
    Indeed, in appendix 1 of version 4 of F806, the position statement states in bullet three “HACCAP” instead of HACCP. Perhaps a typo, but based on the other inappropriate information/ decisions and now requirements, probably this section was updated by the pencil pushers.
    Where will this end, one month audits? The dissatisfaction expressed by a number on this page show a general feeling of discontentment which should be addressed. Costs and fees for additional services few want should not be forced upon those now operating the BRC Standard for Food Safety. Stop this nonsense BRC and revert to the initial philosophies or there may well be an uprising from the industry and retailers will more regularly authorise alternative standards, and manufacturing sites will shift.
    Also as a side note it is agreed about additional audits from retailers – they should just attend pre or first productions of important or significantly different products to oversee safety and quality.

  18. There is no point in having a blended audit, if a site can manage the on site factory bit managing the documentation bit on site should not be an issue.

    1. Agree! It feels like a muddle is being created here when it ought to be straight forward – remote in total or on site in total. Simple. Yet again it shows how BRCGS is out of touch with the increasing pressure that sites are under just keeping going and are not helping the situation. Few factories, and I dare say NONE who received these updates, are out to do anything wrong deliberately so they need to support us, not add to the immense difficulties.

  19. Agree that the blended is not really adding anything, if can do physical visit, why not do all. BUT the blended is recognised by GFSI so BRCGS probably have to offer it, even if no-one takes them up on it. I think the finger should be pointed instead at GFSI’s lack of flexibility, rather than BRCGS – in this case.

  20. First of all, GFSI should have allowed remote auditing during a pandemic.
    But, with the options on offer then a blended audit option is useful for sites which can manage an auditor (distancing etc) in production but don’t have meeting room space to host an auditor safely (like us). However, this option is useless if you have to spend 50% of your time in production. If you’re a very small site (but not small enough for reduced time!) then its impossible to ring out 1.25 days of looking at production.

    Everyone is going to have to contact customers to see if they need BRC to be GFSI compliant this year before they can make a decision. This is really unfair on sites who are trying to protect their staff and their business.

    NSF aren’t offering blended audits, they haven’t worked out how to do it so its not an option.

    NSF also told me that a large proportion of sites are opting for the remote option without any queries about GFSI. I’m not sure this means sites have no clue about GFSI or their customers don’t need the benchmarking.

  21. As I understand it, the option is only available for those who have an announced audit. It’s the unannounced audits that can present the most problems to sites, when someone turns up and wants access. In terms of risk assessing visitors and managing the auditor in units that are already challenged daily in working to a new H&S protocol. We’ve opted for unannounced for the next BRC audit as that is what we have done historically. Reducing the time that the auditor was on site for these would be beneficial. We have had an unannounced retail audit and an announced retail audit during the pandemic and within the last 4 months. Both auditors were great in wanting to assist the factory teams in working safely.

  22. Kassy & team,
    I can’t thank you enough for posting this topic. It has been a nightmare for us going through this year certification with BRCGS. I meant to comment on your post weeks ago, but we’ve been super occupied with our CB. 4 of our facilities would able to get our certs. extended until March, April next year. We’ve repeatedly told the CB & the auditor that our season will end in mid-Oct this year & won’t start up again until next year June. We received no comments from them about this since Aug.
    Now, come to pick our options for the full/normal audit.
    1. We cannot pick the On-site audit option because the CB can’t locate the local auditors for us. Plus, due to the number of COVID cases in California, our cooperate restricted visitors to our facilities as well.
    2. We can’t pick the Remote option either because it’s not GFSI approved/recognized. Plus, as of this afternoon, the CB still couldn’t locate the auditors for us for next week audit.
    3. We requested for the Blended audit, but we won’t have production until June next year. This means our certs. will expire before the 2nd part (on-site) occurs.
    Fun right? We know the CB has been trying to help, but as for now, we don’t know what to do because they don’t know what to do either. We requested them to provide us the Letter of Intent to justify why we can’t have the audit in time. Let’s wait & see what they have to offer tomorrow.

    Will keep you posted!

    Regards,
    HT

  23. From the information given above then, if our certification body has not contacted us within three months of our last audit then the next audit will be announced? From what you’ve outlined above it sounds as though no audits next year can be unannounced for any audit prior to August and provided certification bodies start contacting their clients this month since the guidance has only just been published. Is that how you would understand it?

    1. Hi Paul.

      As from February 2021, after each audit your certification body will let you know within 3 months whether it will be announced or unannounced.

      Assuming that the site gets a grade that is above a C, then in general this will start happening from 1 October 2021 (assuming your announced audit was on 1 February 2021 and you were notified within 3 months that the next one would be unannounced).

  24. And the BRC money making scheme roles on. Over the last 2 editions money has been drained from sites to auditors, trainers and labs. All from the pockets of sites while the BRC includes more and more non food safety items. What will be the night item used to shill sites?

  25. Covid-related social distancing measures in place will not make this easy, with more staff working from home and meeting rooms allowing for social distancing to be booked well in advance!

  26. What if the quality manager or other key staff are on holiday? Holidays are not acceptable NON AUDIT DAYS We all know there is not supposed to be Management Representative now, and the deputy should be able to cover but as Laura has said above, people are working from home, some staff are only part time anyway and it could be their non working day. The systems work without the Quality Manager BUT do staff understand the questions posed at audit and know what to present to the auditor? Understanding the Standard and its interpretation is a skill. Staff do follow procedure but do not realize which clause that actually addresses and could be baffled by what the auditor is asking if the key staff are not present. Holidays MUST be included as non audit days..

  27. Our company worked well enough without BRC, this makes us think that we should just forget about the whole thing and go back to how we were. Life is difficult enough at the moment, this is a totally inappropriate time to bring this into force!

  28. Give us a break, totally inappropriate time to be even thinking about this sort of a change. Lives are disrupted enough at the moment without the added pressure of an unannounced audit

  29. the ‘re audit due date’ is a range of about 1 month on my certificate (and I assume for others too) so do we have to assume its 4 months from the start of the range? which means it could be 5 months realistically from when the audit normally/previously took place.

    1. Hi Chris,

      It would be 4 months from the end of the range, not the start. The window is 4 months, so if your re-audit due date is 23 September 2022, then the unannounced window would be from 23 May 2022 to 23 September 2022.

      Before too long your certificate will look a little different with just 1 re-audit due date, and if the audit is in an announced year then the audit must take place in the 28 days prior to the re-audit due date and if in an unannounced year it will be 4 months prior to the re-audit due date.

  30. Does the re-audit due date get moved forward for the next year if the unannounced audit is completed earlier within the 4 month period. So if the re-audit due date is 11 Nov 2022 and the announced audit happens 28 Sept 2022 does the following year’s due date get moved up to Sept or will it still be in Nov?

    1. Hi Emily,

      Assuming you get a grade B+ or above on the unannounced year, you will maintain your re-audit due date of 11 November.

      The way it works is that if you go within your window, then following a successful audit your re-audit due date is 12 months from the previous re-audit due date (or 6 months if less than a B) and then your window is based on either 28 days or 4 months depending on which year in the cycle you are in.

  31. We process Salmon. So what is to happen if the tender for whatever reason doesn’t arrive and we don’t have fish to process on this unannounced audit date? Does this auditor stick around for a few days waiting for fish like the rest of us?

  32. I think all audits should be unannounced for them to be a true audit. To be a true challenge of how a business operates on any given day, a planned event isn’t useful as it becomes a staged event. Don’t get me wrong, as an interim I’ve had countless unannounced audits from BRC & supermarkets alike so I know they’re not fun… but there’s nothing like getting a AA*!

  33. For on-site verification under blended audit, is it a mandatory that the auditor has to be a BRC-certified auditor or they can be just GMP & HACCP auditor who will receive guidance from the lead auditor (BRC-certified) online?

  34. I really cannot understand how this is going to work for small site where i work where there are less than 25 people. We have small amounts of staff, which will make this different. I can’t even imagine how this would affect smaller business of say 10 employees.

    Additionally, with all the COVID-19 implications occuring at present this is a totally inappropriate time for BRCGS to even be considering this chnage. It would be better to delay this another year when we are hopefully in a better position in the country to know where we are with COVID. Agree unannounced audits do give a better indication of how a site operates.

    I’m expect they will be launching BRCGS Food Safety Issue 9 soemtime next year as well on top of this change, at the moment a bit of common sense needs to prevail many businesses are struggling with COVID let alone need this hassle

    1. Andrew, I can give you an example of an even smaller business.

      This might be an exception but illustrates an issue for smaller BRC certificated sites on the practically of unannounced audit. I know of one small BRC certificated company of which their BRC certificated factory is only a small part of their overall business. (They have a separate factory which produces pharmaceutical products). The company has two directors, one admin and in the BRC factory, two production staff. They have maintained their AA grade for the last 5 years with minimal outside technical help other than for a few of their internal audits.

      One of the directors manages the FSMS and has all the knowledge needed to host a BRC and therefore has to be present for the audit. This director also completes all the sales and technical activities which includes meetings with customers and potential customers, sometimes at short notice. They have maintained their AA grade for the last 5 years with minimal outside technical help other than for a few of their internal audits.

      The key issue is that the directors can’t put their day to business on hold for 3 months on what is a small part of their overall business on the off chance that an auditor might walk through the door. Further complication is that the BRC factory doesn’t run every week.

      10 days out of 3 months is not a practical option if they are to effectively run their business and have the flexibility to respond to all their customers needs on and offsite.

      Large sites with deputies may be able to manage this but it can be impractical for a small company to fit their operation around unannounced audits. The chances are that the auditor will turn up when there is no production and possibly when there is no one to host the audit as one director has to respond to sales related activities and the other director is out several days a week driving the delivery lorry.

      They have enough on their plate sorting out Brexit related issues so haven’t told them about this just yet….their response will be interesting.

  35. I do consultancy for small sites (<10), so they will struggle to cope with an unannounced audit. Plus some of the staff are already on furlough. I think BRC have been very unfair, first you have an extension audit, then a full audit, so small sites have had to shell out even more money in these uncertain times!

  36. Does the un-announced audit change the following audits due date (as in= unannounced +1yr instead of original due date + 1yr).
    In term of budgeting, it makes the hell of a huge difference for the smaller players such as my structure. Can’t really afford a reduction by up to 3 months.. it’s the same as a price rise of 25% in audit costs !

  37. I assume that if you changing the scope of certification (including new processes for example) that this will all still apply? We have an audit in March so will be exempt this time around from the unannounced, but the next year we will be changing the scope quite dramatically and will include areas of the standard we have never had to be audited against before. It will be typical we will be unannounced then. Fine in principal, but as a lot of people have stated, this isn’t easy for a smaller businesses as it’s only myself and an external consultant (who obviously won’t be on site) that will have enough knowledge of the standard to answer most questions, let alone take on challenges around areas we have never been audit on before.

  38. So am I right in thinking as our audit is due end of Jan 2021, the next audit due Jan 2022 will definitely be announced as the unannounced scheme starts on audits after Feb 2021? Does that make sense?

    1. Hi Luke
      There are no rules about which audit needs to be unannounced, it will be decided between you and your CB.
      Kassy

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