You may remember that we covered the biggest change to the GFSI Benchmarking 2020 requirements in one of our previous articles; One in three audits to be unannounced from 2021.

BRCGS have now sent us the position statement that covers this requirement; BRCGS079: Position Statement and Protocol on Unannounced Audits Meeting the GFSI Benchmark.

So, in this article we’re going to cover how the 1 in 3 unannounced audits will be managed.

Which BRCGS audits does this affect?

First of all, the most important thing to know, is that:

  • If you’re on the unannounced audit programme, this does NOT apply to you.
  • If you’re not on the unannounced audit programme, this DOES apply to you.

This applies if you’ve not chosen the unannounced audit programme. It does not apply to sites who have chosen the unannounced audit programme.

1 in every 3 audits will now have to be unannounced as follows:

  • BRCGS Food Safety from 1st Feb 2021
  • BRCGS Packaging from 1st Feb 2021
  • BRCGS Storage & Distribution from 1st May 2021

This change doesn’t affect BRCGS Agents & Brokers audits, as it’s only the practical aspect of the audit that needs to be unannounced, not the paperwork side. And BRCGS Agents & Brokers audits are all paperwork, so the practical side of the audit doesn’t exist.

When will my audit be?

From Feb 2021 (or May if you’re Storage & Distribution) your audit will be within the next 3 years. You’ll get plenty of notice; because your Certification Body will speak to you, within 3 months of your last audit, to confirm that your next audit, will be unannounced.

Once organised with your Certification Body, your unannounced audit will take place within 4 months of the audit due date. Where the site is seasonal and the season is less than 4 months, this will be the maximum audit period.

When will my 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.

Acceptable Not acceptable
Customer visits Staff 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.

If you have any questions about the 1 in 3 unannounced audit protocol, please add them to the comments box below.

Have your say…

23 thoughts on “How your BRCGS 1 in 3 unannounced audit is going to work

  1. 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).

  2. 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?

  3. 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!

  4. 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..

  5. 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!

  6. 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

  7. 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.

  8. 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.

  9. 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?

  10. 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*!

  11. 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.

  12. 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!

  13. 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 !

  14. 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.

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