You may remember that we covered the biggest change to the GFSI Benchmarking 2020 requirements in one of our previous articles; One in four 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 4 unannounced audits will be managed.
Update 29/12/20: This article has been amended from 1 in 3 audits to 1 in 4 audits. The GFSI requirement is to carry out an unannounced audit every 3 years, which means 1 in 4 audits, not 1 in 3.
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 4 audits will now have to be unannounced, to comply with the 3 yearly requirement. The requirement will be applied 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.
|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.
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.
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