In February 2020 the GFSI published their new benchmarking requirements; GFSI Benchmarking Requirements 2020.

There is one huge change that effects us, which all the GFSI recognised schemes are now working on – that one in every three audits will now need to be unannounced.

BRCGS

BRCGS will be publishing guidance for this in August 2020 and have issued the following go live dates:

BRCGS Food Safety and BRCGS Packaging – February 2021

BRCGS Storage & Distribution – May 2021

The change will not affect BRCGS Agents & Brokers sites, as this audit is totally document based and therefore, an unannounced audit is not applicable.

FSSC22000

The FSSC22000 Version 5 Standard already requires sites to have one in three audits in the unannounced audit format. Version 5 went live in January 2020.

IFS

IFS are currently working on the details for the unannounced requirement and will be publishing this in August 2020.

Unannounced audits

We will cover how unannounced audits will work in practice in more detail in future articles.

You may find some of our previous articles helpful:
Top Tips for Unannounced Audits – Part 1
Top Tips for Unannounced Audits – Part 2

Thoughts?

How do you feel about doing unannounced audits? Are you used to them already or will this be a big change for your site? Please add your thoughts to the comments box below.

Have your say…

17 thoughts on “One in three audits to be unannounced from 2021

  1. Whilst this move was almost inevitable, and without seeing the proposals on how it would work, it would seem to continue the trend of bias towards larger companies with more resources. Small companies with restricted management teams may have difficulty coping on audit days where appropriate resources to cover both the audit and production may be limited. And what exactly is a 1:3 cycle? An unannounced visit in 2021 – then two announced visits seems easy enough, but then what if the unannounced is in 2022 and then again in 2024? The first is a 1:3 (2021 & 2023) but the 2024 is not if we count 2022,2023 & 2024 as a three year period. Eager to see how the proposals are put together.

  2. We have never had an unannounced audit, this worries me because we are only a small business and if I was not present as the Technical Manager I’m sure we fail 🙁

    1. Same here Dawn. If I wasn’t in, after the tour of the facility, it really would be a struggle for anyone else to go through anything. Also, we use a Technical consultant for quite a bit still as it’s only me in Quality. So if he isn’t in I would literally dealing with the BRC auditor by myself, which is obviously quite intense

      1. Exactly the same. We have Tesco unannounced already but that’s a seasonal product so I just don’t take holiday during that time. If I’m out in the field or off-site we’d manage an audit, but it would not be easy as I know my systems inside out. When I was off on parental leave we were able to get our consultant in for the day(s) – not possible in unannounced.

        I think if we can make the paperwork side of auditing remote, and a physical visit to see the systems running this would make unannounced a viable option possibly?

        1. We are in the same boat, our technical team has two of us. 1 will start the audit and do the factory tour whilst the other does the traceability check. If the auditor turns up when one of us if off we have problems straight away. We simply cant entertain an auditor and run a traceability check at the same time so straight away we have a major non conformance

    2. Just wondering if I’m living in blissful ignorance…..or not!

      We’re on the unannounced system. Our audit duration is 2.25 days.

      We’ve always worked on the premise that the audit will be conducted on consecutive days. Previously with an audit duration of 2 days we felt that if an auditor was not on site by Thursday morning, then they would not arrive on Friday and would arrive at the earliest on Monday of the following week.

      Has anyone had an audit of more than 1 day duration start on Friday?

      Working on the assumption that the audit is now 2.25 days, following the above logic would that mean that if the auditor was not on site by some time on Weds afternoon then they would not come for the rest of that week?

      We are a fairly small, relatively uncomplicated site. Has anyone had experience of a 2.25 day audit being done in 2 days? I remember there was some discussion of the amount of hours an auditor could work per day, breaks, etc. making this unfeasible, but haven’t followed any discussion since.

      Our audit is due by the end of Sept, so I’m sure we’ll find out soon enough anyway….

      Or, is there a chance it could be delayed due to lack of auditor availability. Our customers insist it is an unannounced audit. If the audit window had to be extended, but not through our fault, I assume it would still be classed as unannounced?

      We had the 6 month extension remote audit, so my understanding is that the audit window in any event absolutely can’t be extended beyond the expiry date on the extended certificate…

      Love to receive any thoughts on this (even if they’ll give me a few sleepless nights 🙂 )

  3. Unannounced audits have been part of SQF audits for a while. I believe it is a better self calibration tools for certificated sites to measure how well they are actually doing what the say they are doing, in other words, how well they are actually implementing the requirements for the respective codes. Interestingly certificates sites tend to fair very well in unannounced audits. Keep in mind that the CBs and the certificated sites must agree on an audit window that the unannounced audits must take place, typically within 30 days prior to the anniversary of the site’s yearly re-certification date. Some large customers such as Nestle and Costco in the USA, require certain high risk certificated vendors’ site to go on fully unannounced audits (3:3). I have performed a few unannounced SQF audits and the sites actually do tend to have an enjoyable unannounced audit experience.

  4. I agree with Dawn, as a small business, we could struggle with an unannounced audit. I think the only way that this could be reasonably managed would be to give the auditing company a set of dates that covered holidays for critical staff in small businesses.I am talking about those with maybe 30 or less people as the infrastructure may not yet be present or developed sufficiently.
    Would it also not be better to introduce this from the next issue of the standard (V9) as they come out approx every 3 years, then we would all know that we will get one in during that period.
    It would also be useful to know the likely window of the unannounced audit, again, especially for small business, i.e if you normal audit is due in July, would the audit window be from April onward? Would this also change your audit schedule for the following year and bring it forwards or do you maintain the original audit due date in July? So many questions that need to be considered and the information giving to us as businesses as to how this will work.

  5. The bottom line is, if your site isn’t audit ready then how are you making safe products?! Most BRC auditors know that we don’t live in an ideal world an perceive things in a human manner so the odd hiccup isn’t going to throw you out. Honestly, if anyone is worried about receiving an unannounced audit, then the systems and culture needs to be changed… an open door policy shouldn’t be a scary notion.

    1. The problem is that there is a difference between a site being able to produce safe and legal food, and it being able to handle an audit, they are two very different beasts. I am confident that when I’m physically away from site everything we do is correct, safe and legal. I am not confident that the other people in my business (finance, sales, procurement, growing) know exactly what the auditor wants when they speak about a specific clause or that odd bit of text we have to shoehorn into that specific procedure to satisfy the standard for example.
      When your business has 0.5 to 1 person per management role, unannounced audits are very difficult, but not impossible.

      1. I know that there are grey areas but the ability to take an audit and the ability to produce safe/legal food are not different beasts at all… following the BRC guidelines for food safety and legality ensure that the food produced is safe and legal, right? As for the other members, how do they perform in internal audits? If your internals are fine then they’re not going to be asked anything different with the BRC auditor… they won’t be expected to know what the clause numbers are, just what they do and why they do it…
        it sounds a bit like there’s an understaffing issue here, which would suggest that things aren’t always being done which would explain your concerns…?

  6. I concur with what Steve mentions. You are producing human consumption items, you must be following Food Safety and Quality principles, at all times. Fostering and enforcing Food Safety and Quality Culture inevitably enhances Safe Food production. I would think that performing periodic unannounced Internal Audits will support plant personnel, getting “comfortable and used” to being around an auditor ” in these type of audits.

  7. I had Global GAP unannounced audit. It was eye opening.
    I agree with Steve, you should not worry. You must always work in system which will control and prevent unsafe products. Make sure your workers understand food safety and help them to adopt the proper working procedures. Food safety shall be culture. I believe it will be a good opportunity for all of to see where we stand.

  8. We’ve had unannounced customer audits in the past and most experienced auditors would take this into account and expect the odd slip-up. My though process is around auditing bodies, and how the actual unannounced part would work.

    What if i want to change certification body, how can i make that decision if my current certification body can send an auditor anytime? If we have an unannounced audit in 2021 does that mean we shouldn’t expect another until 2024 and if that’s the case the unannounced audit would typically be in a specific window (Current unannounced BRC works in this way) to stop certification bodies churning out audits every 9 months and then it’s not really unannounced.

  9. I look after 3 sites which are all audited as their own business as such so basically it could mean I have one a year. Our recent auditor told us he thinks it will be 4 weeks we can block out which would cover my holidays but I feel we will need to also rely on our Deputies. That is where I shall focus on for sure.

  10. There have been no announcements, or position statements on the BRC participation website with regards to unannounced audits.Does this apply to Packaging material sites?
    We manufacture polythene for some food related customers & hygiene-sensitive products for Medical customers.

    Kind regards
    S.Kurkus

    1. We’re expecting the publication of a document from BRCGS this month Stefan. The unannounced audits apply to packaging sites from Feb 2021. As soon as BRC publish more details, we’ll let you know 🙂

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