BRCGS have published updated position statements regarding handling of audits during COVID-19.

We got confused with all the different documents, how they all fit together and where to find them all. So, we’ve worked through them all, organised them all and put them in one place.

We thought, if we’re confused and finding the amount of different documents difficult – then maybe you might be too.

Which is why, we’ve created a page on our website where you can find them all. It also contains answers to the questions we think you’ll want to know. If there’s anything we’ve missed that you want answering, please just say and we’ll update it.

BRCGS COVID-19 documents

To try to simplify things, we thought we’d provide a list of questions and answers – rather than trying to explain everything in the documents above.

If you have a question, that we’ve not covered, please let us know and we’ll add it.

 

Q: I’ve already extended my certificate. Can I extend it again?
A: No. But you can have a full remote audit. This is a normal audit but the full audit is done remotely.

 

Q: Is a remote audit GFSI recognised?
A: No. However, there isn’t a GFSI recognised alternative at the moment. To be GFSI compliant you have to do a blended audit or a full on site audit.

 

Q: What does the GFSI say you should do if your certificate has been extended and is due to expire?
A: The GFSI’s position at present is that you should let the certificate expire and do an on-site audit as soon as is possible. Which we feel, that in this situation – a remote audit is better than no audit.

 

Q: How do I qualify for a remote audit?
A: To qualify you just have to agree with your certification body that a normal audit isn’t possible due to the pandemic
. The BRCGS say it’s acceptable to refuse a normal audit “Where company policy prevents visitors to the site to safeguard the health of employees.” (see document BRCGS072, page 2)

 

Q: How do I prove that an on-site audit isn’t possible?
A:
You just need to have a company policy that visitors are not allowed on-site, due to COVID-19.

 

Q: I produce product for retailers – can I do a remote audit?
A: That’s up to your retailer. Remote isn’t an option for the Asda AA Module. If you really can’t have an on-site audit, you should check with your retailer to understand what they would like you to do.

 

Q: How many remote audits am I allowed?
A: There is currently no limit.
The remote audit option “will remain available to sites until at least April 2021. At which time BRCGS will review the continued need for this audit option.” (see document BRCGS086, page 6)

 

Q: Is a remote audit a good solution if I can’t do an on-site audit due to COVID-19?
A: The best solution is to go ahead with your audit, with the right COVID-19 controls in place.
If you really can’t go ahead with an on-site audit, then a remote audit is definitely the next best option. A remote audit will give you a certificate for up to another year, based on your grade.  You need to keep in mind that this means you may not have had an auditor on-site for up to 2 ½ years, so your customers may ask you do an on-site audit (before your certificate expires), as soon as one is possible.

 

Q: Do I have to do the COVID-19 assessment module?
A:
In principle it is an additional module and therefore is voluntary. However, BRCGS haven’t actually said that it’s voluntary.  If your certification body is saying it’s mandatory, we would definitely challenge this and would be happy to help you do so.

 

Q: Are there any additional COVID-19 requirements that I need to be aware of for my audit?
A:
In principle you’ll be audited to the normal Standard, however we would suggest that you go through the guidance document from BRCGS and ensure that you’ve got everything covered that they talk about – just to be on the safe side.  Please keep in mind this document was written for food sites, so you need to take the principles of the guidance and apply it to packaging, S&D and A&B if needed.

 

Q: Can I do a remote audit if my audit needs to include additional modules?
A: Yes
, you can do additional modules remotely, except the Asda AA Module.

 

Q: What do I do if my certification body won’t do a remote audit and says I have to do a blended audit?
A:
If you want to, you can choose another certification body that will do your audit remotely. It doesn’t specifically say this in BRCGS086 but we’ve checked with BRCGS and they have confirmed that this is acceptable.

 

Q: What’s a blended audit?
A: A blended audit is an audit where 50% (maximum) is done remotely and the other 50% is done on-site
.  This type of audit is GFSI recognised (a remote audit is not GFSI recognised).

 

If you have a question that’s not listed here, please email your question to kassy.marsh@techni-k.co.uk and we’ll include it.

It would be great if we could use this page to share our experiences of remote audits too:

  • What’s worked well?
  • What’s not worked so well?
  • What have you learnt?

Please help your fellow techie’s and add your experiences to the comments box below.

Have your say…

21 thoughts on “What are the options for BRCGS audit during COVID-19?

  1. We have had both types of audit, Just completed our BRC audit on site. There was no problem social distancing as with most companies we have a large board room and desk sat opposite each other gloves, sanitisers were provided. Food we provided individually wrapped sandwiches and cakes. On the site tour face masks were worn and any conversations and demos were kept to minimum below 15 mins contact.
    We had a retailer remote audit, I found this more difficult because you have to up load all documentation before the audit, this takes a very long time, out of a busy schedule. The site tour was done through the retailers own streaming site, the problem is ensuring connectivity throughout the whole site, if lost the area can not be audited, if grainy the auditor asks to go through again and this can take a long time.
    In conclusion i prefger face to face.

    1. We also had this years audit on site (Start of July). We didn’t come across any issues. We carried it out in our conference room round a big table so we could socially distance where you usually all squeeze into my office. There was plenty of sanitiser to hand and we all wore masks throughout. Everyone was happy and we feel that no one was at risk at any time. I haven’t personally taken part in a remote audit but feel face to face would be a lot easier to conduct, as you say if you lose connection its going to hold everything up.

  2. Hello all,

    Whats the meaning of extend my certificate? for how many time it is possible? and who recognize it?

    take care be safe…

    1. Hi Ana
      Extending the certificate is when your certification body carry out a risk assessment of your site and carry out a small desktop type audit – so they can extend the expiry date of your certificate by 6 months. You can only do this one. It’s a BRC recoginised solution – is that what you mean?
      Thanks
      Kassy

  3. We are a Broker and have arranged to have a ‘Remote’ Agents & Brokers Audit on 13th October (our current extension is due to expire on 10th January) and our Auditing Body (Food Cert ID) claim that the duration is still recommended as being 10hrs. Can you believe it, 10 hrs in from of a computer screen on a video call! We only work 7.5 hr days as a norm. I have no idea what they think we are going to spend all the time covering when we don’t actually have any kind of manufacturing facility or how that sort of audit duration can be justified, purely on product range and turnover, when we are essentially just an office based business.

    I don’t know what anyone else’s thoughts are on this, but i for one see it as a manipulative way of making money for the BRCGS by turning a simple paperwork and systems audit into an unnecessary ordeal for the auditees.

    Don’t get me wrong, I am pleased that myself and my Technical Director can go into the office for one day (we mostly work from home all the time these days), because there would be far too much interruption/disruption at home, and not actually have to have the auditor on site – the wonders of modern technology meaning that we can video chat and share screens quite easily. But, to insist that the audit is going to take 10 hrs is, to my mind anyway, a bit of a joke, mixed with a kick in the teeth. It is especially frustrating when your work place is in a rural area, as ours is, and you have to spend 2 hours of your day driving the 100 mile round trip, making it at least a 12 hr day!

    My personal view is that the BRCGS should just have said ‘right, we are facing an unprecedented crisis in the world, lets just increase all certification by 1 year and allow ourselves time to see what is happening with this virus, and reassess the situation in 2021’. How difficult is that? And, what real harm would it have caused? I guess that’s too simplistic a view point, but it makes sense to me.

    Rant, rant, moan groan – finished 🙂

    1. Hi David,

      BRCGS actually did try to do something similar to what you ended your comment with by giving sites a 12 month extension based on a risk assessment and the site doing their own internal audit. Unfortunately however GFSI did not approve and due to BRCGS being GFSI benchmarked, they had to follow the rules that GFSI set.

      Fortunately you are in the position of being able to conduct a blended audit on a fully remote basis, which is something GFSI support (unlike the other types of remote audits), so I’d definitely recommend that you check that your CB is doing a blended audit rather than a remote audit.

      The time for a remote audit is the same as an on-site audit because all of the requirements still apply, but that doesn’t mean you need to spend 10 hours starting at a screen. However, if you have declared that you only work 7.5 hours as a norm this should have been booked in as 1.5 days unless you have agreed to do this over a day. It’ll likely be similar to an actual audit in that you aren’t spending every second with the auditor. Just like in an actual audit where the auditor will request information and you’ll go and get it, in a remote audit they’ll request information and you’ll provide it. The CB are able to reduce the audit duration by up to 30% if they feel it is appropriate and so hopefully won’t keep you for 10 hours if they finish early.

      Finally, unlike certificate extensions it is important to remember that you can have a blended or remote audit with any certification body – so now is the time to shop around, especially if you were charged substantial sums for the extension!

    2. Rough with the smooth in my opinion mate.

      When Audit Day comes, it’s a phone-call to the wife to let her know I will be late. If its not a 14hr day on the first day, something either hasn’t happened or a miracle has been performed.

      Audit days are tough, but that’s Technical for you. I bet you a pint and a bag of crisps that the auditor doesn’t see the benefit of a full 10 hours too.

      It’s just the silly calculation to determine audit time. I’d be impressed if the audit body is only charging the 1 day of that too – as many cap at 8 hours and charge for 2.

      That said, if you look here: https://www.brcgs.com/media/2221/ab212-audit-duration-calculator-issue-2-v1-03092019.pdf – then Appendix.1 gives some reasons to try to reduce the audit time by upto 30%. It may be worth discussing this with the Certification Body. Whilst it won’t save you any money, it could reduce the audit by a up to 3 hours if you can justify the reduction.

  4. Hi,

    I completely agree ! Covid- 19 carries million time more danger than any bacteria causing food poisoning as it can be easily treated with antibiotics.
    I am wondering would BRC take responsibility if somebody gets infected during an audit .
    Thanks.
    Svetlana.

    1. Surely you have controls already in place to protect your staff from the risk of infection.

      Intake checks of the auditor should be thorough and robust. Don’t be afraid of asking where they have been, and refusing entry for any auditor that has left the country (via the audit body in advance) – but if controlled, I don’t see how the BRC could be held accountable if an auditor did infect a site.

      I would look at the audit body themselves (they must have their own risk assessment and controls in place – so audit the audit body) and I would then look at the site too to see if the controls they had were sufficient.

  5. I’ve now had all my audits for 2020 except a full BRC (we had the extension). Most have been a video call to tour the packhouse/ site/ field/ harvesting with everything from Whatsapp to power hungry retailer apps combined with a review of previously uploaded documents and a video call.
    Uploading takes time, but you can re-use your standard documents like calibration certificates etc. Video calls will never be as good as a physical visit but they are sufficient in the short term.
    Its a shame GFSI haven’t stepped up – for once this isn’t BRC – to allow full remote during a pandemic.
    So now the fun of contacting relevant customers to see if they are happy with the remote BRC option, because unfortunately, like most SMEs we don’t have a giant board room!

    1. Don’t forget, you can mitigate risk through PPE.

      The Guidance on the GOV website for getting businesses back open includes provisions such as reduced distancing provided that PPE is worn.

      Beauty Salons can perform close-contact services provided they wear a 3-ply mask and visor. Retail shops can open with 1m distancing provided masks are worn.

      1m is only 3 feet, the width of a table.

      With appropriate checks on intake (COVID Compliant Visitor Sheet, temperature checks, contact details for track an trace) and the opportunity to wear face-coverings with sanitizer – it shouldn’t need a massive board room for a physical controlled audit to take place.

      It’s prep-time and the extra time it takes to host a COVID-Secure audit that makes regular, non-essential 3rd party audits difficult. A well planned GFSI audit, in my opinion, adds more value than any other audit.

    1. RSPO Certificates are valid for 5 years, but their 2019 standard now requires that supplier certificates are checked on a monthly basis – with no option to link directly to the RSPO page, and a site that has a poor search function. Certificates with a long duration offer a multitude of issues.

      BRC, SQF and IFC are all 1 year certificates. FSSC 22000 is a 3 year cert.

      However, if you supply into the major retailers, an FSSC 22000 certificate is likely to cause you problems as the retailers take the accreditation into consideration as part of their risk assessment. If you’re only sitting a GFSI Audit on a 3-year basis, then they will want to be inspecting you more.

      The whole point of the BRC was to reduce audit repetition – and now that the retailers are essentially stuck indoors, they will be falling back on that point more and more.

      It’s only my assumption, but I envision that (should COVID be a long-term issue) – we will see less retailer audits but more focus on the BRC being carried out to frequency, more bolt-ons, and more thorough BRC Auditing in order to appease the retailers.

  6. My experience – completed a blended audit last month and found it a good compromise, minimised the auditor contact time as only on site for one of the days, and a combination of sending them the documents they requested along with some screen sharing and talking through others worked well. The time allocated for the blended part was not all sat in front of a computer as the auditor asked for docs to be sent then wanted time to review them, so was able to get on with other things in-between which made it a bit more relaxed. re the question regards the need to have anything extra in place re current situation, there is (or was with my auditor) an expectation that you will have done a risk assessment regards covid, as it is an ongoing ‘crisis’ situation requiring an emergency plan (3.11)

    1. Thanks Chris, useful to hear your experience. If you don’t mind saying, how much of the on site audit time did you spend in production/site tour, and how complex a site are you (as in only 1 line or many, high-care etc)?

      1. Hi Rebecca, I don’t mind saying at all, about half the on site audit time was spent on site tour, the rest was reviewing docs that are easier to see hard copies of like pest control folders etc and also reviewing the outcome of the traceability exercises. That said we are a very small low risk operation (2 lines running is normal)

  7. I’ve undertaken a number of different audits through the pandemic. Whilst it’s ‘business as usual’ in terms of getting product out, the pandemic offers more challenges when it comes to the protection of staff.

    What I have found is that a happy medium needs to be established, and that takes communication. If you’re a retailer supplying site then it is likely that they will want their visit schedule to not be impacted. What I have found personally, is that risk assessing the policy for visitors is a good way of explaining the rationale behind it. As the UK hits Level 4 on the COVID-19 scale, and local restrictions in some areas are increased, it makes sense to minimise the visitors to site.

    That said, we’ve taken the stance to maintain our legal obligations (HSE, EHO, PHE and Local Authorities) without question, but also to ensure our accreditation to the BRC is maintained. This is on the proviso that we currently do not permit on-site audits/visits which are not business critical.

    We also do not have the infrastructure in place to permit virtual walk-rounds of the production facility, so whilst we welcome remote desktop audits, we can’t physically accommodate an auditor being taking around the site via digital means.

    We’ve undertaken a number of remote audits so far, and whilst they have been markedly different in the ways which they are undertaken, they do offer a way of maintaining compliance. I wouldn’t like to think that a certification as powerful and important as a GFSI accredited one could be done remotely. That’s why we are committed to ensuring that our BRC Audit will go ahead in a controlled manner on site.

    The key areas of concern are:

    Personal Hygiene – which is second nature to food premises anyway.
    Social Distancing in the audit room – separate with desks, no hand shaking, have sanitizer readily available.
    Control Equipment – provide sanitized equipment (pens, clipboards, etc.)
    Area Hygiene – especially in the audit room, have the area periodically cleaned (the factory tour makes a great opportunity) and have sanitizer wipes readily available for both the Auditor and Auditee.

    But most of all – Risk Assess it and practice with others.

  8. We are in the process of extending our audit at the current moment. The reason for concern wasn’t our fear of Covid-19 but the fact that the restrictions put in place creating scheduling conflicts with third party services needed for documentation. I stated from the onset of the virus that with the exception of increased frequencies of sanitizing common areas, wellness checks and facial coverings our food safety practices in place should effectively minimize our risks. Earlier in the year we had a SEDEX audit that was postponed due to an auditors illness, than later due to the unknown risk of Covid-19 as the outbreak initiated. A deadline for September was established and we were able to conduct the audit. My fear is if we are granted an extension until February or March of next year 2021 and the risk changes to severe and travel restrictions and lockdowns are put in place, is there a plan to address that situation.

  9. Hi…..We have received an extension certificate for our seafood operation. The certificate will expire in January 2021. Our problem right now is, we are a seasonal operation that only operates from April 1 to mid August. If we decided to do an onsite audit it wouldn’t be beneficial as we have no production to show an auditor. Not sure how we are going to proceed at this time.

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