Understanding the BRC Unannounced Audit Programme

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1 1. Introduction The BRC unannounced audit scheme provides companies an opportunity to: demonstrate their confidence in their systems and procedures, to the extent they are willing to subject these to unannounced scrutiny provide their customers with an independent unannounced review of systems and procedures that demonstrates they are maintaining their systems in good order provide their customers with an opportunity to review the risk rating of suppliers and view suppliers in the scheme favourably, depending on performance, and adjust the frequency of customer audit, and other additional control procedures applied by the customer This guideline explains how the BRC unannounced scheme operates, what a company needs to do if they wish to join the unannounced scheme and provides answers to some commonly asked questions. Who is required to have BRC Unannounced audits? The unannounced scheme is voluntary and the decision to participate in the scheme rests with the certificated company; however, some customers require manufacturers of their brand products to join the unannounced option 1 scheme. The unannounced scheme is open to sites that have a BRC certificate with a Grade of A+, A, B+, B, C or C+. If you are not certificated you are not eligible for the unannounced scheme and your next audit will be announced. What is the difference between unannounced option 1 and unannounced option 2? The protocol for the BRC Standard identifies three different audit options: an announced audit - where the company and the Certification Body agree the date for the audit an unannounced audit option 1 the full audit is conducted unannounced i.e. the company will not be notified of the date of the audit, which can take place anywhere between three and twelve months after the initial audit date an unannounced audit option 2 the audit will be split into two sections. An unannounced audit will cover GMP and production areas. This will be followed by an announced audit of the systems and documentation ie the company will agree the date for the documentation audit with their Certification Body but will not know the date for the audit of their GMP and production areas. This option is designed for sites 15/1/2014 Page 1

2 who would like to enter the unannounced scheme but wish to avoid having the documentation audit on a day when key staff are absent. When do we have to decide whether we want to have an unannounced audit? The decision to opt into or out of the unannounced audit must be made after each audit. Therefore, if you wish to enter (or remain in) the unannounced scheme then after the audit (assuming you have achieved certification) you must notify your Certification Body that the next audit will be an unannounced. This notification must occur within 3 months (1 month for grade C) of the last audit. If a customer requires a change to the unannounced scheme that is outside these timescales then this should be discussed with your Certification Body. 2. Steps in the Process Step 1: Notifying your Certification Body What do you need to do? - Opting into the Scheme You must contact the Certification Body that carries out your BRC Food Safety audit and notify them that you will be opting into the unannounced scheme. This should be completed within the 3 months (1 month for grade C) following the last audit. The choice of whether you have an option 1 or option 2 unannounced audit must be made at this time. Step 2: The audit planning process What will your Certification Body require? - Planning the Audit Your Certification Body will require some information to help them plan the audit and ensure that the auditor does not turn up at a time when you are not likely to be in production. This information is likely to include: Typical shift patterns Production schedules, to allow audits to cover relevant processes, for example night time manufacture or where production processes are not carried out each day Any dates on which the audit cannot take place, due for example, to non-production (for option 1 the Standard allows a maximum of 15 days to be blocked out from the audit plan as non-audit days. For option 2 a maximum of 10 days can be blocked out) The management organisational chart A simple site plan The process flow diagram A summary of critical control points (CCPs) The list of products or product groups included within the audit scope 15/1/2014 Page 2

3 It is important that this information remains up to date and any changes are notified to your Certification Body in a timely manner. Your certification Body will probably issue you with a new contract for the unannounced audit scheme. Audit Dates - When can I expect the audit? For an option 1 Audit: The audit may occur at any stage from 3 to 12 months of the audit due date, but will typically be within the last four months of the certification cycle. The proposed audit date will not be notified to you in advance of the audit. Month Initial audit Opt into unannounced audits Unannounced audit Audit report and certificate The audit will take place on a weekday and the earliest start time will be agreed with you by the certification body in advance based on shift patterns. For an option 2 Audit: For unannounced option 2 audits the audit is split into two parts of equal duration. Part 1 of this audit will be an unannounced audit of GMP ie of the production areas and activity. This part of the audit will take place from 6 to 10 months of the audit due date. Part 2 of this audit will be an announced audit of documentation and records. This part of the audit will take place within 28 days up to and including the anniversary of the last audit date. Month Initial audit Opt into unannounced audits Unannounced GMP audit Announced Documentation Audit Audit report and certificate The audit will take place on a weekday and the earliest start time will be agreed with you by the certification body in advance based on shift patterns. Can I block dates if they are not convenient? It is expected that Standards are maintained at all times and that your site is audit ready. 15/1/2014 Page 3

4 However there is no point in the auditor turning up during a factory shut down or periods of refurbishment when no production is taking place. For option 1 audits up to 15 days may be excluded. For option 2 audits up to 10 days may be excluded. For grade C sites a maximum of 5 days may be excluded. Any such dates must be communicated to the Certification Body at the time of opting into the unannounced audit scheme. It is important to keep your Certification Body updated on any dates when there will be no production. Step 3: The Audit Will I get any warning that the auditor is coming? For option 1 there will be no warning as this is an unannounced audit. For option 2 there will be no warning for part 1 of the audit as this is unannounced. The Certification Body will agree a date with the company for part 2 of the audit. Can I refuse access to the auditor? Unless the auditor turns up on a day which it has been agreed in advanced would be a no audit day then you are obliged to accommodate the auditor and allow the audit to start immediately on their arrival at the site. If access is denied you are likely to be liable for the auditor s costs and the site s certification may be suspended or withdrawn. What happens if our site is not in production when the auditor arrives? As part of the audit planning the company should notify its Certification Body of any particular days or times when production is not undertaken. If the audit takes place on a date when production was supposed to be undertaken, but on arrival the auditor finds it is not, then the audit cannot proceed. At the Certification Body s discretion a further unannounced audit may be scheduled or the site will be suspended and revert to the announced scheme. The site may also be responsible for the auditor s expenses. What happens if the Technical Manager is away on the day of the audit? This would not be accepted as a reason to prevent the audit going ahead. It is expected that in most organisations there is cover for Managers in their absence. The first day of the audit will largely be factory based in the production area with most documentation viewed on the second day. The auditors will work with the site to plan the documentation which will need to be seen to allow time for this to be found. 15/1/2014 Page 4

5 Will the audit be longer than my Standard BRC audit? The audit duration will be calculated using the BRC audit duration calculator and will be the same as for an announced audit. Will the actual audit be different from my previous announced audit? The audit procedures and content are the same for both announced and unannounced audits. However, the audit will begin with an inspection of the production facilities and this will normally commence within 30 minutes of the auditor arriving on site. For option 2 unannounced audits the first day will concentrate on GMP and production areas and the second on documentation and records. Step 4: Audit Grading and Certification Is the process different for unannounced audits? The process for reporting and correcting non-conformities is the same for all BRC audits i.e. following the audit you must undertake corrective action to remedy all the non-conformities identified during the audit. The company must also complete a root cause analysis to identify the underlying cause of each non-conformity and develop a corrective action plan to address these root causes. After a review of the audit report and the documentary evidence demonstrating corrective actions, a certification decision is made by the Certification Body. Where a certificate is granted the new certificate will be issued within 42 days of the audit and your grade will be A+, B+ or C+ to indicate the audit was unannounced. If you achieve an A+ or B+ grade your new certificate will have an expiry date based on the previous certificate expiry date plus 12 months (6 months for C+). This ensures that where an audit occurs before the end of the current certificate, it is not disadvantaged by a shorter certificate life or increased frequency of audits. For option 2 unannounced audits the audit report and certification decision are made within 42 days of completion of the part 2 audit. The audit report and certificate will state Unannounced Option 1 or Unannounced Option 2 as appropriate. This new certificate will supersede the existing certificate. Step 5: Planning the following audit When will my following audit occur? Assuming your site has achieved certification your next audit is also eligible for the unannounced scheme. The next audit date will be based on the initial audit date before you entered the unannounced audit scheme and not the date of your most recent unannounced audit. 15/1/2014 Page 5

6 3. General Questions and Answers We normally have combined audits with more than one certification scheme. What happens to our audit? The BRC audit must follow the rules outlined above if you are to be included in the unannounced scheme. Your Certification Body may be able to approach the other scheme and clarify whether they would accept an unannounced audit. If this is acceptable then both audits can be unannounced and simultaneous. However, if the other scheme owner does not permit unannounced audits then they will need to occur on different dates. Will the audit be more expensive? The cost of the audit is determined by the Certification Body and will vary between Certification Bodies. The unannounced audit is expected to be the same cost as your current announced audit. We would like to change Certification Body for next year s audit. How do we do this within the unannounced audit process? This is acceptable but you must decide upon the certification body within the first 3 months of your audit and ensure that the new Certification Body is made aware that you are in the unannounced audit scheme. Will it be clear to our other customers that the audit was unannounced? Yes, grades from unannounced audits are denoted with a + (e.g. A+) to indicate that the audit has been part of the unannounced scheme. What happens if we fail the audit i.e. we become not certificated? Once the site has addressed the non-conformities that were raised at the audit, it can arrange a new audit. This new audit will be an announced audit. This re-audit cannot take place within 28 days of the previous audit. Some customers require notification of this situation immediately after the audit is complete. We have not previously been certificated to the BRC Standard. How do we proceed? The first BRC audit for any site must be an announced audit. Following successful completion of this initial audit (i.e. the company obtains a grade A, B or C) then you can opt into the unannounced scheme. What happens if I only produce Seasonal Products? Seasonal sites are eligible for the unannounced audit schemes; however, the following rules apply: The expected seasonal production dates must be communicated to the Certification Body when you notify your certification body of your intention to join the unannounced scheme. 15/1/2014 Page 6

7 No dates may be excluded within the production season If an Option 2 Unannounced audit has been selected then the planned document review audit will normally occur before the season and the unannounced Good Manufacturing Practice audit. Please see further details in our Position Statements document (F042) 4. Where can I go for more information? The BRC Global Standards team will be pleased to provide advice if required or you can contact your Certification Body. For the BRC - Contact : Enquiries@brcglobalstandards.com or the website : 15/1/2014 Page 7