Unannounced Audits: A Guide to the New BRC Requirements
A major UK retailer recently stated that any site producing products under their own label must undergo a Full Unannounced audit. The Global Food Safety Initiative (GFSI) has also discussed the possibility, or at least defining a minimum number of Unannounced audits in a given cycle. So what does this entail and how can a company best prepare?
Who can have one?
For the British Retail Consortium (BRC) Global Standard for Food Safety, the requirements state that a company must have achieved either a Grade A or B on its last audit, and opted for the Unannounced option within three months of their last certification.
As a direct result of the retailer’s statement, the BRC is permitting any site that has Grade A or B to transfer into the Full Unannounced audit, even if they are beyond the three month period.
A Full Unannounced audit is where the entire audit is conducted unannounced. The BRC Global Standard has a second option for a partially unannounced audit where the Good Manufacturing Practice (GMP) or factory processes audit is unannounced whilst the systems audit is conducted as a planned and arranged audit.
Why have one?
It is a common myth that prior to an audit, a company goes into overdrive; fixing holes, painting walls, revising documents, training staff and getting internal audits up-to-date. Whole timetables of HACCP reviews, management reviews and recall tests are scheduled to happen just prior to the audit. Managers suddenly run around briefing people how important it is that it all “looks good on the day”.
A Full Unannounced audit is a way to demonstrate that a company works to the same standards every working day, not just brushing up for a couple of days a year.
For the extra scrutiny a successful unannounced BRC audit provides, the site will be rewarded with a + symbol after the grade, demonstrating that they maintain their systems in good order year round.
What do I need to do?
Once the Unannounced audit option has been selected, we will ask the site to complete a form providing key information to enable the audit to go ahead smoothly:
- Security – SGS will provide details of all auditors who may conduct your audit, and will provide photographic proof of identity on arrival. As with all audits, a trainee auditor, or a witnessed assessment on an auditor may take place. These training and witnessed audits are conducted by strict rules, and do not affect the audit outcome.
- Block out dates – with a Full Unannounced audit, a maximum of 15 days can be blocked out (10 days for a Partial Unannounced audit), when an audit cannot take place. These should be used when the site is not in production either for shutdowns, or for refurbishment.
- Shift patterns and earliest time of arrival.
- Where the auditor is to report on arrival at the site, who to ask for and a nominated deputy.
- Pre audit info – HACCP summary, process flow, simple site plan, organisation chart, types of products produced.
SGS must be notified of any significant changes to the site, key contacts or changes to the scope of the audit.
When can I expect to have one?
The BRC protocol states the potential date range for an audit is anywhere from nine months before the re-audit due date, although it will most likely occur in the last four months of the cycle.
The audit will only happen on a weekday, and the earliest start time will be based on the shift patterns and agreed with SGS in advance.
The audit will not take place on any of the blocked out days previously supplied.
How does it happen on the day?
The auditor will report to the agreed point on site and ask for the nominated person (or deputy), explaining it is for an Unannounced BRC Certification audit. From that point, the requirement is that the auditor is granted access to the production facilities within half an hour.
During these 30 minutes, any relevant health and safety points, a brief opening meeting, and issue of any relevant personal protective equipment needs to be completed. If your site has any specific health and safety requirements, it will pay to notify SGS in advance of these, or provide a briefing document, to save time on the day.
If key members of the site are not available on the day, the site’s defined deputies should still be able to manage the audit process. The BRC protocol does not permit an audit to be cancelled because personnel are not available.
If access is not granted, then the BRC protocol stipulates that the site’s current certification can be suspended or withdrawn, so it is important that any personnel who may be at the nominated reporting point are briefed on how to communicate the arrival of the auditor.
SGS is the largest certificating body for BRC, IFS and FSSC 22000 certificates around the globe.
Global Product Manager - BRC
t: +44 (0)1934 522 917