BRCGS Audits Impacted by Covid-19

BRCGS audits will expect sites and certification bodies to follow any government guidance in place for the region or country applicable.

The procedure applies to existing certificated sites who are unable to receive a physical audit because:

• The site is located in a country or region where government advice/restrictions prevent movement or access to the site
• Where company policy prevents visitors to the site to safeguard the health of employees
• Where it is the policy of the certification body to restrict auditors travel to a particular country or region to safeguard the health of their auditors.

BRCGS appreciate that the travel restrictions will have an impact on audit arrangements where auditors located in a restricted travel area can’t audit other regions. They also understand that high risk staff members may have to be safe guarded. BRCGS, do however expect that certification bodies utilise their global auditor pool. Reasons for audit delay due to cost purposes will not be accepted. This process is not applicable to sites not currently certificated to BRCGS.

Reference can be made to appendix 1 outlining specific scenarios.

BRCGS (re) Audits Due

Where the site is operational, but a physical audit may not occur on or before the BRCGS audit due date and will result in existing certificates expiring, a certificate extension of up to 6 months validity may be issued based on:

• The successful completion of a risk assessment by the Certification Body confirming it is appropriate to continue certification
• The Certification Body completing a discussion with the site and review of procedures in place to establish the impact of Covid 19 extraordinary circumstances to the site operations and the effective implementation of any emergency response plan.

Note that certificates may only be extended by the current Certifying Body.

Risk Assessment

The Certification Body shall assess the risks of continuing certification and have a documented policy and process defining the methods for evaluating the site. Reference may be made to the principles of IAF document ID3:2011 Management of Extraordinary Events or Circumstances Affecting ABs, CABs and Certified Organizations.

The Certification Body shall gather information from the certified site and consider within the risk assessment:

• The history of third party certification
• The history and maturity of the BRCGS system
• Whether there is any other management system or certification in place
• Absence of critical situations throughout the organisation’s certification history with respect to the BRCGS standard
• Pending compliance activities / legal proceedings
• Product recalls since the last BRCGS audit
• Whether the site is functioning normally
• Whether significant changes have been made at the site since the last BRCGS audit
• Whether the site is operating to the scope of certification
• Any changes to processes or services outsourced following the COVID-19 emergency
• The appropriateness of the sites emergency response plan to Covid 19

Discussion with site

The aim of the discussion is to assess the site actions in response to Covid-19 and ensure that the site has developed its procedures such that it can continue its operations to supply safe products.

The Certification Body shall agree appropriate times with the site to complete a review of the risk assessment details to confirm that it is appropriate to extend certification.

This does not need to be completed in one session and the duration can be appropriate to the complexity of the issues to be discussed but should be a minimum of 1 – 2 hours where there are few site changes. This shall be conducted with suitably senior and competent persons at the site. It is expected that supporting documents are provided as evidence for discussion.

This shall include as appropriate:

1. Review of implementation of sites emergency response plan to Covid 19.

• As a minimum it is expected that sites have considered impact of staff availability with contingency plans in place. They shall have updated their screening processes for staff and have a policy in place for staff members who may have been exposed to Covid 19.
• The site shall have considered requirements for additional or increased cleaning and where appropriate hand washing.
• Each site shall have defined minimum criteria for cleaning and product quality management where the optimum activities have needed to be adjusted due to staff shortages.
• Sites shall have contingency plans in place for ingredient supply that may be affected.
• The site have a clear policy on access to the site and the impact on any service provision changes eg maintenance and pest control, to ensure continued production of safe products.
• The Certification Body would be expected to sample evidence of an appropriate management meeting discussion/actions as well as the documented policies.

2. Internal Audits

• Review of internal audits schedules and implementation to ensure that product safety systems continue to operate effectively under pressure.
• Review of any adaptations the sites may have to make to normal ways of working.
• The Certification Body would be expected to sample an appropriate recent internal audit as well as the documented policies

3. Review of any significant changes to the operation of the site in response to Covid 19 eg changes in outsourcing and the controls the site have put in place.
4. Review of recent customer complaint levels
5. Review of any product recall since the last BRCGS audit, root cause and corrective actions put in place as a consequence.

Outcome

Any concerns following the discussion with the site that could raise doubts to continuing certification shall be documented in a similar format to ‘non conformities’ and the Certification

Body shall agree with the site a process where these can be actioned, where appropriate, so that certification can be extended.

Certificates may only be extended to the current scope – significant changes to scope may not be made.

Sites Certificated with C and D Grades

Where sites are currently certificated with a grade C or D, unfortunately these shall be classified as ‘high risk’ and certificates may not be extended.

Sites Certificated to Packaging Standard issue 5

When sites are currently certificated to BRCGS Packaging issue 5, note that the risk assessment and discussion shall be against issue 5. This will allow extension of the current issue 5 certificate. Once travel restrictions are lifted, an audit on site to issue 6 should be carried out as soon as possible.

Sites Certificated to Gluten Free Certification Program

Where certification to the GFCP is currently in place at a site based on a third party certification, other than BRCGS, the risk assessment principle may be used for sites that fall into the criteria, as long as the third party certification is maintained ie other scheme certificate is permitted to be extended.

Physical onsite Unannounced audits

In the current climate, it is recognised by stakeholders that unannounced audits may place undue burden on sites busy with ensuring supply chain continuity. Therefore unannounced audits will be temporarily suspended. Where physical onsite audits are still taking place and unannounced audits are due in the next 4 months, Certification Bodies should contact sites to arrange an announced audit. Protocols for announced audits shall then apply including grading outcomes.

Informing BRCGS

‘Concession reference numbers’ are not required for certificate extensions that fulfil this criteria. The certification body is responsible for notifying BRCGS through the Directory.

Updates are currently being made to the BRCGS audit Directory schedule tab and should be available shortly, your Consultant will share any changes that apply to your organisation with you.