25 replies to this topic

[GMO]

Does anyone know any more about this?

[Simon]

Unannounced BRC?

 

Nice to see you back GMO

 

Regards,

Simon

[cazyncymru]

Yes, I've had an email from ASDA today.

 

Asda will be, as of 1st October, insisting that anyone packing own label product, will have to have an unannounced BRC Audit.

And you can only block off 15 unavailable days!!

 

Cazx

[cazyncymru]

Wonder how I'll cope if I have a PIU and BRC same day!! It will all be very cosy! Unless I'm off on one of the 15 days holidays I can't block off!

[shea quay]

Turns out today is becoming a day of comebacks!

 

Regarding Asda, this is what landed on my desk this morning;

 

"On the 26^th June 2013 ASDA announced that from the 1^st October 2013 all manufactures of ASDA Brand Food Products must have their BRC audits undertaken as “Unannounced Option 1. Other requirements which were delivered at the ASDA conference for “Manufacturers of ASDA Branded Food Products” and these are summarised as follows:-
 
1.     That all first tier material suppliers for ASDA Branded Food Products must be BRC (or GFSI) certificated as part of the supply chain.
2.    All packaging suppliers used for “ASDA Branded Food Products” must have BRC/IoP certification.
3.    All storage and distribution activities associated with ASDA Branded Food Products must be carried out by a service supplier who is certificated to the BRC Storage & Distribution standard."

 

We don't supply ASDA, but surely it's only a matter of time before others follow suit. I believe it is the responsibility of every Food Safety Manager to tell ASDA to go f*** themselves myself. I plan on drafting a strongly worded letter down the pub later if anyone is interested.
 

[George @ Safefood 360°]

The announcement by ASDA to introduce unannounced BRC audits is an early indication of what many of us believe will be unannounced audits becoming the norm. Obviously this presents a whole multitude of practical issues on the ground. For many years I conducted technical audits for a retailer whose policy required they had to be unannounced. Shea quay's colorful reaction was not common in my experience but it is true that I was not on many of these companies x-mas card list. The look of shock (actually it might have been closer to horror) on the faces of the Quality Manager when I turned up unannounced resembled something from the World Gurning Competition. Personally I did not enjoy the experience having worked as a Quality Manager myself for many years previous. As the auditor, however, I heard all possible reasons not to allow me conduct the audit - everything from 'the dog ate my homework' type reasons to the outright NO's!! 

 

I believe the Retailers are reacting to a number of important and serious issues relating to third party certification schemes such as the GFSI. I will do a more detailed blog on the subject later this week since it is a significant event for both retailers and food businesses. The latest Woolworth standard for suppliers is representative of this also. Recent events bring the issue into sharp focus. The horse meat scandal centered on businesses that were both GFSI (Grade A) certified and Retailer technically approved. Third party certification is growing dramatically on the global stage and now deserves some serious debate.

 

There is the simple fact that an announced audit will provide an auditor with the real operational and management standards of the plant in a way that announced cannot.

 

I will be happy to share with Shea the top 10 excuses I heard to prevent an unannounced audit ... and it may help him spare the sensibilities of the poor auditor    

Edited by George Howlett, 06 July 2013 - 03:02 PM.

[Simon]

Totally inevitable and completely unavoidable natural progression, over the next few year's unannounced audits will become the norm; I've been saying this for a couple of years.  I remember my old cub scout motto "be prepared" and that's exactly how it should be.  Apart from a little disruption and a little mess that can be accepted as part of the daily business of running a business everything else should be operating as per policies and procedures and as per the requirements of standards.  

Unannounced audits will make us all raise our game, if we still want to be in the game.  We have discussed members preparedness previously: Unannounced Audits - how prepared are you? - what we will see (hopefully) is the shape of this poll chart shifting positively as unannounced audits drive continual improvement.  Perversely I would actually advocate breaking BRC audits up into 3 or 4 short unannounced audits per year, moving away from an annual event where we naturally relax once it's over.

 

If (and it's a big IF) unannounced 3rd party audits mean customers will rein in their own audits and provide them with more trust in the integrity of 3rd party audits then I'm all for it. Personally I would much prefer to have one unannounced BRC audit than one scheduled BRC audit and multiple customer audits.  

 
At the end of the day unannounced audits are coming there's no doubt about that, so rather than wasting our time bleating on about how tough it is, it's time to draft an action plan to prepare ourselves for unannounced audits.  Off the top of my head are are a few things I would do.

 

• Make an appointment with senior management to review
• Develop a very quick and easy internal training course on the subject of unannounced audits for managers and supervisors
• Make an action plan to improve the operational effectiveness of systems and procedures (if you need to)
• Make more people responsible for the maintenance of the FSMS
• Audit, audit, audit and involve more in responsibility for auditing
• Have a monthly CAPA meeting
• Develop a very quick and easy internal training course on the subject of unannounced audits for employees
• Make a detailed action plan for what happens the day the auditor turns up

Of course the list will be different depending on where your business is at.

 

Maybe you can help shape the list.

 

Regards,

Simon

 

 

 
 

[Charles.C]

Dear All,

 

No blame attached to the EHOs ? Seem to recall they are long unannounced already ?

 

I get the impression this is a purely European thrust ? Or perhaps the USFDA / USDA also do it routinely already ?

 

Looks like a "Business Opportunity" for the secretarial staff at CBs.

 

Rgds / Charles.C

[George @ Safefood 360°]

Totally inevitable and completely unavoidable natural progression, over the next few year's unannounced audits will become the norm; I've been saying this for a couple of years.  I remember my old cub scout motto "be prepared" and that's exactly how it should be.  Apart from a little disruption and a little mess that can be accepted as part of the daily business of running a business everything else should be operating as per policies and procedures and as per the requirements of standards.  

Unannounced audits will make us all raise our game, if we still want to be in the game.  We have discussed members preparedness previously: Unannounced Audits - how prepared are you? - what we will see (hopefully) is the shape of this poll chart shifting positively as unannounced audits drive continual improvement.  Perversely I would actually advocate breaking BRC audits up into 3 or 4 short unannounced audits per year, moving away from an annual event where we naturally relax once it's over.

 

If (and it's a big IF) unannounced 3rd party audits mean customers will reign in their own audits and provide them with more trust in the integrity of 3rd party audits then I'm all for it. Personally I would much prefer to have one unannounced BRC audit than one scheduled BRC audit and multiple customer audits.  

 
At the end of the day unannounced audits are coming there's no doubt about that, so rather than wasting our time bleating on about how tough it is, it's time to draft an action plan to prepare ourselves for unannounced audits.  Off the top of my head are are a few things I would do.

 

• Make an appointment with senior management to review
• Develop a very quick and easy internal training course on the subject of unannounced audits for managers and supervisors
• Make an action plan to improve the operational effectiveness of systems and procedures (if you need to)
• Make more people responsible for the maintenance of the FSMS
• Audit, audit, audit and involve more in responsibility for auditing
• Have a monthly CAPA meeting
• Develop a very quick and easy internal training course on the subject of unannounced audits for employees
• Make a detailed action plan for what happens the day the auditor turns up

Of course the list will be different depending on where your business is at.

 

Maybe you can help shape the list.

 

Regards,

Simon

 

 

 
 

Logical plan, Simon and very useful. It is an interesting question though... if unannounced audits make so much sense (from a food safety perspective) why have we not seen a move towards them before now? The reason is in part due the significant impacts such a decision has on the Retailers and Certification Bodies and not just the food plant itself. If all BRC audits were to become unannounced tomorrow we could see major disruption to the operations of the CB's; an increase in the number of failed audits and certified food businesses; increased costs to the food sector to name a few.

 

Bottom line... food safety recalls and scandals that come from certified companies only serve to undermine the credibility of the GFSI schemes. Question: will unannounced audits address this issue?

[George @ Safefood 360°]

Dear All,

 

No blame attached to the EHOs ? Seem to recall they are long unannounced already ?

 

I get the impression this is a purely European thrust ? Or perhaps the USFDA / USDA also do it routinely already ?

 

Looks like a "Business Opportunity" for the secretarial staff at CBs.

 

Rgds / Charles.C

I have no doubt that the business plans are being drafted as we speak to cope with all those re-audits in 30 days, 6 months etc. I think it is a global question, Charles. GFSI for example is the main driver for change in north america (on a practical level regarding retailers e.g. Walmart and Woolworth's down under. A big issue here is the resources to service the explosion in 3rd party certification globally. There simply are not enough experienced auditors and it will take time to address this. From experience, the job of an unannounced auditor hardly makes for an attractive career path. A job as parking meter attendant my be more attractive.

[Simon]

Hello guys,

 

There has been a tentative move towards unannounced audits, you know it’s been an option to have an unannounced BRC audit for a while.  Problem is it hasn’t been taken up readily and can you really blame businesses for not electing for the stress, inconvenience and risk. 

 

Who has the better FSMS a business with a scheduled grade A or an unannounced grade B? 

 

We cannot answer for sure, however, I would edge toward the latter.  To a number crunching ill-informed buyer or a database, a B’s a B, and that could mean you are no longer an approved supplier.

 

If all audits were unannounced then it’s clear, and that would be one inconsistency removed (where consistency is absolutely essential). 

 

All change is difficult and it will cause disruption all round, but it isn’t insurmountable. What’s the point in every Tom, Dick and Harry getting an A?  Yes some companies may drop a grade, but at least it separates and rewards excellence and acts as a catalyst for continuous improvement.  We all need a driver for change.

 

Fundamentally if a company fails an unannounced audit they have serious issues and ultimately they are putting human health at risk, and for that quite frankly they deserve to fail.

 

Bottom line there is (a degree of) lack of trust by retailers in GFSI approved, Accredited, Certification audits. I also have that same lack of trust.  I see companies with Grade A that are not grade A.

 

The only way to build trust is through consistency.  Unannounced audits across the board are in my opinion a good idea and may succeed in making certification to grade A consistently tougher. 

 

To be a success the above relies heavily on auditor quality and consistency and perhaps this is the greater challenge faced by the certification industry.  More and more companies seeking 3rd party certification plus unannounced audits will definitely mean less good auditors to go around.  A way has to be found to square this circle if progress is to be made.

 

It is interesting to discuss the wider topic, but from a food safety practitioner’s perspective none of the above really matters, we cannot affect it.  All we can do is prepare ourselves for what is to come so that we have a better chance of passing an unannounced audit with a Grade A.

 

I really should be out in the sun, or finishing my vat return,

 

Regards,

Simon

[Charles.C]

Dear All,

 

Just a few thoughts although I suspect some are close to reiterating part of George’s post.

 

I am unsure if the proponents of unannounced audits really believe that  Food Safety will be thereby enhanced or are just giving the nod to the leverage wielded by retailers and perhaps the likely demise of numerous dubious, less deeply-pocketed (?), competitors. Perhaps the loss of the latter would indeed be a good thing but I’d like to see some evidence.

 

If the retailers’ justification is to prevent  horsemeat, melamine type issues, I fear that “Where there’s a will,…..

It could be argued that  prevention should be directed towards prioritising control processes (PRPs??) / auditing scopes / auditing capabilities rather than timing of visits. Shades of a sledgehammer to crack a (perceived) nut ?

 

It also appears to me that the, IMO, ever-increasing level of required minutiae in the various Food Standards is self-defeating if Food Safety is genuinely the true objective (ignoring red-herrings like weight control). Rather focus on aspects which experience has demonstrated are more likely to create safety incidents. I believe it’s called risk assessment. Or was it HACCP ?

 

Charles.C

[cazyncymru]

The FSA released its "Incident Report" for 2012 back end of June.

 

I've attached it as it does make interesting reading, and I think it is relevant for this topic, and as to why ASDA may have made the decision it has. A number of withdrawals and recalls could have been avoided.

 

As a site, we are always "Audit Ready". My issue is if it clashes with another audit. I have already had more than 15 audits this year, and a rather full diary coming up. We are a small facility and it would be impractical if not downright impossible to host 2 audits simultaneously Who do I turn away??

 

Caz x

Attached Files

•  incidents-report-2012.pdf   675.32KB   49 downloads

[Simon]

Hi Caz, so you would obviosuly like to take that number of audits down. A couple of questions.
 

Do you elect for BRC unannounced now?
Do you think mandatory unannounced BRC will reduce the number of 'other' audits?

Am I right in saying you have an action plan or checklist for unannounced audit preparedness?
 

Cheers,
Simon

[cazyncymru]

Hi Caz, so you would obviosuly like to take that number of audits down. A couple of questions.
 

Do you elect for BRC unannounced now?
Do you think mandatory unannounced BRC will reduce the number of 'other' audits?

Am I right in saying you have an action plan or checklist for unannounced audit preparedness?
 

Cheers,
Simon

 

Action plan for unannounced audits? Too right I do! I think you'd be stupid not too.

 

I would "elect" to have an unannounced BRC if it meant I didn't get audited, on practically a weekly basis, by the retailers et al.

 

Unfortunately I doubt that the numbers of audits I get would reduce, even if I had an A* with no non-conformances in an unannounced BRC audit, which is why this will never work. Until someone has the balls to stand up to the retailers and stop all of this repeat auditing, then we are never going to move on. With all the audits I've had this year, I can count on 1 hand the number of non-conformances I've had. We are an A Grade BRC site, with no non-conformances, PIU Green & ASDA green. I have had the EHO/FSA and FVO audit this year. As a site we worked damned hard to achieve this, and we work damned hard to maintain it, as I am sure have many other sites. WHAT ELSE DO YOU WANT ME / US TO DO??????

 

I question what our Minister for Agriculture, Food & Marine is doing to help manufacturers. There should be dialogue with the retailers so that there can be a common goal with regards to standards (with the BRC was meant to be!). We all now that these audits are costing us money, can't be much change from £1000 these days for an audit. At least on these days I get a decent lunch! but I'd rather have a 1% pay rise!

 

I'm sure I can't be the only Technical Manager who is totally disillusioned with the current situations.

 

Cazx

[Simon]

Action plan for unannounced audits? Too right I do! I think you'd be stupid not too.

 

I would "elect" to have an unannounced BRC if it meant I didn't get audited, on practically a weekly basis, by the retailers et al.

 

Unfortunately I doubt that the numbers of audits I get would reduce, even if I had an A* with no non-conformances in an unannounced BRC audit, which is why this will never work. Until someone has the balls to stand up to the retailers and stop all of this repeat auditing, then we are never going to move on. With all the audits I've had this year, I can count on 1 hand the number of non-conformances I've had. We are an A Grade BRC site, with no non-conformances, PIU Green & ASDA green. I have had the EHO/FSA and FVO audit this year. As a site we worked damned hard to achieve this, and we work damned hard to maintain it, as I am sure have many other sites. WHAT ELSE DO YOU WANT ME / US TO DO??????

 

I question what our Minister for Agriculture, Food & Marine is doing to help manufacturers. There should be dialogue with the retailers so that there can be a common goal with regards to standards (with the BRC was meant to be!). We all now that these audits are costing us money, can't be much change from £1000 these days for an audit. At least on these days I get a decent lunch! but I'd rather have a 1% pay rise!

 

I'm sure I can't be the only Technical Manager who is totally disillusioned with the current situations.

 

Cazx

 

Soz Caz, I guess I pressed a button.
 

The above is your current situation and it's not good.

 

One of the key goals of unannounced audits surely must be a reduction of audits, if not then I agree it won't be helpful.  I think BRC et al recognize the need to build trust in BRC Certification to reverse the trend of increasing independent audits.  I'm sure they are focused on this. I think unannounced audits is one weapon in the fight for integrity.  Whether it works and whether it reduces independent audits remains to be seen.  But something needs to be done.  Surely ASDA would drop their independent audits (so at least one less). 

 

Regards,

Simon

[cazyncymru]

 

Not only are ASDA insisting that you have an unannounced BRC, but they will be employing loads more Technical Managers so that they can carry out "PIU type unannounced audits"

 

God / Allah / Guru help us!  Just in time to give the Food Graduates jobs!!

 

Edited by cazyncymru, 12 July 2013 - 12:09 PM.

[Simon]

Not only are ASDA insisting that you have an unannounced BRC, but they will be employing loads more Technical Managers so that they can carry out "PIU type unannounced audits"

Well that's just plain stoopid.

[cazyncymru]

I bet these unannounced will be supplemented by the HACCP Audit, Foreign Body Audit and Cleaning Audit that ASDA already carry out! And lets not forget the approval Audit!

 

I wonder how many of these Technical Managers will be on site for 1st production runs at 2am on a Saturday morning??

[marxu]

I wonder who will pay for this extra audit and associated expenses (they should if it is  their requirement).  I think retailers should give more financial security to suppliers first and work more with them to improve product quality. What about if there is somebody on holiday and we have another customer audit. I could go to ASDA, TESCO  store and find a few wrong things myself but I can not do it as client or supplier.

[GMO]

We conservatively estimated across my two sites that we have 27 audits a year.  This has already increased this week with a request for one more and another which is completed every 6 months.  So 30 audits it is.  One week recently I had three audits in 4 working days including Tesco PIU.  We got a blue (for the last audit with Tesco), so a fantastic result but the personal toll it took on me was huge.  The problem I'm having is export customers are now going down the same route.  It used to be export was a way to sell stock and not get many complaints or audits.  No more.

 

If the Asda move reduces audits, then fair enough.  I'll be the happiest blooming food geek in the world.  The point of BRC was always to be instead of the retailers doing their own audits.  It's not worked.  It might help me hold off those export customers for a while but not for long I suspect.

 

To be honest, as I have unannounced PIU on two sites, unannounced BRC doesn't really phase me but it's worth remembering for certain other schemes, e.g. red tractor, it's a prerequisite to acceptance.

 

As Caz I think said earlier on, as you can't block out many dates anymore, if anything it will share the audit workload.  Let's hope everyone is ready...

[Filipa A.]

Good Morning!

 

Apart from the unannounced BRC audit  requested by Asda, we have received now the information that we will have another unannounced audit (Asda Assurance audit) following Asda Technical Polices and requirements!

 

Anyone have this document?

 

Thanks,

 

Filipa

[GMO]

Btw two A*...

 

But 60-70 days of auditing a year is getting ridiculous...  I now delegate some audits to other people because I just can't do them all myself!  We managed three in one day the other day and had M&S and unannounced LIDL on one day recently which was a bit tasty.

[Simon]

Btw two A*...

 

But 60-70 days of auditing a year is getting ridiculous...  I now delegate some audits to other people because I just can't do them all myself!  We managed three in one day the other day and had M&S and unannounced LIDL on one day recently which was a bit tasty.

 

There is a currently a topic running on the forum where a member recently achieved certification to FSSC 22000 and realized (after a lot of hard work and cost) the requests for information and audits not only continue, but continue to grow.  Kind of disillusioning and perhaps an indication that 3rd party certification and the GFSI dream is faltering.

[GMO]

There is a currently a topic running on the forum where a member recently achieved certification to FSSC 22000 and realized (after a lot of hard work and cost) the requests for information and audits not only continue, but continue to grow.  Kind of disillusioning and perhaps an indication that 3rd party certification and the GFSI dream is faltering.

 

 

It's true and it's like the retailers can't back away from it because of not being able to trust the auditors or suppliers but ultimately trust is about risk assessment and lack of trust costs money.  Perhaps there could be a system, like BRC or any of the GFSI schemes but in several tiers.  Then to supply one retailer you may only need tier 1 but to supply some of the more picky ones you need tier 3 or something?

The fact is 60-70 days of being audited a year does not add value to my business and beyond, say 10 days of auditing (where you get different people's view which is always helpful) the remaining 50-60 days don't make the food any safer.  All it does is add cost, add stress and stop me working on continuous improvement (ergo, it may actually make the food less safe.)

 

Perhaps if the multiples were more ready to share and accept eachothers audits?  But that's never going to happen.  I did hear a rumour that one large retailer was trying to get the discounters out of a factory because their view is they piggyback onto the food safety systems of the big players without bearing the cost.  But the thing is that's the same for a factory.  A way to utilise your assets is to supply to the discounters who give you very little hassle on a Technical front, have good payment terms and aren't on your backs every day.  I mean, who really wants all of the big 4 plus all the other players with their stringent standards in one factory?  Then when you factor in supplying world wide, it just gets ridiculous.