14 replies to this topic

[GMO]

A warning!
 

We made a mistake last year and were late with our management review (trying to get everyone in the room at the same time).  It was less than 2 weeks, we were honest and while it wasn't perfect, that was all we could do.

 

We got a minor from it.  Apparently BRC global standards have clarified that any lapse over 7 days is a minor and if it's >365 days at time of audit and the next one hasn't been done, it's a major.

 

Word to the wise!

 

[classic]

Hi GMO

 

Where is this requirement documented in the BRC  standards.  It seems a bit harsh as even when you plan your annual review meeting  well in advance there is always some reason why the meeting cannot take place and it is moved.

 

Classic

[Ryan M.]

Did you write your Management Review SOP as such to be done on a specific date/timeline?  Maybe you put yourself in that corner....

[mgourley]

This is one reason why we do quarterly reviews.

1) easier to get people in one room

2) does not take all day

3) information is not a year old if there is something that needs to be acted upon

4) prevents NC at audit time

 

Marshall

[GMO]

Did you write your Management Review SOP as such to be done on a specific date/timeline?  Maybe you put yourself in that corner....

 

No we didn't.  Our auditor specified that they had checked with BRC and confirmed anything over 7 days is a minor or a major if it's still not complete when audited.  A failure of our honesty.

[GMO]

This is one reason why we do quarterly reviews.

1) easier to get people in one room

2) does not take all day

3) information is not a year old if there is something that needs to be acted upon

4) prevents NC at audit time

 

Marshall

 

Good point.  We've set ours for 11 months now but it's worth us considering.

[GMO]

Hi GMO

 

Where is this requirement documented in the BRC  standards.  It seems a bit harsh as even when you plan your annual review meeting  well in advance there is always some reason why the meeting cannot take place and it is moved.

 

Classic

 

Section 1.1.3

Management review meetings attended by the site’s senior management shall be undertaken at

appropriate planned intervals, annually as a minimum, to review the site performance against the

Standard and objectives set in clause 1.1.2. The review process shall include the evaluation of:

• previous management review action plans and timeframes

• results of internal, second-party and/or third-party audits

• customer complaints and results of any customer feedback

• incidents, corrective actions, out-of-specifi cation results and non-conforming materials

• review of the management of the systems for HACCP, food defence and authenticity

• resource requirements.

Records of the meeting shall be documented and used to revise the objectives. The decisions and

actions agreed within the review process shall be eff ectively communicated to appropriate staff , and

actions implemented within agreed timescales.

[pooled]

Our Management Review is broken down for sections to be reviewed so as to not try and cram it all into one meeting. Internal Audits are performed one month and then a Management Review is scheduled for the following month.

[Ryan M.]

Maybe I missed it or you didn't post the full requirement, but I see no specific timeline other than annual. Such as completed by 7 or 10 days?

[mgourley]

There is no specific timeline other than annual.

If you are over 365 days from your last review... NC

 

Marshall

[GMO]

Maybe I missed it or you didn't post the full requirement, but I see no specific timeline other than annual. Such as completed by 7 or 10 days?

 

I suppose the interpretation is that annual = 365 days (or 366 in a leap year) therefore more than that is a non conformance; 7 days is perhaps considered sufficient leeway for an "acceptable" delay.

 

In any case, I don't think anything >366 days can be argued as "annual" to the letter of the standard so I actually agree with the non conformance even if I think it's pedantic.  I just wanted others to be aware.

[Ryan M.]

Interesting...I'm not familiar with BRC, but do they schedule their auditing as such?  For example, if your first BRC audit was on 12/20/16 your next annual audit would have to be by 12/20/16, or do they give a window?  The whole thing seems absurd to be honest.  Operations and life happen, the question is how much risk is added if you do the review on day 366 versus 365?  

[mgourley]

There is an audit window with BRC. Consequently, your audit dates "move up" each year. 

 

That is why they use the term "annually" in the standard. It does not say "calendar year" or any other qualifier.

 

Marshall

[GMO]

Interesting...I'm not familiar with BRC, but do they schedule their auditing as such?  For example, if your first BRC audit was on 12/20/16 your next annual audit would have to be by 12/20/16, or do they give a window?  The whole thing seems absurd to be honest.  Operations and life happen, the question is how much risk is added if you do the review on day 366 versus 365?  

 

I agree.  I also see no benefit to the review if I'm honest and tried to argue our weekly meetings cover it all but it wasn't accepted.  We only do the review to "tick the box". 

[Dapulu]

Weird. Porbably depends on the auditor, however I don't see anywhere the 7 days clause...maybe that's what it says in the interpretation guide, I don't have it though.

 

On previous teams and audits, we've got 2 NC on that clause. One is for missing out the "fraud and authenticity" section in the meeting record, and the other one for missing the date on a few pages of the record.

 

We've also got an annual review +365 days later, I'd say close to +430 days. However, after explaining that the current CEO made the annual review 350 days after he took the position, and that the date of his entrance was around 2.5 months after the previous CEO annual meeting review, we didn't have any issues. 

 

Maybe depends on the auditor