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SaltSafety

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Posted 12 July 2011 - 02:31 PM

Just completed our first BRC audit and recieved only a C grade. The BRC standard indicates that this requires a re-audit of non-compliances within 28 days, but our auditor has told us to submit corrective actions and that we will then have a "surveliance" audit in 6 months. Is this normal and/or acceptable?
Also, our audit, including about 6 hours of plant inspection, took four full days. Does this seem excessive? We only make salt (sodium chloride) and have two basic production lines with about 8 packaging options. It's really a fairly simple process with few "ingredients". Would like to see what others out there think.



tsmith7858

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Posted 12 July 2011 - 03:01 PM

Just completed our first BRC audit and recieved only a C grade. The BRC standard indicates that this requires a re-audit of non-compliances within 28 days, but our auditor has told us to submit corrective actions and that we will then have a "surveliance" audit in 6 months. Is this normal and/or acceptable?
Also, our audit, including about 6 hours of plant inspection, took four full days. Does this seem excessive? We only make salt (sodium chloride) and have two basic production lines with about 8 packaging options. It's really a fairly simple process with few "ingredients". Would like to see what others out there think.


I do not think the standard requires a re-audit within 28 days, only that corrective actions and evidence be submitted within 28 days. It is the auditors discretion as to whether they need to return to see the correction in person. The six months is appropriate for the grade.

4 days seems excessive for the audit. 1 1/2 used to be the standard unless extra days were warranted based on multiple locations, large facility, higher number HACCP plans or high number of people/processes. I think it may have been moved to 2 days but they are also focusing on more floor time so the 6 hours on the floor seems way off for a 4 day audit.

I have to end by stating we dropped our BRC for FSSC 22000 this past year and I have not kept up to date on any recent chages so I may be inaccurate.

Good luck on your corrective actions and pending certification!


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Madam A. D-tor

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Posted 12 July 2011 - 03:21 PM

Dear Saltsafety,

If you gain grade C the non-conformities need to be closed on site,during a re-visit. During this visit only the non-conformities are verified and results are included in the original report.
For A and B grades the non-conformities are closed off-site, by sending evidence to the auditor/CB.
Perhaps your non-conformities were all documents to be changed and the auditor decided it is possible to do the verification off site. Perhaps the auditor was mistaking and just told you, what he/she tells after every audit.

4 days on site seems quite long to me too. As Tsmith7858 already said, the time on site depends on size of the site, number of workers, number of production lines, number of product groups, number of HACCP-plans, etc.
I have seen the calculation model somewhere on this site.
Most CBs sent a questionnair to gain all this kind of information. Perhaps you (or someone of your organisation) filled in number f packing lines instead of proceslines, products instead of product groups and all workers instead of FTE. you also get reduction for working in shifts. e.g. if there are 30 persons working in a 3 shift system, there will be only 10 workers working during the audit.
Most important is the question: do you feel that the auditor did a good audit or do you feel that he/she was spending too much time drinking coffee and filling in checklists?
BtW is the reporting time included in this time on site? For your information: for an initial audit I need 2 days on site and 8 hours (=1 day) reporting.

The 6 months frequency is only as long as you have grade C. You will see that the next audit (over 6 months) the result will be B or A. Then you will have an annual frequency.


Kind Regards,

Madam A. D-tor

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Foodworker

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Posted 12 July 2011 - 04:29 PM

This seems so wrong on so many levels that I have serious doubts that the certification body is properly accredited to do BRC audits. You can check on the BRC Directory website.

If you get a Grade C then a return visit within 28 days is mandatory and the next audit is 6 months later. There is no real concept of a surveillance audit with the BRC, each audit is a full top to bottom certification audit.

4 days is a long audit! There is an audit time calculator issued by the BRC which I think has been posted before, but I will do it again for convenience. For 4 days to be justified you need a large site, in excess of 1500 staff or a very complex operation with a large number of individual HACCP plans. If you are only packing salt, you are not doing anything complicated.

Additionally, if 4 days is correct, according to the calculator 16 hours or more should have been spent in the production area.

Report writing time is excluded from the calculator.

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jaredkkrischel

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Posted 12 July 2011 - 06:08 PM

If you don't mind me asking, who was your Certification Body?



George @ Safefood 360°

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Posted 12 July 2011 - 10:44 PM

You can take it as fact that a grade C requires a re-visit within 28 days - even if the corrective actions relate to procedural and document changes only. This is mandatory. A four day audit for an operation as described in your post for me has to raise an eyebrow or two. After subjecting you to a four day audit I suppose the least they could do is spare you the revisit… but on the face of it, what you describe makes little sense.

If you feel confident about your position and facts I would certainly address your questions to the CB and see what response you get. Other than that I would be exploring other CB options for your next audit in six months.



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SaltSafety

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Posted 13 July 2011 - 12:53 PM

This seems so wrong on so many levels that I have serious doubts that the certification body is properly accredited to do BRC audits. You can check on the BRC Directory website.

If you get a Grade C then a return visit within 28 days is mandatory and the next audit is 6 months later. There is no real concept of a surveillance audit with the BRC, each audit is a full top to bottom certification audit.

4 days is a long audit! There is an audit time calculator issued by the BRC which I think has been posted before, but I will do it again for convenience. For 4 days to be justified you need a large site, in excess of 1500 staff or a very complex operation with a large number of individual HACCP plans. If you are only packing salt, you are not doing anything complicated.

Additionally, if 4 days is correct, according to the calculator 16 hours or more should have been spent in the production area.

Report writing time is excluded from the calculator.



Our facility covers a lot of area, although some is not really production area. We only have about 140 employees for 3 shifts and a simple process, but the plant size is what brought it to a 3day audit. But really, the auditor addressed every single requirement of the BRC standard in considerable detail. I can't imagine it taking any less time for a smaller facility. He did write the report as he went throught the audit, so I guess you can consider the 1 day for report writing to be included, but that mean much time for us to sit and wait for the next question. Seems most people I've talked to say 1.5 days and then the report is written up after they leave.
The BRC standard says that a C grade must be followed by a revisit. I'm a little concerned that if the CB does not do a revisit BRC might take issue with our certification. Any thoughts?


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SaltSafety

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Posted 13 July 2011 - 12:54 PM

You can take it as fact that a grade C requires a re-visit within 28 days - even if the corrective actions relate to procedural and document changes only. This is mandatory. A four day audit for an operation as described in your post for me has to raise an eyebrow or two. After subjecting you to a four day audit I suppose the least they could do is spare you the revisit… but on the face of it, what you describe makes little sense.

If you feel confident about your position and facts I would certainly address your questions to the CB and see what response you get. Other than that I would be exploring other CB options for your next audit in six months.



If a revisit is mandatory and they don't do it, would there be any issue with our the BRC issuing our certificate?


Foodworker

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Posted 15 July 2011 - 08:27 AM

Your audit report and Corrective Action details should go through a Technical Review before certification. Ideally, the Reviewer will pick up the problem before it gets to the BRC.

However, if the Certification Body does not do its job properly the report may get to the BRC when it is uploaded to their Directory Website. They have a Compliance Team which monitors the reports and if it gets this far, they will reject it. (I believe the compliance monitoring is sample based so there will be a possibility it may get through unnoticed, but I wouldn't risk it.)

There is a further opportunity to get it sorted. As this was your first audit, you are allowed 90 days rather than 28 to complete the on site revisit. You still will not be certified until the re-visit has closed off the non conformities.

Your next full audit will be 6 months after the last day of the initial audit.

I would still contact your Certification Body (Assuming they are a fully accredited CB) to discuss this as you will have put a lot of time, effort and money to get certified, so you do not want complications.

With respect to the time taken, the audit time calculator only relates to production and storage facilities so external areas which play no part in the operation are excluded.

The auditor writing his report as he goes along is bad auditing practice, and frankly discourteous, but unfortunately does occur.

Check your bill carefully to make sure that do not add any time for report writing.

Remember that you have the right to complain to the Certification Body and the BRC.



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Jason H.Z.C.

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Posted 15 July 2011 - 09:10 AM

If a revisit is mandatory and they don't do it, would there be any issue with our the BRC issuing our certificate?


Hi, SaltSafety,

If the CB truly not visit your site again for verifying the closure of NCs, it will be a NC in the management system of the CB. Every CB should be accredited before it arranges and conduct relevant audits. And the accreditation body of the CB will definitely not be convinced to accept the situation post by you.

Thus I guess, the revisit shall be completed in your site after 28/90 days of the end of the audit. So you'd better contact your CB again and ask them to come again.

Further more, Typical audit manday has been adjusted as 2 days for BRC. So normally at least in China, 1,5 day is difficultly to be realized.

By the way, if you want to prolong your corrective action duration up to 90 days, you have to write to your CB a justfication in advance.

Best regards,

Jason

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Kind Regards,

Jason

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Posted 17 July 2011 - 01:47 PM

Just completed our first BRC audit and recieved only a C grade. The BRC standard indicates that this requires a re-audit of non-compliances within 28 days, but our auditor has told us to submit corrective actions and that we will then have a "surveliance" audit in 6 months. Is this normal and/or acceptable?
Also, our audit, including about 6 hours of plant inspection, took four full days. Does this seem excessive? We only make salt (sodium chloride) and have two basic production lines with about 8 packaging options. It's really a fairly simple process with few "ingredients". Would like to see what others out there think.



DEar Saltsafety

Definitely, 4 days audit is a very long time! Even if you are packaing salt for final consumption or to be use in a final product.

Regards




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