BRC rules on exclusion from scope?
She pointed out that BRC were tightening up excluding areas from the scope of the audit. She mentioned that the area excluded needed to produce less than 2% of the overall production of the factory. I did challenge her and after a lot of heated discussion she agreed to grant us our BRC certification with the exclusion from scope included. Has any other members had a problem like this or knows if BRC are reviewing the exclusion to scope?
Regards
Bruce
We also recently had a BRC audit. We excluded from the scope probably 1/3 of our area, as it is not being used in production any longer. Mostly this was all outside, but she did exclude them from our audit. She did not state anything about not allowing it.
The BRC version 6 book has a section addressing scope exclustions - I don't have mine handy, but am sure someone else can give you the section. The exclustions were tightened up quite a bit over previous versions. In all the audits I have had since v6 came out, the auditors have questioned our previous exclusions, and we have had to revise ours considerably.
According to the wording of the V6 manual, I quote,
" The exclusion of products produced on a site will only be acceptable where the excluded products can be clearly differentiated from products within scope and make up a MINORITY of the products produced at the site.
- The products are produced in a separate area of the factory
Or
- The products are produced on different equipment, e.g. products packed in glass jars in a cannery"
There is no definition of minority by percentage or any other guide.
Therefore as far as I would interpret this area, provided the exclusion is less then the scope you should be allowed to have such exclusion.
It is in section 3 6.3 Exclusions to the scope and from what I can see it does not give a % it only states the minority of products but it does state as long as it is agreed with the certification body in advance
It is very specific with what the exclusion to the scope can be and it sounds like you were in the right with what you had done