10 replies to this topic

[Miss Tammy]

We just completed our 7th consecutive BRC with 12 minors, which is a grade B.  Prior to this, we had all grade A!  (only 3 minors last year) This was the first time we had the auditor, and he was new to the auditing firm that we use.  His style was very confusing as he did not go in order, but jumped from one standard to another without rhyme or reason!  He would ask for a specific record out of nowhere and I would not even know which standard he was on!  It was a nightmare to say the least.  By the end, I was so stressed and confused that I missed an opportunity to argue two of the NC's that I strongly disagree with.  My question: Has anyone ever appealed a BRC audit, and if so were you successful? 

[Charles.C]

We just completed our 7th consecutive BRC with 12 minors, which is a grade B.  Prior to this, we had all grade A!  (only 3 minors last year) This was the first time we had the auditor, and he was new to the auditing firm that we use.  His style was very confusing as he did not go in order, but jumped from one standard to another without rhyme or reason!  He would ask for a specific record out of nowhere and I would not even know which standard he was on!  It was a nightmare to say the least.  By the end, I was so stressed and confused that I missed an opportunity to argue two of the NC's that I strongly disagree with.  My question: Has anyone ever appealed a BRC audit, and if so were you successful? 

 

Hi Miss Tammy,

 

I cannot offhand recall any previous Posts here documenting an appeal. But i might be wrong.

 

There are however several posts from memory regarding substantial disagreements in the course of the audit regarding implied forthcoming NCs..

 

You might consider describing the most vexing of yr NCs to get some feedback.

[Miss Tammy]

Charles,

 

Thanks for your interest.  The first  concerns the requirement to have a list of controlled documents.  The auditor stated that EVERY document must be on the list, even a glass and brittle plastic cleanup procedure that is posted in the facility.  Every policy in the quality manual. every HR document, EVERYTHING!  Our company has had a combined total of 14 BRC audits, and all we have ever provided is a list of records used in the plant, and have never been told differently.

 

The second are two non-conformities from the 2015 internal audit that were not documented as completed.  The standard states that any that impact food safety, quality or legality must be recorded etc.  These were some light bulbs that were out and a wall in a non product area that needed cleaning! 

 

I think we have decided to except it.  I did some research that suggests we will end up even worse should we appeal, but it is a "hard pill to swallow"!

 

Any input would be appreciated......

[Charles.C]

Hi Tammy,
.

Thanks for feedback.

 

I deduce the 2 criticisms relate to clauses 3.2.1 and 3.7.2

 

For  the first one, as per the Standard's text, IMO the auditor has no justification for his "100%" controlled document requirement (would be interesting to see the interpretation in BRC's  IG document). Offhand, I cannot remember any Standard having this specific requirement although some people  do it anyway.

 

On the other hand, yr Documentation Procedure should have a response to the first 2 bullets of 3.2.1 regarding "controlled documents. I'm not sure if you had this".?

 

For the second one, I deduce this refers to an auditor finding of 2 omitted corrective actions in 2015 which were never subsequently documented as completed. I doubt you can escape from this one. It's like a freebie NC.

 

Interesting to hear more comments.

[Miss Tammy]

I agree that the incomplete NC were "low hanging fruit" for the auditor, but as neither impact food safety legality or quality which the standard specifically states, I disagree on this being an NC.  I guess we will have to suck it up and take the "B", but as we are in discussions with new customers, it could be very detrimental to our future business.  I hope to never have this auditor back even if we have to change auditing firms:-(

[Charles.C]

I agree that the incomplete NC were "low hanging fruit" for the auditor, but as neither impact food safety legality or quality which the standard specifically states, I disagree on this being an NC.  I guess we will have to suck it up and take the "B", but as we are in discussions with new customers, it could be very detrimental to our future business.  I hope to never have this auditor back even if we have to change auditing firms:-(

 

Hi Tammy,

 

Frankly i am surprised the auditor continued with the 100% NC since his final list of NCs will ultimately be liable to survey by the CB's own  accreditation body for "consistency".

 

Another thread here recently discussed where the last stage disagreed with the CB's decision and added (!) an NC to the original list. This one could be the opposite IMO.

 

So if you don't see this auditor again.........

[Miss Tammy]

Yes Charles, I am afraid to challenge it for that very reason.  He stated that he was very new to this auditing firm, so maybe I have a prayer???  I don't think it very likely that they will disagree with him though.  Any action would probably be internal on their part as in additional training.  It was without a doubt the most stressful situation I have dealt with in my entire career!  They are stressful enough without feeling like the auditor is deliberately trying to confuse and keep you off balance. 

[GMO]

 even a glass and brittle plastic cleanup procedure that is posted in the facility. 

 

 

 

I would expect this to be on a doc control list to be honest.

[GMO]

 

The second are two non-conformities from the 2015 internal audit that were not documented as completed.  The standard states that any that impact food safety, quality or legality must be recorded etc.  These were some light bulbs that were out and a wall in a non product area that needed cleaning! 

 

 

Yep but it was raised in an internal audit so you presumably thought it was an issue and your records say they weren't done.  Picky?  Yes but difficult to argue this is against the standard.

 

We also had a hard time with our auditor but we argued at the time.  Definitely a lesson for the future, however tired you are.  Also don't let him jump around.  Ask him for a list of things he would like to see next.  Most auditors like this and it allows you to keep the audit flowing.

[redfox]

Hello Tammy,

 

IMEX, those findings is really an NC. Especially those un-closed NC of your internal audit. Cause auditor find it negligence of the site when it fails correct NC. An NC on your previous internal audit and still NC on the next internal audit some auditor will put it Major NC. We will be having an audit this June 8-9 against BRC7, your post remind us that we must be vigilant in or documentation.

 

Regards,

redfox

[melsm57]

1. I was pretty ticked at my last BRC (at a previous company) - The auditor who had been at the facility twice before - identified 7 minors which was small improvement over the previous time - and tbh there were several cheapies, that could easily have been avoided if the team had just responded appropriately to my pre audit prep meetings and inspections (isn't it always so?) - but when the written report came in , there were 2 more items, that had been discussed but had not been identified in the closing meeting as NC .  I felt let down by that.