Minimum Operational Records, BRC Audit Requirements

 

Dear all,

 

I have question with regards to BRC audit requirement. I read from the manual that "it is unlikely that full compliance can be satisfactorily demonstrated at an audit undertaken less than 3 months from commencement of operation".

 

Meaning it is mandatory to have at least 3 months records of operation before subjecting one product to BRC audit?

 

In case we included this product during proper audit as part of the scope, will the auditor would accept trial records instead of operational records? or will the auditor declare that this is not possible and will be excluded in the scope but at the same time, the audit of the rest of the product would still continue?

 

Or do we have to tell the certification body ahead of time not to include this particular product in the scope?

 

Any help is highly appreciated.

 

 

Thanks,

 

Lelou

 

 

Hi lelou,

 

I presume you refer to this -

 

Manufacturing units that are newly built or ‘commissioned’ must ensure that systems and procedures in place are compliant before an initial BRC audit is undertaken. It is at the discretion of the company when they wish to invite a certification body to carry out an audit; however, it is unlikely that full compliance can be satisfactorily demonstrated at an audit undertaken less than 3  months from commencement of operation. This is likely to be the situation even where the site for certification uses quality systems developed by other certificated companies in the group.

 

 

One immediate difficulty is likely to be the Internal Audit.

 

See this thread -

 

http://www.ifsqn.com...udit-frequency/

Has your facility been operating for more than 3 months and you are asking about a new product that is only in trial phase? Or is the entire facility and product new (less than 3 months)?

Hi Lelou,

 

When you are developing a new product which doesn't fall under the current scope, it's a good thing to have a conversation with your certification body. Together you can see and decide what's the good moment for them to carry out the audit.

 

As development of new products is part of the business, I'm sure that they can advise you.

 

The advantage of doing so, is that you ensure that there will be no breaks in your supply chain, once the product is ready.

 

Kind regards,

 

Gerard

Has your facility been operating for more than 3 months and you are asking about a new product that is only in trial phase? Or is the entire facility and product new (less than 3 months)?

Hi Peaches,

 

The entire facility has been operating for more than 6 months, but the product in question has not been operating for more than a month, we only have 1 or 2 records in place which came from trial only. Meaning no commercial production yet.

Thanks for clarifying - As Gerard stated, have that discussion with your CB.  If it is a similar product/process that is currently being produced, then there may be no issues. 

I agree that you should contact your certification body, but also consider how similar it is to your current products. I have found through hard experience that one good reason not to try to achieve certification before 3-6 months of operation is that you are likely still trying to establish the proper procedures and limits. If it is a very different product and you are still making major adjustments, it is likely that what you are doing may not match yet with what you say you should be doing.