I agree with Marshall- in our first audit last year, we received a major non-conformance for clause 3.4.1 for not auditing the BRC procedures throughout the year. Our argument was how can we audit the program when it is not technically in place, or how can you audit something that you have just put in place?
The auditor double checked with head office but were firm on this as a major. We did not have any discussion as to how long these audits should have been happening for, but as Marshall states, clause 3.4.1 says 'throughout the year' so 12 months before makes sense (as much as BRC clauses make sense!).
Ben