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Common Critical Non-conformites in a BRC Audit?

brc Non-conformites

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#1 rtorres

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Posted 12 August 2020 - 04:30 PM

Hello Everyone,

 

I have a BRC Issue 8 audit coming up in a few months. Can any one tell me what are the more common sections that I may get a Critical on?


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Ramiro Torres


#2 pHruit

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Posted 12 August 2020 - 04:47 PM

The clauses marked with a star are "fundamental", so those are effectively an instant fail if significantly non-compliant.

There are a few places that publish lists of the most common NCs, although not specificalyl for criticals (n.b. not all updated for Issue 8, but many of the clauses are the same):

https://techni-k.co....n-conformances/

https://www.qadex.co...ance-in-audits/

 

Forgive me for saying, but I feel nervous on your behalf if you are focussing on potential criticals at this stage!

Do you have some significant concerns in specific areas?

If there are particular clauses that concern you, and for which the Interpretation Guide hasn't helped and/or you want further input on, then putting the clause number into the search box towards the top right of the forum can usually  bring up useful threads, and if you can't find what you need then by all means post specific questions here - it's a very helpful community ;)



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#3 rtorres

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Posted 12 August 2020 - 05:41 PM

Thank you, I do remember from my BRC Issue 8 training from last year the instructor mentioning stars and fundamental sections. 

 

Its okay that you ask, I am kinda wondering how everyone else has been doing with implementing, measuring, and improving their food safety culture. I know it was new to Issue 8. So not sure how critical auditors are being when it comes to this section. I have implemented a food safety culture and I have measured our culture, just not really sure how to show that I am improving it?

 

Just want to be prepared for this upcoming audit.


Regards,

 

Ramiro Torres


#4 Charles.C

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Posted 13 August 2020 - 12:24 AM

The clauses marked with a star are "fundamental", so those are effectively an instant fail if significantly non-compliant.

There are a few places that publish lists of the most common NCs, although not specificalyl for criticals (n.b. not all updated for Issue 8, but many of the clauses are the same):

https://techni-k.co....n-conformances/

https://www.qadex.co...ance-in-audits/

 

Forgive me for saying, but I feel nervous on your behalf if you are focussing on potential criticals at this stage!

Do you have some significant concerns in specific areas?

If there are particular clauses that concern you, and for which the Interpretation Guide hasn't helped and/or you want further input on, then putting the clause number into the search box towards the top right of the forum can usually  bring up useful threads, and if you can't find what you need then by all means post specific questions here - it's a very helpful community ;)

 

Hi pHruit,

 

I recall that previously BRC themselves issued  fascinatingly detailed breakdowns of their audit results vs category (attached somewhere on this forum) which were from memory in line with the brief quadex link (the latter perhaps using BRC data).

I also recall that then the fraud segment had substantial NCs as also did the "sharps".

Plus the consequences significantly varied with product category (hardly surprising if risk a factor).

 

The two links give differing conclusions but this maybe due to, for example, ver.7 cf ver 8 or BRC altering their expectations with time (?) or ?. I have some reservations about the paucity of the NC listings in techni-k -  "a truncated list" ?


Kind Regards,

 

Charles.C


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#5 beautiophile

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Posted 13 August 2020 - 01:32 AM

BRC makes annual reports. This is for 2019:

https://www.brcgs.co...019-digital.pdf

What you'd like to know is on page 8 & 9.

I don't know why they keep displaying invalid links of other years on their publication hub.



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#6 Charles.C

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Posted 13 August 2020 - 07:18 AM

BRC makes annual reports. This is for 2019:

https://www.brcgs.co...019-digital.pdf

What you'd like to know is on page 8 & 9.

I don't know why they keep displaying invalid links of other years on their publication hub.

 

Hi Beautiophile,

 

Thks for the link.

 

(1) The tables on Pgs 15,17 seem to be contradictory.

(2) The meaning of Saturation% is inscrutable,  not to mention "Volume" of audits.

 

Translated from the Latin ?.

 

Re (1) - eg Clause 4.4.1 tops the Blue Chart but is ranked 5 on Pg 17 ??

                  Clause 4.4.9 is ranked 3 on Pg 17 but is non-existent on Blue Chart

 

Clause 4.4.9 is stated to be Door Condition, in the Code it's related to Lighting !

 

Moreover the report seems to have massively shrunk , ie no detailed analysis of product categories etc although the report(s) I am remembering might have been compilations rather than annual.


Kind Regards,

 

Charles.C


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#7 pHruit

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Posted 13 August 2020 - 08:49 AM

Hi pHruit,

 

I recall that previously BRC themselves issued  fascinatingly detailed breakdowns of their audit results vs category (attached somewhere on this forum) which were from memory in line with the brief quadex link (the latter perhaps using BRC data).

I also recall that then the fraud segment had substantial NCs as also did the "sharps".

Plus the consequences significantly varied with product category (hardly surprising if risk a factor).

 

The two links give differing conclusions but this maybe due to, for example, ver.7 cf ver 8 or BRC altering their expectations with time (?) or ?. I have some reservations about the paucity of the NC listings in techni-k -  "a truncated list" ?

 

Yes, I too recall seeing similar but couldn't put my hand on anything for V8, hence having a bit more of a general look at google suggestions.

My general impression is that the "new" clauses often cause a few headaches as people try to get to grips with them, so I'm not surprised to see Radiological Hazards on the techni-k list. I agree that the data behind it is far from comprehensive in real terms though.

 

The BRC report linked by Beautiophile is interesting, but aside from the "curious" presentation of data, it's a bit unclear as to what period it actually relates. FWIW the "created" date in the PDF file data is 15/02/2019, which IIRC was the same month that Issue 8 audits went live - the data being presented is therefore presumably all for Issue 7 audits?

It suggests that the first annual report relevant for Issue 8 should have been due earlier this year, so I can imagine that this was perhaps not considered a priority in the scramble to set up remote audit protocols etc...

 

 

Thank you, I do remember from my BRC Issue 8 training from last year the instructor mentioning stars and fundamental sections. 

 

Its okay that you ask, I am kinda wondering how everyone else has been doing with implementing, measuring, and improving their food safety culture. I know it was new to Issue 8. So not sure how critical auditors are being when it comes to this section. I have implemented a food safety culture and I have measured our culture, just not really sure how to show that I am improving it?

 

Just want to be prepared for this upcoming audit.

 

The new Food Safety Culture element has unsurprisingly been one that has generated a lot of discussion ;)

These threads may help as a starter:

https://www.ifsqn.co...safety +culture

https://www.ifsqn.co...n-organization/

https://www.ifsqn.co...safety +culture

https://www.ifsqn.co...safety-culture/



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#8 QCYFH

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Posted 13 August 2020 - 12:56 PM

Hi. 

 

I would definitely suggest paying attention to your food safety culture plan - we 'got away with' a poor one the first year (feb 19), however in our BRC audit in July the auditor said he wouldn't have let us off with the plan we had.

 

We received a non-conformance for having a plan, however it was not formally reviewed. (tbh it was a poor plan altogether so we got away lightly) 

 

Just make sure whatever you do RECORD it, otherwise it didn't happen. Our auditor said to make the plan as big and best as possible because if you don't meet everything in the plan you are recording the measuring / effectiveness anyway. So it's better to have 10 things on their that didn't happen for certain reasons than to not have the 10 things on their at all.

 

Hope this makes sense! 



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#9 pHruit

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Posted 13 August 2020 - 03:38 PM

I would definitely suggest paying attention to your food safety culture plan - we 'got away with' a poor one the first year (feb 19), however in our BRC audit in July the auditor said he wouldn't have let us off with the plan we had.

 

We received a non-conformance for having a plan, however it was not formally reviewed. (tbh it was a poor plan altogether so we got away lightly) 

 

 

This seemed to be almost a semi-formal approach from BRC to this new requirement, with the first audit really only expecting evidence that you'd sort of started thinking about it - the expectation being that by the second one you've got a year's worth of data from your staff surveys or whatever you've been doing, and thus should be in a position to know what your culture currently is, and then be able to identify what you should be doing to improve it. It does feel like a lot of sites may have managed to kick that a bit further into the long grass with the remote audits, as it wasn't a topic on the list. Which is a little surprising IMO, as the circumstances are/were right for all sorts of cutting of corners IMO...



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#10 rtorres

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Posted 14 August 2020 - 03:47 AM

Hi pHruit,

 

There is no need for you to apologize, I am sure your just as passionate about food safety as I am.

 

Like I said I am new to food safety, and had my first BRC audit last year. I don't think I asked the question correctly.

I am not worried that I am going to get a critical. I was just wondering if someone had some good advice on what I should expect with this second audit.


Regards,

 

Ramiro Torres


#11 Charles.C

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Posted 14 August 2020 - 06:10 AM

Yes, I too recall seeing similar but couldn't put my hand on anything for V8, hence having a bit more of a general look at google suggestions.

My general impression is that the "new" clauses often cause a few headaches as people try to get to grips with them, so I'm not surprised to see Radiological Hazards on the techni-k list. I agree that the data behind it is far from comprehensive in real terms though.

 

The BRC report linked by Beautiophile is interesting, but aside from the "curious" presentation of data, it's a bit unclear as to what period it actually relates. FWIW the "created" date in the PDF file data is 15/02/2019, which IIRC was the same month that Issue 8 audits went live - the data being presented is therefore presumably all for Issue 7 audits?

It suggests that the first annual report relevant for Issue 8 should have been due earlier this year, so I can imagine that this was perhaps not considered a priority in the scramble to set up remote audit protocols etc...

 

Yes, I wondered if there were ver7 refs somehow involved in the potpourri but didn't have a copy at hand to check. It's a confused and confusing document.


Kind Regards,

 

Charles.C


#12 pHruit

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Posted 14 August 2020 - 08:37 AM

Hi pHruit,

 

There is no need for you to apologize, I am sure your just as passionate about food safety as I am.

 

Like I said I am new to food safety, and had my first BRC audit last year. I don't think I asked the question correctly.

I am not worried that I am going to get a critical. I was just wondering if someone had some good advice on what I should expect with this second audit.

 

Ah, ok, understood!
As it'll be your second audit against Issue 8, I'd expect particular scrutiny of 1.1.2 / Food Safety Culture - having had a year to work on this there is likely to be an expectation that you've analysed  your data, identified areas for improvement, and are implementing measures to make those improvements.

The other key thing I'd suggest looking at is your non-conformances from the previous year - these are likely to be reviewed in detail under clause 1.1.12.

 

Otherwise the audit should theoretically proceed in a similar fashion to your first one, so it's perhaps a case of a general review (e.g. doing your own internal mock BRC - if possible audited by someone other than you, as it's easy to miss things when you're very close to your own system) just to make sure you're comfortable that you've addressed all the clauses, your records are all in good order etc.

If you've got the same auditor then this is easier to prepare for, but if it's a different auditor then you can find that the experience can be very different even thought they're both auditing the same standard ;)







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