Consequences of a late GMP audit while preparing a BRC audit
We are a small poultry processor preparing for our first BRC Food Safety audit next spring. We are a USDA inspected facility, and have historically had GMP audits annually. Our goal is to become BRC Certified in 2021. Our GMP audit was in Mid-March 2020, so we ideally want to have our BRC Audit around the same time next year.
However, due to complications brought on by COVID-19, we will not be fully compliant with the BRC Standard Issue 8 for another two months most likely, which would not give us the 3-6 month compliance history needed for the audit, if we schedule it for mid-March 2021.
Since a GMP audit is voluntary, and seems to have no expiration date (none listed on certificate or report), what would be the consequences of letting more than 12 months go by between our GMP audit and our BRC audit, assuming our customers would not have an issue with it?
Thank you!!
If there's no regulatory or BRC requirement to do GMP audit every 12 months, and it's only your internal policy - just add adjustments to your policy to extend GMP audit frequency say to every 18 months or so.
I have found most times there is no impact. With that said if you are working with a consultant you may want to have the consultant write a letter (this is what we do for our clients and it works well) indicating the reason for the lapse, time-lines, etc. and give it to you so you can provide to your customers that may get nervous or have a specific requirement for year to year.
While most do not carry an expiration, the assumed is most times 1 year.
completely agree with the two previous posts.
I would like to add something to think about. Having the GMP audit prior to your BRC certification could be a benefit to you and your facility. Having been BRC certified for many years now, knowing the complexities, all the documentation, all the focus required ect ect......your annual GMP audit could highlight some areas that need to be corrected and might prevent some easily overlooked non conformances.
Best of luck in on your upcoming certification!
Hi Mary,
I'm not sure what the scope of GMP is in USA but IMEX, scope of GMP and BRC are worlds apart ? eg GMP typically has no detailed involvement with haccp.
As is for a new establishment, I would guess BRC expect to see an equivalent time period of appropriate, auditable, Production-Related Records/Data.
IMEX of BRC audit, there was total disinterest with respect to any other existing certified Standards.
Many thanks to you all for your answers and advice!! I appreciate the opportunity to access experts in food safety so much!!