What Happens When You Remove Product Lines from Your BRC Scope?

Hi there,

We have undergone some changes at our facility that resulted in selling some of the equipment so we will no longer be making a finished ready to eat popcorn product.  However, we will continue to package dry edible beans in a retail size package.  The popcorn line will be gone by June 16 while our unannounced audit window starts August 15, 2025.  With that being said - the BRC book for our company will need to be updated with the removal of all the popcorn info including the HACCP plan, flow charts, etc.  

My question is - what can be audited during the audit?  Just the bean line or can any of the popcorn information be audited also?

Our scope will include only the dry edible bean line packaging and washing and packaging of dry edible beans.

Thanks for your help.

I am not as proficient in BRC as I am SQF, however do know that most auditors are looking at the past year when auditing as far as records are concerned.  I would be keeping all the documentation on hand a readily available for review even with the line being removed.  I would be prepping the certification body as well to let them know that scope of the audit moving forward would be changing to cover all the bases, being transparent and up front through all communications.   The auditor will most likely focus more on the line that is in use in your process as this is what can be physically audited when onsite.    

I agree with NWilson.  I'd get in touch with your certification body explaining the scope is reducing not increasing but also agree that they like to pick a moment or set of records in time from a historical period and look at those.  While the product is gone, the behaviours indicated from the records will remain so it's still valid in my opinion albeit they will only be able to focus on what is currently being packed at the time.

I'd certainly not just offer to show them old packing records from the current product unless they ask for that because it would look like you're hiding something.  Offer both.  

Let the Certification Body know. They will remove the information related to the popcorn from the scope and I see no reason that they would audit it.

Gail Silverman

IQC 

Israel

...

We have undergone some changes at our facility ... will no longer be making a finished ready to eat popcorn product.  ... The popcorn line will be gone by June 16 while our unannounced audit window starts August 15, 2025.  ...My question is - what can be audited during the audit?  ... any of the popcorn information be audited also?

...

Think of it a bit like verifying a metal detector, if you made product past the last check but are no longer currently still making it, you still need to perform another verification on it to confirm what has been made since the last one was done according to the designated methods.  

Auditors for renewal are usually interested in everything that has happened since the last audit, not just what will be done in the future.  During the opening meeting you can describe the change that occurred to help them understand why processes that are no longer present are going to be seen in the records.

I think you find most auditors are pragmatic until it looks like you're trying to keep something from them.  Then they get suspicious...  So offer anything they want to look at and I bet you they will still focus far more on the line that will be there going forward.

I think you find most auditors are pragmatic until it looks like you're trying to keep something from them.  Then they get suspicious...  So offer anything they want to look at and I bet you they will still focus far more on the line that will be there going forward.

All solid advice, and I double agree with GMO.  You were operating that line under the previous scope, so all relevant records are in play when they're reviewing the prior year.  Don't go around immediately deep shelving all the records, this would be a prime case where they'll poke at just to see if you can readily produce them as required during the audit.  But other than some cursory glances at the retired product records and checking to see how exactly your decommissioning plan went, they're likely going to quickly move on to the existing product and scope.

If you removed equipment entirely, they might ask how.  If you moved old equipment into your storage racks in the warehouse area to keep for some other use or whatever, they're going to want to see it on hold or otherwise denoted as inoperative.  When my auditors see equipment covered and wrapped in storage, they're drawn to it like a moth to a flame and very particular about how employees know not to go plug it in and run it without a wash.  And always eager to hit you with an NC if it's covered in dust.