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cazyncymru

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Posted 24 August 2007 - 04:00 PM

Today i have had two customers contact me with regards to carrying out an audit.

Neither of them will accept my BRC Certification Bodies report and thus i must waste 2 more days going over old ground to satisfy these people, and at a cost that is comparable to the cost of my BRC!!

Interstingly, both of the customers employ the services of a different BRC CB in order to carry out their audits.


Sour Grapes anyone????? ;)



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Posted 26 August 2007 - 09:25 PM

Today i have had two customers contact me with regards to carrying out an audit.

Neither of them will accept my BRC Certification Bodies report and thus i must waste 2 more days going over old ground to satisfy these people, and at a cost that is comparable to the cost of my BRC!!

Interstingly, both of the customers employ the services of a different BRC CB in order to carry out their audits.
Sour Grapes anyone????? ;)

Pain in the A!@ Caz?

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Posted 27 August 2007 - 08:32 AM

Dear Caz,

That´s quite intresting as I thought those standards should prevent the companys from multi audits but obvouisly it didn´t work. I think the BRC did a mistake in this point: there is no contract between their certification bodies and the owner of the standard so every customer can demand on an audit from their auditor (wich of course they do :angry: )
In my opinion this hasn´t got to do anything with food safety anymore, it´s just for tormenting the companys.

So what about the GFSI slogan: "Certified once - accepted everywhere"???
It doesn´t even work within one standard

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Posted 27 August 2007 - 08:23 PM

So what about the GFSI slogan: "Certified once - accepted everywhere"???
It doesn´t even work within one standard

It is a very good point. This is a growing problem. What can / should we do about it?

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cazyncymru

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Posted 28 August 2007 - 04:40 PM

It is a very good point. This is a growing problem. What can / should we do about it?



If it wasn't for the likes of the Supermarkets dictating that we had to have BRC i'd say "forget it" (me being polite!)
and i wouldn't bother with any accreditation, yet maintain my quality systems and all its periphery.

I think the whole system has become farcical, each supermarket selecting its own CB and not accepting the findings of another CB. The standard is the same for all of us, so a CB isn't going to find something another CB isn't looking for!

I think we should canvas BRC themselves and tell them whats going on, i bet i'm not the only person who has these views :(
(i feel a poll coming along simon!)

C x


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Posted 30 August 2007 - 01:32 PM

If it wasn't for the likes of the Supermarkets dictating that we had to have BRC i'd say "forget it" (me being polite!)
and i wouldn't bother with any accreditation, yet maintain my quality systems and all its periphery.


I agree.
Of cource producers have to watch out for quality and it could help if there are some guidelines saying how to ensure safe products. But all this certification stuff gives not a guarantee that a product is really safe because if there are producers who wants to break the rules they do it no matter if their are certificated or not. I mean an auditor can´t see if they are "cheating" ,they won´t admit it.
e.g that discussion in Germany with that old mead that had been sold: how is an auditor supposed to see how long this meat has been stored frozen before it´s getting sold as fresh meat. The meat doesn´t look bad or smell wrong. Only microbiological test discovered that the meat was old. But the auditor hands out the certificate and the consumers has been tricked, though.

But it´s the honest producer who has to suffer under the bureaucracy of the standard owners

But that´s only my opinion, which don´t has to mean much as I´m not an expert

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Posted 30 August 2007 - 02:59 PM

Dear All,

It is a very good point. This is a growing problem.

Sorry to be a Doubting Thomas but any further evidence ?

I wouldn’t know about all this CB manoueverings but the UK customer who represent my single experience in this respect simply require suppliers to get "BRC" to enable them to not have to carry out a detailed audit themselves. Period. As based on the earlier versions of BRC I found this a reasonable request. My personal criticism of BRC is the increasing complexity / frequency of their language / requirements (I used to reserve these words primarily for ISO!) and I deduce IFS are going the same way.

I also think you have to remember the driving force from the “due diligence” factor in UK. I don’t know if this exists the same in Germany, EU in general ?

Rgds / Charles.C

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Posted 31 August 2007 - 01:23 PM

I also think you have to remember the driving force from the “due diligence” factor in UK. I don’t know if this exists the same in Germany, EU in general ?


What do you mean with "due diligence"?
There are a lot of laws concerning food safety and I know that the EU has made instroductions about hygiene in food producing and converting industry (e.g. 178_2002 Basis VO)

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Posted 01 September 2007 - 08:19 AM

Not sure if "due diligence" was just in the UK 1990 Food Safety Act. Anyway there is evidence (I've seen and heard it) of both retailers and large food producers requiring BRC audits to be undertaken by their named Certification Body. If the supplier was not agreeable they would be subject to an audit by them and would have to pay the associated costs. The reason is that these particular companies did not trust the audits carried out by other CB's and / or they would get increased consistency and control over their supplier base. Either way it is wrong; and it’s up to the likes of BRC and UKAS to sort it out.

I would be happy to forward a petition to either of the above if someone wanted to put something together (with evidence).


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Posted 01 September 2007 - 10:24 AM

Dear Chac,

“Due Diligence” is a concept used in relationship to the UK Food Law. Am definitely no expert here (see below) but if I understand it correctly, it acts as a very strong incentive to ensure that both manufacturers and importers (carry out) / (verify the carrying out of) various activities so as to ensure a safe food supply. Conceptually I deduce that it effectively compels the trade to perform some control functions which might elsewhere (Germany ??) be carried out by official bodies (any UK specialists, please correct me if I’m wrong here). I’ve extracted a few more authoritative comments below which should explain it much clearer.

1. - The principal defence for a person alleged to have committed an offence under The Food Safety Act 1990 is known as “Due Diligence”.
"Due Diligence” is a defence allowed under the Act, it is not compulsory or a statutory requirement.
This enables someone to be acquitted of an offence if they prove that they "took ALL reasonable precautions and exercised ALL due diligence" to avoid committing the offence.
Earlier food law allowed a written warranty to the effect that the goods complied with all relevant legislation, to be pleaded as a defence. A written warranty is no longer a defence in itself. However it might still form part of a "due diligence" defence.
It is therefore, good practice to have a control system in place to cover *all aspects of the operation of the business which concerns compliance with food standards requirements.
* [A system which is adequate to control foreign bodies in food will not ensure that compositional requirements are met for example].
Taking reasonable precautions involves the setting up of a control system having regard to the nature of the risks involved.
Due diligence involves securing the proper operation of that system.
The system should address the following points:
• raw materials.
• production.
• recipe, specifications, or compliance with compositional standards.
• packing and storage.
• labelling and advertising.
• packaging.
• monitoring complaints.
• record keeping.
• training.
Note: This list is not exhaustive.
The operation of the system must be kept under review and amended as necessary.
There must be adequate liaison with manufacturers, packers and suppliers on matters relating to legislative or other changes in requirements for product specification.
These notes are for guidance only and do not represent an authoritative interpretation of the law which can only be given by the Courts.
More information/Disclaimer ………………….

http://www.leics.gov...ity_control.htm



2.“To be fully compliant with legislation, food businesses need a documented Food Safety Management System. Not only is this useful in food safety management, but it can form a crucial part of your defence in the unfortunate event of legal action being taken against you or your company.
"Due diligence defence" (Food Safety Act 1990, Food & Environment Protection Act 1985)
It is a defence for any person charged with an offence under either act to prove that he took ‘all reasonable precautions and exercised all due diligence’ to avoid the commission of the offence. The burden of proving the defence, on the balance of probability, falls on the defendant.”
http://sentinelsafet...ood-safety.html



3. “The UK, as a member of the European Union (EU), conforms to all EU Directives, Regulations and obligations. We therefore recommend that this report is read in conjunction with the Food and Agricultural Import Regulations and Standards (FAIRS) report produced by the U.S. Mission to the EU in Brussels, Belgium - Report Number: E29117.
Available at through FAS Online Reports - use the Search function at: http://www.fas.usda....rep/default.asp
The vast majority of food laws of the EU member countries have already been fully harmonized into EU law. Where EU regulatory harmonization is not yet complete, imported product must meet existing UK requirements. Areas which are yet to be harmonized include materials in contact with food and foods for particular nutritional uses.
Based on the EU single market principle, all food products legally imported and distributed in one member country of the EU can also be distributed in all other member countries, except in those cases when a country can prove health concerns about the product intended for import.
The marketing and sale of foodstuffs in the United Kingdom (UK) is governed by the Food Safety Act 1990. The Act makes it an offence for anyone to sell, or possess for sale, food which:
has been rendered injurious to health
is unfit or so contaminated that it would be unreasonable to expect it to be eaten
is falsely described, advertised or presented
is not of the nature, substance or quality demanded

The Act addresses inspection, detention and seizure of suspect food, food hygiene inspections and, more relevant for UK domestic production, powers to make prohibition notices to stop a UK factory production. Imported foods can be inspected for safety at any point in the distribution chain, port of entry (by Port Health officials), retail, foodservice or wholesale level (by Trading Standards Officers).
The Act also makes for the defense of "due diligence". In practice, this means that a UK importer, faced with a legal action involving a U.S. product which contravenes the requirements listed above, must show that they took "all reasonable precautions" and exercised all "due diligence" to avoid committing an offence. This, in effect, makes traceability of the product supply chain and its ingredients very important.”
http://london.usemba...s/food_laws.htm



4. The BRC website has this -

“Developed by the BRC (the British Retail Consortium, a UK trade organization that represents the interests of the UK retailers), the BRC Global Standard - Food, was created to establish a standard for the supply of food products and to act as key piece of evidence for UK retailers and brand owners to demonstrate ‘due diligence’ in the face of potential prosecution by the enforcement authorities.
The standard is being adopted by food suppliers throughout the world and especially for those organizations supplying British retailers. Certification to the standard helps manufacturers, brand owners and retailers fulfill their legal obligations whilst ultimately safeguarding the consumer. The standard possesses a comprehensive scope covering all areas of product safety and legality and addresses part of the due diligence requirements of both the supplier and the retailer.
Who is it for?
Particularly suitable for any suppliers, regardless of product or country of origin, that supply food product to the UK retailers. Indeed, many UK retailers recommend that their food product suppliers meet the requirements of the BRC Global Standard - Food.”
http://www.brc.org.u...subsection_id=2

(the word “recommend” in last paragraph is a rather polite understatement of course!)

Hope the above helps a bit. There is also an old forum thread on this topic - http://www.ifsqn.com...?showtopic=1373


Rgds / Charles.C


Kind Regards,

 

Charles.C


Chac

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Posted 04 September 2007 - 11:26 AM

Dear Charles,

In Germany there is a similiar system in the business. There is a different meaning of due diligence in German laws. Somehow it's not enough to prove that you have done anything possible, it's only enough to show that it wasn't your fault (sorry, I don't understand exactly what is meant with that so I cannot explain it more closely here)
I didn't heard it in connection with food industry, though.

This whole system sounds a little bit suspiscious to me. How is it possible that a producer who causes seriously demage to health can get away with that just because they can prove that they have done anything possible to prevent this?


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Posted 04 September 2007 - 09:36 PM

Dear Chac,

Good question which I suspect does not have a simple answer (ie I don’t know). Similar issues exist in the medical profession, etc etc.

It must be an interesting job to evaluate such cases.

Eg Got ISO ? Got HACCP ? Got Insurance ??

Rgds / Charles.C


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Posted 24 September 2007 - 06:39 PM

Hi,
we have BRC grade B, and id say over the last 3 months i have had about 5 customer audits, not small audits but full days audits!!!! i asked the last potential customer who audited us as to why they they needed to conduct in depth audits if we had BRC? He said that anyone who wishes to supply them must have grade A, anyone not with Grade A will be subject to their audit, he also commented on the amount of factories they audit and have grades B/C etc and that they find loads of non conformances and they cant understand how some of these factories have BRC at all!!! I have also come across another customer who wont take our BRC because the certification body isnt on their 'approved list of certificating bodies', if it was just up to me I wouldnt bother with BRC but would just continue having all the systems etc in place, the stress prior & during the audits are unbearable!!!! and mines due soon!!!!!!!!



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Posted 25 September 2007 - 08:19 AM

we have BRC grade B, and id say over the last 3 months i have had about 5 customer audits, not small audits but full days audits!!!! i asked the last potential customer who audited us as to why they they needed to conduct in depth audits if we had BRC? He said that anyone who wishes to supply them must have grade A, anyone not with Grade A will be subject to their audit, he also commented on the amount of factories they audit and have grades B/C etc and that they find loads of non conformances and they cant understand how some of these factories have BRC at all!!! I have also come across another customer who wont take our BRC because the certification body isnt on their 'approved list of certificating bodies', if it was just up to me I wouldnt bother with BRC but would just continue having all the systems etc in place, the stress prior & during the audits are unbearable!!!! and mines due soon!!!!!!!!


All of those involved with BRC Certification should be very concerned with this kind of information. If companies who do not meet the requirements of the Standard are getting certified – the certification process is broken…and it needs fixing ASAP.

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Posted 26 September 2007 - 03:19 PM

Dear Simon,

All of those involved with BRC Certification should be very concerned with this kind of information. If companies who do not meet the requirements of the Standard are getting certified – the certification process is broken…and it needs fixing ASAP.


It used to be called the ISO9000 song. new name but sameO-sameO.

Rgds / Charles.C

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Posted 27 September 2007 - 06:51 AM

Interesting problem which I suspect is becoming increasingly common. In fairness to the BRC auditors they are looking for evidence of conformance to the BRC standard whereas a customer is looking for evidence of conformance of the BRC system to their specific products i.e the scope of the sampling exercise is now more narrower. Once you drill down, the potential for finding non conformance's is much greater.

I think the other issue is that you cannot carry out an effective food safety audit by spending an hour in a factory and then 10 hours in an office pouring over paperwork - the balance is all wrong. (Apologies if this point has already been discussed at length elsewhere).

Effective quality systems auditing requires spending far more time on the factory floor looking for more detailed evidence of the application of the quality system in situ. e.g an effective appraisal of training requires observing and talking to people who are doing the job on the factory floor and not looking to a see if their signature is on a piece of paper in the office. In my experience auditors from customers tend to spend far more time on the factory floor. Haccp prerequisites and the haccp plan itself are better followed in detail on the factory floor but this takes far more time on the production lines.

I think there is too much emphasis on having the right pieces of paper in place for the audit which is not the same as having an effective food safety management system in place!

Perhaps there is also a difference between the supermarket expectations of the BRC standard and how the standard can be applied and audited by third party certification companies within the time allocated for each audit?


Edited by Ken, 27 September 2007 - 06:53 AM.


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Posted 27 September 2007 - 07:42 AM

Interesting problem which I suspect is becoming increasingly common. In fairness to the BRC auditors they are looking for evidence of conformance to the BRC standard whereas a customer is looking for evidence of conformance of the BRC system to their specific products i.e the scope of the sampling exercise is now more narrower. Once you drill down, the potential for finding non conformance's is much greater.

Hi Ken, nice to hear from you. A question. Does the BRC Food have a requirement such as 3.1.2 in BRC Packaging, or does that not apply here?

I think the other issue is that you cannot carry out an effective food safety audit by spending an hour in a factory and then 10 hours in an office pouring over paperwork - the balance is all wrong. (Apologies if this point has already been discussed at length elsewhere).

It hasn’t and I agree wholeheartedly. There is a huge amount to get through during BRC audits. Unlike with an ISO 9000 Audit with a BRC Audit every clause of the standard has to be covered, which of course limits the drill down into the detail. We all know what can be found in the detail. :whistle:

Thanks for your comments Ken, they provide a different perspective and give some credit for the difficult task with which CB’s have to contend. This time pressure allied with the undoubted skulduggery that exists in all commercial spheres are causing inconsistencies in the quality of auditing and therefore the certification process. Obviously, customers who use BRC Certified suppliers are uncovering this problem.

But what to do? :dunno:

Regards,
Simon

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Posted 28 September 2007 - 08:05 AM

Not sure if "due diligence" was just in the UK 1990 Food Safety Act. Anyway there is evidence (I've seen and heard it) of both retailers and large food producers requiring BRC audits to be undertaken by their named Certification Body. If the supplier was not agreeable they would be subject to an audit by them and would have to pay the associated costs. The reason is that these particular companies did not trust the audits carried out by other CB's and / or they would get increased consistency and control over their supplier base. Either way it is wrong; and it’s up to the likes of BRC and UKAS to sort it out.

I would be happy to forward a petition to either of the above if someone wanted to put something together (with evidence).



Well Spar insist on Micron 2
Uniq insist on National Britannia
Aldi / Lidl use Bodycote

Coop, Tesco etc etc don't mind who you use, they audit anyway!!!! :rolleyes:


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Posted 28 September 2007 - 03:46 PM

Well we've just had our BRC, and passed with grade A, 3 tiny tiny minors!!
the auditor said there is a new standard on the way and lots of changes!!! MORE WORK!!!
Anyway i can relax again for a bit till another customer wants to audit us!!!
:rolleyes:



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Posted 30 September 2007 - 08:25 PM

Well Spar insist on Micron 2
Uniq insist on National Britannia
Aldi / Lidl use Bodycote

Coop, Tesco etc etc don't mind who you use, they audit anyway!!!! :rolleyes:

It really is a joke.

Well we've just had our BRC, and passed with grade A, 3 tiny tiny minors!!
the auditor said there is a new standard on the way and lots of changes!!! MORE WORK!!!
Anyway i can relax again for a bit till another customer wants to audit us!!!
:rolleyes:

Well done Sue, put your feet up for a little while. Tuesday. :biggrin:

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Posted 10 October 2007 - 06:58 AM

From my experience and it does not matter what standard you are adhereing to the major issue is the quality of the auditor that is of major concern.(I apologise to everyone if this has been covered elsewhere). I have been an auditor in the past so know how daunting the task can be and I agree you are only scrtaching the surface, but it should be fairly obviuos whether the system is sustainable or it is managed by one person.
When I have been in production Quality Assurance my policy for the quality system is it is something that is part of every day life and we did not run around like a crazy person in the weeks preceeding audits making sure everything was right. We did a quick review of approx 1-2 hours to check things look okay but we were doing this regulary as the system is there to ensure Food Safety and Quality not to satify an auditor.We wanted the audit to be a tool for us as an external review of the system.

Now don't get me wrong I am not advocating multiple audits as this is a waste of time and a very expensive excerise. We had multiple customer audits and Council audits against multiple standards and the same and there would always be different things highlighted. We had instances where audits occured with in the same week and as you all know most standards have the same criteria just badged under a different name.

Any thoughts on this :wtg:

Ideas are like rabbits. You get a couple, learn how to look after them, and pretty soon you have a dozen. John Steinbeck


Edited by Aussie Deb, 10 October 2007 - 07:00 AM.


MartLgn

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Posted 10 October 2007 - 10:07 AM

When I have been in production Quality Assurance my policy for the quality system is it is something that is part of every day life and we did not run around like a crazy person in the weeks preceeding audits making sure everything was right. We did a quick review of approx 1-2 hours to check things look okay but we were doing this regulary as the system is there to ensure Food Safety and Quality not to satify an auditor.We wanted the audit to be a tool for us as an external review of the system.


Hi Deb . :welcome:

Thats a very good approach to an audit and one that we try to take ( not always with total success), it is always useful to have an external viewpoint on what you are doing and how successful you are at implementing your systems. A review of any food safety incidents/customer complaints can be a very powerful indicator of how well your FSMS is working just as effectively as any auditors report.

Why put off until tomorrow that which you can avoid doing altogether ?

Charles.C

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Posted 15 October 2007 - 04:07 PM

Dear Aussie Deb,

We wanted the audit to be a tool for us as an external review of the system.


I fear that this is a very generous viewpoint regarding the potential benefit of auditors.

I would suggest that for most factories, they fall somewhere between "a large pain in the lower regions" and the "Ultimate Enemy". I have also seen both sides of the fence and frankly often felt equally uncomfortable in both functions although I agree with you that it is often rapidly clear as to the general condition of an audited establishment. It is surprising that there are no bestsellers (I think) in a category such as "Strangest Factories I have Ever Seen". :smile:

I know, getting a bit OT again, but I'm only reinforcing the thread topic - there are simply too many audits taking place - perhaps the "ideas" are like rabbits should be replaced by "auditors". :whistle:

Rgds / Charles.C

PS- Despite my doubts, yr contribution is highy welcomed of course :thumbup:

Kind Regards,

 

Charles.C


Jarve

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Posted 23 October 2007 - 12:27 PM

In response to the original question "is it worth it?" I would say that having BRC accreditation is much more of a "flag waving" opportunity these days, because regardless of the grade achieved most of the major customers will still come and audit sites anyway.

Because I changed jobs and manufacturing sectors earlier this year, I have been audited three times at three different sites, achieving grade "A" at all of them - even though at one particular site I realised that what was being labelled at the time of the audit was completely wrong and actually illegal, but it wasn't picked up and had been standard practise for at least five years - we only had one minor NCR as a result of this audit! (however I must admit my heart was in my mouth for a while).

Personally I would rather not have the accreditation, and throw my doors open to all that want to come and see us, however my MD would probably view things much differently. <_<



Cathy

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Posted 17 September 2008 - 12:29 PM

In the U.S. companies are moving toward requiring a GFSI accepted audit - typically either BRC or SQF. Recently two supermarket retail chains have decided to not accept BRC. This is unfortunate since the standards are supposed to be equivalent. I wish that such decsions could be sent to the folks involved in the GFSI and that they would intervene to reduce the number of audits going on.


Cathy Crawford, HACCP Consulting Group
http://haccpcg.com/



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