BRC Agents and Brokers Standard
BRC Agents and Brokers Standard
BRC Agents and Brokers Standard
ISBN 978-0-11-708237-3
9 780117 082373
January 2014
www.tso.co.uk
Issue 1
21/11/2013 08:52
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Liability
BRC publish information and express opinions in good faith, but accept no liability for any error or omission in any such information or
opinion including any information or opinion contained in this document.
Whilst the BRC have endeavoured to ensure that the information in this publication is accurate, they shall not be liable for any damages
(including without limitation damages for pure economic loss or loss of business or loss of profits or depletion of goodwill or otherwise
in each case, whether direct, indirect or consequential, or any claims for consequential compensation whatsoever (howsoever caused)
arising in contract, tort (including negligence or breach of statutory duty), misrepresentation, restitution or otherwise, in connection with
this publication or any information contained in it, or from any action or decision taken as a result of reading this publication or any such
information.
All warranties, conditions and other terms implied by statute or common law are, to the fullest extent permitted by law, excluded.
Nothing excludes or limits the liability of BRC for death or personal injury caused by their negligence, for fraud or fraudulent
misrepresentation or for any matter which it would be illegal for them to exclude or attempt to exclude liability for.
The Global Standard for Agents and Brokers and the terms of the disclaimer set out above shall be construed in accordance with English
law and shall be subject to the non-exclusive jurisdiction of the English Courts.
Copyright
British Retail Consortium 2014
ISBN 9780117082373
All rights reserved. No part of this publication may be transmitted or reproduced in any form (including photocopying or storage in any
medium by electronic means) without the written permission of the copyright owner. Application for permission should be addressed to
the Commercial Director of Global Standards at the British Retail Consortium, contact details below. Full acknowledgement of author and
source must be given.
No part of this publication may be translated without the written permission of the copyright owner.
Warning: Any unauthorised act in relation to a copyright work may result in both a civil claim for damages and criminal prosecution.
For more information about BRC, contact
British Retail Consortium
Second Floor
21 Dartmouth Street
London
SW1H 9BP
Tel: +44 (0) 20 7854 8900
Fax: +44 (0) 20 7854 8901
email: [email protected]
website: www.brcglobalstandards.com
Printed in the United Kingdom for The Stationery Office
J002814442 C5 02/14 35841 19585
BRC
iii
Contents
Section 1 Introduction
1
Background
2.1
2.2
2.3
5.1
5.2
5.3
A hazard-and-risk-analysis-based system
5.4
Section II Requirements
Introduction to the Requirements
iv
7
9
Non-applicable clauses
10
1.1
10
1.2
11
12
14
3.1
14
3.2
Documentation control
14
3.3
14
3.4
15
BRC
3.5
Internal audit
15
3.6
16
3.7
Traceability
16
3.8
Complaint handling
17
3.9
Corrective action
17
18
19
20
4.1
20
4.2
21
4.3
21
4.4
22
4.5
Product legality
22
4.6
Product design/development
23
4.7
Product release
23
Personnel
24
5.1
24
25
Introduction
27
27
27
29
4.1
29
Registration fee
Scope of Audit
29
5.1
29
5.2
29
5.3
29
5.4
Extension to scope
30
5.5
Auditor selection
30
Audit Planning
31
6.1
31
6.2
31
6.3
31
BRC
32
32
8.1
Non-conformities
32
8.2
33
Audit Reporting
34
10
Certification
35
11
BRC Logos
35
12
35
12.1 Introduction
35
36
13
36
14
36
36
37
37
15
37
16
Appeals
38
39
41
43
2.1
43
2.2
43
2.3
44
44
3.1
Calibrating auditors
44
3.2
Feedback
44
3.3
44
Appendices
Appendix 1
vi
47
Appendix 2
48
Appendix 3
Product Categories
50
Appendix 4
Certificate Template
53
Appendix 5
54
Appendix 6
Glossary
55
Appendix 7
Acknowledgements
60
BRC
Section I Introduction
SECTION I
INTRODUCTION
BRC
BRC
Section I Introduction
Section I
Introduction
1
Background
Welcome to the first issue of the Global Standard for Agents and Brokers (the Standard). The Standard has
been developed to provide a framework to manage product safety, quality and legality for businesses in the
food and food packaging industries which buy, sell or facilitate the trade of products. These companies play
an essential role in the movement and trade of products, providing a critical link in their chain of custody.
They can influence product safety and quality standards at their suppliers and are responsible for maintaining
an effective chain of traceability. Where activities include importation there are in many cases specific legal
obligations with regard to the products which they import and requirements to maintain records which may
later be requested by authorities or customers.
There have been many requests for a global standard to be produced to cover this sector, both from the
industry and from retailers, food service companies and manufacturers purchasing from these companies.
Certification against the BRC global standards is recognised by many retailers, food service companies and
manufacturers around the world when assessing the capabilities of their suppliers. This Global Standard has
been developed to specify the safety, quality and operational criteria required to fulfil obligations with regard
to legal compliance and protection of the consumer. The format and content of the Standard is designed to
allow an assessment of a companys product safety management systems and procedures by a competent
third party the certification body against the requirements of the Standard.
The Global Standard for Agents and Brokers sets out the requirements for companies in the food and/or
food packaging supply chain that provide services for the purchase, importation or distribution of products.
The companies may also own their own processing, storage or distribution facilities but these facilities are
certificated to relevant production or storage and distribution standards.
The scope of certification shall cover all applicable operations at the office certificated.
2.1
The Standard has a scope which is limited to product safety, quality and legality.
It defines requirements for the systems of operation and services to ensure this.
The Standard does not cover other activities such as environmental, ethical or financial arrangements which
may be covered by other certification schemes.
2.2
Brokers companies that purchase or take title to products for resale to manufacturers, other brokers,
retailers or food service companies but not directly to the consumer.
Importers/exporters companies that facilitate the movement of products across national boundaries,
satisfying legal and customs requirements. Importers and exporters may also be agents and/or brokers.
BRC
Where the companies offering these services also own their own manufacturing or storage or distribution
facilities, these facilities may be certificated against the relevant BRC global standard.
2.3
The Standard has a scope which covers certification for the following categories of products:
food products, including raw materials, processed foods, and fruit and vegetables
food packaging materials primary, secondary and tertiary materials, and raw materials for the
manufacture of packaging materials
consumer products
livestock.
The BRC has developed a range of global standards which set out the requirements for the manufacture of
food and consumer products, the packaging used to protect the products, and the storage and distribution
of these products. The other BRC standards complement the Global Standard for Agents and Brokers and
provide a standard for the auditing and certification of suppliers.
The BRC Global Standard for Food Safety is a certification standard for the manufacture and packing of food
and drink products. It sets out requirements based on the HACCP (Hazard Analysis and Critical Control Point)
system, good manufacturing practice and supporting quality management systems. The Standard is Global
Food Safety Initiative (GFSI) benchmarked.
The BRC Global Standard for Packaging and Packaging Materials is a GFSI-benchmarked certification standard
that lays down the requirements for the manufacturing of packaging materials used for food and consumer
products. Food and non-food businesses may request this from their suppliers of packaging.
The BRC Global Standard for Storage and Distribution is a certification standard that sets out the
requirements for the storage, distribution, wholesaling and contracted services for packaged food products,
packaging materials and consumer goods. The standard is not applicable to storage facilities under the direct
control of the production facility management, which are covered by the relevant manufacturing standard,
e.g. the Global Standard for Food Safety.
The BRC Global Standard for Consumer Products is a certification standard applicable to the manufacture and
assembly of consumer products. This specifically excludes food-associated products such as vitamins, minerals
and herbal supplements, which fall within the scope of the BRC Global Standard for Food Safety.
The Standard is intended to assist companies and their customers in meeting the legislative requirements for
food safety. Legislation covering food safety differs in detail worldwide but generally requires food businesses
to:
ensure the presence of a detailed specification which is lawful and consistent with compositional and
safety standards for the products concerned and follows good manufacturing practice
ensure they satisfy themselves that their suppliers are competent to produce the specified product,
comply with legal requirements and operate appropriate systems of management control
verify the competence of their suppliers or receive the result of any other audit of the suppliers system at
a frequency based on risk
BRC
establish and maintain a risk-assessed programme for product examination, testing or analysis
Section I Introduction
This Standard has been developed to support companies and their customers to meet these requirements.
Whilst legislative requirements for packaging materials will differ, similar principles are often adopted
particularly where packaging will be supplied to the food industry.
5.1
The company must have a full understanding of the products being traded or covered by the services
provided and have systems in place to identify and control hazards significant to the safety, legality or quality
of the products. The Global Standard for Agents and Brokers is based on three key components: senior
management commitment; hazard and risk analysis a step-by-step approach to managing product safety
risks; and supplier and subcontracted service management.
5.2
The effective and consistent achievement of product safety requires this to be recognised as a shared
responsibility for all personnel within the business. Product safety management extends beyond technical
departments and must involve commitment from the full management team, including procurement, logistics
and sales.
The starting point for an effective product safety plan is the commitment of senior management to the
development of an all-encompassing policy as a means to guide the activities that collectively assure
product safety. The Global Standard for Agents and Brokers places a high priority on clear evidence of senior
management commitment.
5.3
A hazard-and-risk-analysis-based system
The Standard requires the development of a product safety plan covering the services/operations which the
company manages or specifies and based on the principles of hazard and risk analysis. The development of
the plan requires the input of all relevant departments and must be supported by senior management.
5.4
The Standard is intended to provide assurance to customers of the management of product safety risks as
products pass through the supply chain. A risk-based process is taken to ensure that products are produced
by approved manufacturers following agreed specifications with a traceable and transparent supply chain.
The selection and management of product manufacturers, subcontractors and service providers is key to the
management of risk.
The Global Standard for Agents and Brokers is a service certification scheme. In this scheme, businesses are
certificated upon completion of a satisfactory audit by an auditor deployed by an independent third party
the certification body. The certification body in turn shall have been assessed and accredited by a national
accreditation body to ISO/IEC 17065.
In order for a business to receive a valid certificate on completion of a satisfactory audit, the organisation
must select a certification body approved by the BRC. The BRC lays down detailed requirements that a
certification body must satisfy in order to gain approval. Approved certification bodies are listed in the BRC
Directory at www.brcdirectory.com
BRC
There are a number of benefits to companies arising from the adoption of the BRC global standards. The BRC
global standards:
are internationally recognised and provide a report and certification that can be accepted by customers
in place of their own audits, reducing time and cost
provide a single standard and protocol that govern an accredited audit by third-party certification bodies,
allowing a credible independent assessment of a companys product safety and quality management
systems
allow certificated companies to appear in the BRC public directory, providing recognition of their
achievements and use of a logo for marketing purposes
are comprehensive in scope, covering areas of product safety, legal compliance and quality
provide potential customers with confidence in the services provided, thereby facilitating trade
are designed to support compliance with regulatory requirements being proposed in the US Food Safety
Modernisation Act and EU legislative requirements
require ongoing surveillance and confirmation of the follow-up of corrective actions on non-conformity
to the Standard, thus ensuring that a self-improving quality and product safety system is established.
The BRC wishes to acknowledge all those food industry experts who have contributed to the preparation
of Issue 1 of the Global Standard for Agents and Brokers. A list of those who have contributed to the
development of the Standard can be found in Appendix 7.
BRC
Section II Requirements
SECTION II
REQUIREMENTS
BRC
BRC
Section II Requirements
Section II
Requirements
Introduction to the Requirements
The format of the Standard
Each clause of the Standard begins with a highlighted paragraph in bold text, the
statement of intent. This sets out the expected outcome of compliance with the
particular clause. This forms part of the audit and all companies must comply with the
statement of intent.
Below this statement of intent, set out in a tabular format, are specific requirements which, if applied
appropriately, will help to achieve the stated objective of the clause. The requirements shall form part of the
audit and must be complied with, where applicable, in order for a certificate to be issued.
Non-applicable clauses
The requirements section of the Standard is based on good industry practice, such that certificated companies
are able to demonstrate to customers their commitment, a structured approach to managing product safety
and a controlling influence over the safety, legality and quality of the products covered by their services.
It is recognised, however, that the activities and services provided by brokers and agents or nonmanufacturing service providers may vary considerably and that some of the services included within this
Standard may not be offered by all companies applying for certification. Such services will be considered to
be non-applicable and certification can still be provided on the basis of compliance with the remainder of the
applicable requirements.
To ensure consistent understanding and application of the Standard, the sections which may be classified
as non-applicable are identified by the absence of background shading behind the statement of intent. For
example:
BRC
1
1.1
The companys senior management shall demonstrate that they are fully committed
to the implementation of the requirements of the Global Standard for Agents and
Brokers and to the operation of processes which facilitate continual improvement of
their product safety and quality management services.
Clause
Requirements
1.1.1
The company shall have a documented policy which states the companys intention to meet
its obligation to supply safe and legal products to the specified quality, and its responsibility
to its customers. This shall be:
signed by the person with overall responsibility for the company
communicated to all staff.
1.1.2
The companys senior management shall ensure that clear objectives are defined to maintain
and improve the services ensuring product safety, legality and quality in accordance with the
quality policy and this standard. These objectives shall be:
documented and include targets or clear measures of success
clearly communicated to relevant staff
monitored and results reported at least six-monthly to company senior management.
1.1.3
10
1.1.4
The company shall have a demonstrable system which ensures that significant product
safety, legality and quality issues are brought to the attention of senior management.
1.1.5
The companys senior management shall provide the resources required to ensure the
product safety, legality and specified quality of products supplied in compliance with the
requirements of this Standard and the companys customers.
1.1.6
The companys senior management shall have a system in place to ensure that the company
is kept informed of any emerging product safety, quality or legality issues, industry codes of
practice and all relevant legislation applicable in the country where the product is intended
to be sold.
BRC
Section II Requirements
Clause
Requirements
1.1.7
Where required by legislation, the company shall be registered with, or be approved by, the
appropriate authority.
1.1.8
The company shall have a genuine, original hard copy or electronic version of the current
Standard available.
1.1.9
Where the company is certificated to the Standard, it shall ensure that recertification audits
occur on or before the audit due date indicated on the certificate.
1.1.10
The opening and closing meetings of the audit for this Standard shall be attended by a
senior manager of the company.
1.1.11
The companys senior management shall ensure that the root cause of non-conformities
identified at the previous audit against the Standard have been effectively addressed to
prevent recurrence.
1.2
The company shall have a clear organisational structure and lines of communication
to enable effective management of services ensuring product safety, legality and
quality.
Clause
Requirements
1.2.1
The company shall have an organisation chart demonstrating the management structure
of the company. The responsibilities for the management of activities that ensure product
safety, legality and quality shall be clearly allocated and understood by the managers
responsible. It shall be clearly documented who deputises in the absence of the responsible
person.
1.2.2
The companys senior management shall ensure that all employees are aware of their
responsibilities. Where documented work instructions exist for activities undertaken, the
relevant employees shall have access to these and be able to demonstrate that work is
carried out in accordance with the instruction.
BRC
11
The company shall operate a product safety plan for the processes for which it is
responsible. This shall be based on the principles of hazard and risk analysis, which
shall be documented, systematic, comprehensive, fully implemented and maintained.
In the food industry these principles are commonly known as HACCP (Hazard Analysis
and Critical Control Point).
Clause
Requirements
2.1
The person responsible for leading the hazard analysis shall be able to demonstrate
competence in the understanding of HACCP principles and their application. Where a team
is used, the team members shall have knowledge of the hazard and risk analysis principles.
In the event of the company not having appropriate in-house knowledge, external expertise
may be sought but the day-to-day management of the system shall remain the responsibility
of the company.
2.2
Where the hazard and risk analysis study has been undertaken centrally, it shall be possible
to demonstrate that the study has been verified to meet the specific activities of the local
operations to which the study applies.
2.3
The hazard analysis, and resulting procedures, shall have senior management commitment,
and shall be implemented through the companys documented management systems.
2.4
The company shall define the scope of the hazard and risk analysis in terms of the products
and services that are included.
This shall include:
a description of the nature of products traded (e.g. canned fish, fresh produce,
corrugated board) and any particular specified storage or handling conditions (e.g.
temperature control requirements, propensity to water damage etc.)
a description of any services provided directly or arranged whilst the product is under the
responsibility of the company.
2.5
A process flow diagram shall be prepared to cover each step in the process from the
purchase or acceptance of responsibility for products to acceptance of the products by the
companys customer. As a guide this should include the following where applicable:
product and supplier approval
importation/export processes
product checks or testing
subcontracted transport or distribution
subcontracted storage of products
processes for damaged or rejected product
any subcontracted processes undertaken on products (e.g. relabelling, further processing).
12
BRC
Section II Requirements
Clause
Requirements
2.6
The company shall identify and record all potential hazards associated with each step of the
product flow. The company shall include consideration of the following types of hazard:
microbiological growth resulting from temperature abuse of products that require
temperature control
physical contamination (e.g. glass contamination, wood splinters from pallets, dust, pests)
chemical or radiological contamination (e.g. pesticides, heavy metals, product tainting)
physical damage (e.g. breakage, puncturing of packaging, water damage)
fraud (e.g. substitution or deliberate adulteration)
malicious contamination of products
allergens
any other hazards mandated by the customer or relevant regulatory authorities.
2.7
The company shall complete a documented risk analysis of the potential hazards in order to
identify which need to be controlled. The following should be considered:
the likely occurrence of the hazard
the severity of the hazard (e.g. injurious to health, potential to cause food poisoning,
rejection or a product recall)
existing prerequisite programmes which effectively prevent or reduce the hazard to
acceptable limits.
2.8
For each hazard which requires control, processes shall be established to ensure that
subcontracted service providers effectively manage their operations to prevent, eliminate or
reduce a significant hazard to acceptable limits. Such processes may include:
specifications and contracts with subcontracted service providers
review of HACCP or hazard and risk management plans operated by service providers to
confirm that the identified hazard is being controlled.
2.8.1
Where controls are managed by HACCP or hazard and risk management plans operated
by service providers, these shall be reviewed by a competent person to determine the
effectiveness of the plans or be within the scope of an accredited certification of the service
provider.
Records shall be maintained to demonstrate the results of the review.
2.9
There shall be effective processes to monitor and verify that the processes operated by
subcontracted service providers are effectively controlling the hazards identified.
2.10
Corrective action plans shall be defined for instances where monitoring identifies a failure of
the controls or where results indicate that products or services are out of specification.
2.11
The hazard and risk analysis shall be formally reviewed at least annually and whenever
new product types are traded (i.e. products which have different characteristics from
the products included within the original study) or where new services/process steps are
introduced.
BRC
13
3
3.1
The companys processes and procedures to meet the requirements of this Standard
shall be documented to allow consistent application, facilitate training, and support
due diligence and supply of a safe product.
Clause
Requirements
3.1.1
The companys documented procedures, working methods and practices shall be collated in
the form of a printed or electronic quality manual.
3.1.2
The quality manual shall be fully implemented and the manual or relevant components shall
be readily available to key staff.
3.1.3
All procedures and work instructions shall be clearly legible, unambiguous, in relevant
languages and sufficiently detailed to enable their correct application by appropriate staff.
3.2
Documentation control
The company shall operate an effective document control system to ensure that only
the correct versions of documents are available and in use.
Clause
Requirements
3.2.1
The company shall have a procedure to manage documents which form part of the quality
system. This shall include:
a list of all controlled documents, indicating the latest version number
the method for the identification and authorisation of controlled documents
a record of the reason for any changes or amendments to documents
the system for the replacement of existing documents when these are updated.
3.3
The company shall maintain genuine records to demonstrate the effective control of
product safety, legality and quality.
14
Clause
Requirements
3.3.1
Records shall be legible, retained in good condition and retrievable. Any alterations to
records shall be authorised and justification for alteration shall be recorded. Where records
are in electronic form, these shall be suitably backed up to prevent loss.
3.3.2
Records shall be retained for a defined period, with consideration given to any legal or
customer requirements and to the shelf life of the product or usage of packaging materials.
This shall take into account, where it is specified on the label, the possibility that shelf life
may be extended by the consumer (e.g. freezing).
3.3.3
Where records are held by third parties, the company shall be able to obtain copies of the
records typically within one working day (e.g. warehouse intake checks).
BRC
3.4
Section II Requirements
The company shall understand and clearly communicate its customers requirements
to relevant suppliers of products and services.
Clause
Requirements
3.4.1
The company shall have a system for identifying whether customers have specific
requirements. Where there are specific customer requirements, these shall be made known
to relevant staff within the company and kept up to date.
3.4.2
3.5
Internal audit
The company shall be able to demonstrate that it verifies the effective application of
its product safety and quality system and the implementation of the requirements of
this Standard.
Clause
Requirements
3.5.1
There shall be a planned programme of internal audits with a scope which covers the
implementation of the product safety and quality management system and procedures
implemented to achieve this Standard. The scope and frequency of the audits shall
be established in relation to the risks associated with the activity and previous audit
performance; all activities shall be covered at least annually.
3.5.2
Internal audits shall be carried out by appropriately trained competent auditors, who are
independent from the audited activity.
3.5.3
The internal audit programme shall be fully implemented. Internal audit reports shall
identify conformity as well as non-conformity and the results shall be reported to the
personnel responsible for the activity audited. Corrective actions and timescales for their
implementation shall be agreed and completion of the actions verified.
BRC
15
3.6
Clause
Requirements
3.6.1
Specifications shall be available for all products. These shall either be in the agreed format of
the customer or, where this is not specified, include key data to meet legal requirements and
assist the customer in the safe usage of the product.
3.6.2
The company shall seek formal agreement of specifications with relevant parties. Where
specifications are not formally agreed, the company shall be able to demonstrate that it has
taken steps to ensure formal agreement is in place.
3.6.3
3.6.4
3.7
Traceability
The company shall be able to trace all product lots back to the last manufacturer and
forward to the customer of the company.
Clause
Requirements
3.7.1
The company shall maintain a traceability system for all batches of product which identifies
the last manufacturer or, in the case of primary agricultural products, the packer or place
of last significant change of the product. Records shall also be maintained to identify the
recipient of each batch of product from the company.
3.7.2
The company shall test the traceability system at least annually to ensure that traceability
can be determined back to the last manufacturer and forwards to the recipient of the
product from the company. This shall include identification of the movement of the product
through the chain from the manufacturer to receipt by the company (e.g. each movement
and intermediate place of storage).
The traceability test shall include the reconciliation of quantities of product received by the
company for the chosen batch or product lot. Traceability should be achievable within four
hours (one day when information is required from external parties).
3.7.3
16
BRC
3.8
Section II Requirements
Complaint handling
Clause
Requirements
3.8.1
All complaints shall be recorded, investigated and the results of the investigation recorded.
Corrective action appropriate to the seriousness and frequency of the problems identified
shall be carried out promptly and effectively.
3.8.2
Complaints arising from the action of a service provider or supplier shall be notified to that
supplier for further investigation.
3.8.3
Complaint data relating to products and services shall be analysed for significant trends
and used to recommend ongoing improvements to product safety, legality and quality, and
to reduce recurrence. Root cause analysis shall be used for serious or frequently occurring
complaints to avoid recurrence.
3.9
Corrective action
The company shall be able to demonstrate that it uses the information from
identified failures in the product safety and quality management system to make
necessary corrections and prevent recurrence.
Clause
Requirements
3.9.1
The company shall have a documented procedure for handling non-conformities identified
within the scope of this Standard, to include:
clear documentation of the non-conformity
assessment of consequences by a suitably competent and authorised person
identification of the corrective action to address the immediate issue
assignment of responsibilities and appropriate timescales to ensure correction
verification that the corrective action has been implemented and is effective
identification of the root cause of significant or recurring non-conformity and
implementation of any necessary action to prevent recurrence.
BRC
17
3.10
Clause
Requirements
3.10.1
There shall be documented procedures for managing products which do not conform to
buying or customer specification. This shall include:
a process for subcontractors handling the product to report potentially non-conforming
product
clear identification of non-conforming product to prevent release, e.g. stock
management IT systems
agreed procedures with subcontractors for secure storage to prevent accidental release
referral to the brand owner where required
defined responsibilities for decision-making on the use or disposal of products
appropriate to the issue, i.e. acceptance by concession, redesignation to an alternative
customer, reworking or destruction
records of the decision on the use or disposal of the product
records of destruction where product is destroyed for product safety reasons.
18
BRC
3.11
Section II Requirements
The company shall have a plan and system in place to effectively manage incidents
and enable the effective withdrawal and recall of products should this be required.
Clause
Requirements
3.11.1
The company shall have clear processes to enable subcontractors to report incidents and
potential emergency situations that impact product safety, legality or quality. The company
shall have procedures and assigned responsibilities for the review of incidents and to define
the appropriate action.
3.11.2
The company shall have a documented product withdrawal and recall procedure. This shall
include as a minimum:
identification of key personnel constituting the recall management team, with clearly
identified responsibilities
guidelines for deciding whether a product needs to be recalled or withdrawn and records
to be maintained
an up-to-date list of key contacts or reference to the location of such a list, e.g. recall
management team, emergency services, suppliers, customers, certification body,
regulatory authority
a communication plan including the provision of information to customers and regulatory
authorities in a timely manner
details of external agencies providing advice and support as necessary, e.g. specialist
laboratories, regulatory authority and legal expertise
a plan to handle the logistics of product traceability, recovery or disposal of affected
product and stock reconciliation.
The procedure shall be capable of being operated at any time.
3.11.3
The product recall and withdrawal procedures shall be tested, at least annually, in a way
that ensures their effective operation. Results of the test shall be retained and shall include
timings of key activities. The results of the test and of any actual recall shall be used to
review the procedure and implement improvements as necessary.
3.11.4
In the event of a product recall, the certification body issuing the current certificate for the
company against this Standard shall be informed within three working days of the decision
to issue a recall.
BRC
19
4
4.1
The company shall operate procedures for approval of the last manufacturer or
packer of products for which it provides a service to ensure that traded products are
safe, legal and manufactured in accordance with any defined product specifications.
Clause
Requirements
4.1.1
The company shall have a documented supplier approval procedure which identifies the
process for initial and ongoing approval of suppliers and the manufacturer/processor of each
product traded. The requirements shall be based on the results of a risk assessment which
shall include consideration of:
the nature of the product and associated risks
customer-specific requirements
legislative requirements in the country of sale or importation of the product
source or country of origin
potential for adulteration or fraud
the brand identity of products, i.e. customer own brand or branded product.
4.1.2
The process for the initial and ongoing approval of the manufacturers of product shall be
based on:
certification of the manufacturing/packing site to the applicable BRC global standards or
other Global Food Safety Initiative (GFSI) benchmarked standard
and/or
supplier audit with a scope to include product safety, traceability testing, HACCP (Hazard
Analysis and Critical Control Point)/hazard and risk management, review and good
manufacturing practices, undertaken by an experienced and demonstrably competent
product safety auditor.
By exception only and where a valid risk-based justification is provided, initial and ongoing
approval may be based on:
legally enforceable warranties from the supplier
a historical trading relationship supported by documented evidence of performance
reviews demonstrating satisfactory performance
a manufacturing-site questionnaire which has been reviewed and verified by a
demonstrably competent person
a specific customer requirement to supply from a manufacturer where liability is with the
customer.
20
4.1.3
4.1.4
BRC
4.2
Section II Requirements
The company shall be able to demonstrate that suppliers of services that are
outsourced have been approved and are managed to ensure that any risks to product
safety have been evaluated and effective controls are in place.
Clause
Requirements
4.2.1
There shall be a documented procedure for the approval and monitoring of suppliers of
services, e.g. transport, storage, laboratory testing, labelling.
The approval process shall be risk-based and shall consider:
risk to product safety and quality
compliance with legal requirements, e.g. weight, label controls
customer-specific requirements
potential risks to the security of the product (food defence, substitution).
4.2.2
The approval process shall be based on one or more of the following options:
certification of the supplier, e.g. BRC global standards or other applicable GFSIbenchmarked standard or applicable ISO standard
supplier audit with a scope to include product safety, traceability testing, hazard analysis
review and good operating practices, undertaken by an experienced and demonstrably
competent product safety auditor
historical performance supported by documented evidence of performance reviews
demonstrating satisfactory performance
supplier questionnaire which has been reviewed and verified by a demonstrably
competent person
licence to operate (e.g. licensed waste management contractor).
4.2.3
Contracts or formal agreements shall exist with the suppliers of services. These shall clearly
specify service requirements and ensure that potential product safety risks associated with
the service have been addressed.
4.2.4
There shall be a formal process of review of service providers, based on risk and using
defined performance criteria, which may include complaints, results of any product tests,
customer rejections or feedback. The process shall be fully implemented.
4.3
Security systems shall ensure that products are protected from theft, substitution or
malicious contamination whilst under the management control of the company.
Clause
Requirements
4.3.1
The company shall assess the potential risks to the security of the products during
subcontracted transportation and storage by the service providers the company appoints.
Security measures identified by the risk assessment shall form part of the contract or terms
and conditions for subcontracted suppliers which have access to the product.
4.3.2
The security arrangements at subcontracted suppliers which handle product shall be verified
at the start of a contract and then at a frequency based on risk thereafter.
BRC
21
4.4
The company shall operate processes to ensure that products received comply with
buying specifications and supplied product is in accordance with any customer
specification.
Clause
Requirements
4.4.1
The company shall have a product sampling or assurance programme to verify that products
are in accordance with buying specifications and meet legal and safety requirements.
Where verification is based on sampling, the sample rate and assessment process shall be
risk-based.
Records of the results of assessments or analysis shall be maintained.
4.4.2
4.4.3
Where claims are made about products handled, including the provenance, chain of
custody, and assured or identity preserved status (see Appendix 6 Glossary) of a product
or raw materials used, supporting information shall be available from the supplier or
independently to verify the claim.
4.4.4
Where the company undertakes or subcontracts analyses which are critical to product
safety or legality, the laboratory or subcontractors shall have gained recognised laboratory
accreditation or operate in accordance with the requirements and principles of ISO 17025.
Documented justification shall be available where non-accredited test methods are used.
4.4.5
Test and inspection results shall be retained and reviewed to identify trends. Appropriate
actions shall be implemented promptly to address any unsatisfactory results or trends.
4.5
Product legality
The company shall have processes in place to ensure that the products traded comply
with the legal requirements in the country of sale where known.
Clause
Requirements
4.5.1
The company shall have documented processes to verify the legality of products which are
traded. This shall include as applicable:
labelling information
compliance with relevant legal compositional requirements
compliance with quantity or volume requirements.
Where such responsibilities are undertaken by the customer, this shall be clearly stated in
contracts.
22
BRC
4.6
Section II Requirements
Product design/development
Product design and development procedures shall be in place for new manufacturedproduct development processes, where this is a service managed by the company,
to ensure that safe and legal products are developed meeting customer-specified
requirements.
Clause
Requirements
4.6.1
The company shall have a process for managing new product development activity with
potential suppliers, which shall include:
a project brief defining the requirements for the products to be developed
a process for reviewing product samples against the brief
a formal product approval process.
4.6.2
The company shall ensure that all new manufactured products have been included within
the HACCP/hazard and risk management plan of the manufacturing site. This shall ensure
that hazards have been assessed and suitable controls are implemented.
4.6.3
The company shall be able to demonstrate that the shelf life attributed to new food
products has been verified through shelf-life testing assessment or by using documented
protocols reflecting conditions experienced during storage and handling, or, where this is
not practical, via a documented science-based justification.
4.6.4
The company shall have processes to ensure that new food products are labelled to meet
legal requirements for the designated country of use. This shall, as appropriate to legislation,
include information to allow the safe handling, display, storage, preparation and use of the
product within the food supply chain or by the customer. There shall be a process to verify
that ingredient and allergen labelling is correct, based on the product recipe.
4.6.5
Where a product is designed to enable a claim to be made to satisfy a consumer group (e.g.
nutritional claim, reduced sugar), the company shall ensure that the product formulation
and production process is fully validated to meet the stated claim.
4.7
Product release
Where products require formal release by a customer or legal authority, the company
shall ensure that an effective product release procedure is in place, with facilities
holding products on behalf of the company.
Clause
Requirements
4.7.1
Where products require positive release, procedures shall be in place to ensure that
release does not occur until all release criteria have been completed and release has been
authorised by the company.
BRC
23
5
5.1
Personnel
Training and competency
The company shall ensure that all personnel performing work that affects product
safety, legality and quality are demonstrably competent to carry out their activity,
through training, work experience or qualification.
24
Clause
Requirements
5.1.1
All relevant personnel, including temporary staff, shall be appropriately trained prior to
commencing work and adequately supervised throughout the working period.
5.1.2
The company shall have a documented training procedure and documented training records
to demonstrate that the training is appropriate and effective.
5.1.3
The company shall routinely review the competencies of staff directly involved with product
safety. As appropriate, it shall provide relevant training. This may be in the form of training,
refresher training, coaching, mentoring or on-the-job experience.
BRC
SECTION III
THE AUDIT PROTOCOL
BRC
25
26
BRC
Section III
Introduction
The audit protocol describes how the audit process operates for the Standard and the rules around the audit
and certification to the Standard. This is an essential element of the Standard and should be read and fully
understood.
Every effort has been made to ensure that the content of this audit protocol is accurate at the time of printing.
However, it may be subject to minor change, and reference should be made to the BRC Global Standards
website, www.brcglobalstandards.com, where any changes will be published.
Conformance by the company with the requirements of the Global Standard for Agents and Brokers and
its suitability for the awarding and continuing retention of certification will be assessed by an independent
audit company the certification body. Certification will be awarded on completion of a successful audit and
closure of any non-conformities identified to the satisfaction of the certification body within a defined time
period.
See Figure 1 for a flowchart outlining the steps of the audit protocol that lead to certification.
The Standard should be read and understood and a preliminary self-assessment should be conducted by the
company against the Standard to prepare for the audit. Any areas which need to be improved to meet the
requirements should be addressed by the company to prevent a non-conformity being raised at the audit.
Further information and guidance to ensure compliance with the Standard, including training courses and
guideline booklets, is available from the BRC Global Standards website.
An optional on-site pre-assessment may be carried out by the selected certification body in preparation for
the audit, to provide guidance to the company on the process of certification. It should be noted, however,
that under the rules for accreditation consultancy cannot be provided during any pre-assessment offered
by the same certification body which will later undertake the certification audit.
Once a self-assessment has been completed and non-conformities addressed, the company must select a
certification body. The BRC cannot advise on the selection of a specific certification body, but the
Directory section of the BRC Global Standards website lists BRC-approved certification bodies.
Visit www.brcdirectory.com
Certification bodies shall be BRC-approved and a condition of approval is that they shall either be accredited
or have an application for accreditation accepted by their accreditation body with a scope which includes the
BRC Global Standard for Agents and Brokers. Please note that as this Standard was introduced in January
2014, during the first year of its application certification bodies are likely to offer non-accredited certification
while going through the accreditation process. In selecting a certification body, the company should consider
the scope of accreditation of the certification body, as some may not be able to provide an accredited
certificate for all traded products. Clarification of the standards and categories of products against which the
certification body can audit can be obtained either by confirmation from the certification body concerned or
from accreditation schedules published by the appropriate national accreditation body.
BRC
27
Figure
HowCertifi
to gain
certification
How to1 Gain
cation
Obtain copy of Standard www.brcglobalstandards.com
On-site audit
INITIAL AUDIT
Corrective action
submitted or revisit
within 90 calendar days
Corrective action
submitted or revisit
within 28 calendar
days
No non-conformities
identified
Evidence assessed:
inadequate
Evidence assessed:
clarification required
Evidence assessed:
compliant
Additional
clarification required
Corrective action
status documented
Certification documentation
collated
No certificate issued.
Report issued specifying
status.
Process/certification
suspended
Evidence assessed:
inadequate
Certification decision
made by certification
decision manager
Certificate details
and audit report
issued to company
and sent to BRC
Ongoing compliance
Certificate and audit details listed
on BRC Global Standards Directory
www.brcdirectory.com
28
BRC
A contract shall exist between the company and the certification body, detailing the scope of the audit
and the reporting requirements. This Standard sets out the requirements for companies that want to apply
to be audited against the Standard and for companies issued with a certificate. Contracts between the
certification body and the company shall include a clause acknowledging these obligations. This contract will
be formulated by the certification body.
The contract shall clearly identify that a copy of the audit report and any subsequent certificate or audit result
shall be supplied to the BRC in the agreed format. The contract shall also dictate that all documents in relation
to the audit shall be made available to the BRC upon request. Documents provided to the BRC will be treated
as confidential.
4.1
Registration fee
The BRC will require a registration fee to be collected by the certification body from the company for
every audit undertaken. The certificate and audit report shall not be valid until the registration fee and the
certification bodys audit fees have been received, irrespective of the outcome of the certification process.
Scope of Audit
5.1
The scope of the audit (see clause 1.2 in Section I) the products and services provided shall be agreed
between the company and the certification body in advance of the audit to ensure the allocation of an
auditor with the correct product knowledge. The audit shall include all applicable requirements within the
Standard and all applicable products traded by the company within the scope of the Standard.
The audit scope and any services excluded shall be clearly defined both on the audit report and on any
certificate issued. The scope description on reports and certificates must include:
The wording of the scope will be verified by the auditor during the site audit. The description of products or
product groups and services within the scope shall enable a recipient of the report or certificate to clearly
identify whether products supplied have been included within the scope.
5.2
The achievement of the certification criteria relies on clear commitment from the company management to
adopting the best-practice principles outlined within the Standard. There is often an assumption by customers
that where a certificate has been issued to a companys office, all products and not just a selection of
products have been included within the scope of the certificate. It follows, therefore, that the exclusion of
products or services provided by a certificated office shall not be permitted.
Certificates are issued to the company for specific office locations and it is permissible for a company to have
some offices certificated under the scheme and other offices not included in the scheme.
5.3
Companies providing services included within the scope of this Standard may have a single office or may have
a number of offices based in one or more countries around the world. The scope of certification may include
all offices or only specific offices.
For the purposes of reporting and certification, each registered office shall have its own audit report and
certificate.
BRC
29
Where a company has multiple office locations all operating to a common quality system and all records are
electronic and available to review from a single location, it may not be necessary for each individual office
location to be physically visited in order for a certificate to be issued.
The certification body shall develop an audit programme for the assessment of a multiple-office system
that shall enable information to be assessed to provide confidence that each individual office complies with
the requirements of the Standard for the scope of the products and services that are applicable. It would
be expected that a physical audit visit would be carried out at the head office and a sample of other office
locations.
The factors which shall be considered in the development of a programme of audit visits shall include:
the use and extent of a common quality system operating at each office
the ability to access records and other documents at one office from another office, directly and without
unreasonable delay
the ability to interview staff at offices not visited, e.g. by videoconference or phone/video links.
The audit plan shall be agreed between the certification body and the company. Additional visits may be
required over and above the plan where:
significant issues are identified at an office audit which would necessitate visits to another office to fully
demonstrate compliance to a level to achieve certification of that office.
5.4
Extension to scope
Once certification has been granted, any additional significant products or product groups traded or services
undertaken by the company, which may be included in the scope of certification, must be communicated to
the certification body. The certification body shall assess the significance of the new products or services and
decide whether to conduct an office visit or undertake a document review to extend scope.
Where an extension to scope is awarded, the current certificate will be superseded by a new certificate
showing the amended scope. The new certificate issued shall have the same expiry date as detailed on the
original certificate.
5.5
Auditor selection
It is the responsibility of the company to ensure that adequate and accurate information is given to the
certification body detailing the products it trades and the services provided, to enable the certification body to
select an auditor with the required skills to undertake the audit.
The certification body, auditors and the company must be aware of the need to avoid conflict of interest
when arranging an auditor for the office visit. The company may decline the services of a particular auditor
offered by the certification body. The same auditor is not permitted to undertake audits on more than three
consecutive occasions at the same company.
30
BRC
Audit Planning
6.1
For the initial audits the company shall agree a mutually convenient date, with due consideration given to the
amount of work required to meet the requirements of the Standard.
Newly established companies must ensure that systems and procedures in place are compliant before an initial
BRC audit is undertaken. It is at the discretion of the company when it wishes to invite a certification body to
carry out an audit; however, it is unlikely that full compliance can be satisfactorily demonstrated at an audit
undertaken less than three months from commencement of operation.
There is a requirement on the company to be prepared for the audit, to have appropriate documentation for
the auditor to assess and to have appropriate staff available at all times during the audit.
6.2
Before the audit takes place, the certification body shall indicate the approximate duration of the audit. The
minimum duration of an audit is one man day at the companys office facility.
The calculation for the audit duration is based on:
It is recognised that other factors may also influence the actual time taken to complete the audit and may
result in a longer than scheduled audit. These factors include:
the quality of company preparation, e.g. documentation, hazard and risk analysis, quality management
systems.
If additional office locations are included within the audit process, then additional time will need to be
allocated for this.
The calculation for the audit duration shall determine the expected amount of time to undertake the office
audit. Additional time will be required for the review of any documentary evidence provided in response to
non-conformities identified and the completion of the final audit report.
6.3
The company shall supply the certification body with background information prior to the audit day to ensure
the auditor is fully prepared and to provide the best opportunity for the audit to be completed efficiently. The
information will be requested by the certification body and may include but is not limited to:
recent quality issues, withdrawals or customer complaints, and other relevant performance data.
BRC
31
The company shall make the previous years audit report and certificate available to the certification body
where this is a contract with a new certification body.
The time to assess all documentation by the auditor and certification body is supplementary to the duration of
the audit.
the opening meeting to confirm the scope and process of the audit
document review a review of the documented hazard and risk analysis and quality management
systems
traceability challenge
review of records
final review of findings by the auditor preparation for the closing meeting
closing meeting to review audit findings with the company. Note that non-conformities are subject to
subsequent independent verification by the certification body management.
The company will fully assist the auditor at all times. It is expected that at the opening and closing meetings
those attending on behalf of the company will be senior managers who have the appropriate authority to
ensure that corrective action can be progressed if non-conformities are found. The most senior manager on
site or their nominated deputy shall be available at the audit and attend the opening and closing meetings.
During the audit, detailed notes shall be made regarding the companys conformities and non-conformities
against the Standard and these will be used as the basis for the audit report. The auditor will assess the nature
and severity of any non-conformity.
At the closing meeting, the auditor shall present his/her findings, and discuss all non-conformities that have
been identified during the audit, but shall not make comment on the likely outcome of the certification
process. Information on the process and timescales for the company to provide evidence to the auditor of
the corrective action to close non-conformities must be given. A written summary of the non-conformities
discussed at the closing meeting will be documented by the auditor either at the closing meeting or within
one working day after completion of the audit.
At the closing meeting, the auditor shall provide the company with an explanation of the BRC Directory
system, which allows secure access to audit data for both the client and its nominated customers.
The decision to award certification will be determined independently by the certification body management,
following a technical review of the audit report and the closing of non-conformities in the appropriate
timeframe. The company will be informed of the certification decision following this review.
The level of non-conformity assigned by an auditor against a requirement of the Standard is an objective
judgement with respect to severity and risk and is based on evidence collected and observations made during
the audit. This is verified by the certification body management.
8.1
Non-conformities
32
Critical where there is a critical failure to comply with a product safety or legal issue.
Major where there is a substantial failure to meet the requirements of a statement of intent or
any clause of the Standard or a situation is identified which would, on the basis of available objective
evidence, raise significant doubt as to the conformity of the product or services being supplied.
BRC
Minor where a clause has not been fully met but, on the basis of objective evidence, the conformity of
the product or services is not in doubt.
The objective of the audit is to provide a true reflection of the standard of the operation and level of
conformity against the Global Standard for Agents and Brokers. Consideration should therefore be given
to awarding a single major non-conformity where minor non-conformities are repeatedly raised against a
particular clause of the Standard. Clustering of a significant number of minor non-conformities against a
clause and recording this as a single minor non-conformity is not permitted.
8.2
Following identification of any non-conformity during the audit, the company must undertake corrective
action both to remedy the immediate issue and undertake an analysis of the underlying cause of the nonconformity (root cause) and, as a minimum for major and critical non-conformities, develop an action plan to
address the root cause.
The process for closing out non-conformities depends upon the level of non-conformity and the numbers of
non-conformities identified (see Table 1).
8.2.1
In some circumstances the number or severity of non-conformities raised at the audit prevents the site from
being certificated following that audit. This will be the case where there is a:
critical non-conformity
and/or
the number or type of non-conformities exceeds the limits for certification as per Table 1.
The grading of non-conformities will be reviewed by the independent certification process of the certification
body as soon as possible after the audit. Where the review confirms that a certificate cannot be awarded, the
company will be required to undertake another full audit before assessment for certification.
Where this occurs at a certificated site, certification must be immediately withdrawn.
It is a requirement of some customers that they shall be informed when their suppliers have a critical nonconformity identified or fail to gain certification. In such circumstances the company shall immediately inform
its customers and make them fully aware of the circumstances. Information on the corrective actions to be
taken in order to address the non-conformities will also be provided to customers where required.
8.2.2
No certificate shall be issued until major and minor non-conformities have been demonstrated as having been
corrected, either permanently or by a temporary solution (where acceptable to the certification body).
For each major non-conformity raised, the site shall in addition to undertaking the necessary immediate
corrective action undertake a review of the underlying cause (root cause) of the non-conformity. The root
cause shall be identified and an action plan to correct this, including timescale, provided to the certification
body. This shall be included in the audit report.
Close-out of non-conformities can be achieved either by objective evidence being submitted to the
certification body, such as updated procedures, records or invoices for work undertaken etc., or by the
certification body undertaking a further office visit.
If satisfactory evidence is not provided within the 90 days following the audit for companies new to the
Standard or within 28 days for existing certificated companies, certification will not be granted. The company
will then require a further full audit in order to be considered for certification.
Non-conformities from the audit shall also be checked during the next audit to verify effective close-out of
the non-conformities and their root cause. Where the correction has been ineffective, a non-conformity shall
be raised against clause 1.1.11.
BRC
33
Critical
Major
Minor
<2
<10
Certificate
on
completion
Re-audit
frequency
once
certificated
Provide objective
evidence:
Yes
12 months
Yes
12 months
No certificate
issued
Dependent
on
subsequent
full audit
result
within 28 calendar
days where
company is currently
certificated
within 90 calendar
days where this
results from an initial
audit
0
<3
<20
Revisit to review
corrective action:
within 28 calendar
days where
company is currently
certificated
3 or 4
<10
1 or more
0
0
within 90 calendar
days where this
results from an initial
audit
Full re-audit, usually
no less than 3 months
following the initial audit
>4
20 or
more
The certification body shall justify a high number (more than 20) of minor non-conformities where one or no
major non-conformities are given. This shall be detailed on the audit report.
Audit Reporting
Following each audit, a full written report shall be prepared in the agreed format. The report shall be
produced in English or in another language dependent upon user needs. Where the report is produced in a
language other than English, the audit summary sections shall always be reported in English in addition.
The audit report shall provide the company and particularly customers or prospective customers with a profile
of the company and an accurate summary of the performance of the company against the requirements of
the Standard.
34
BRC
be informed of the product safety controls in place and improvements since the last audit
The report shall accurately reflect the findings of the auditor during the audit. Reports shall be prepared and
dispatched to the company within 42 calendar days (up to 104 days will be permitted for initial audits where
the additional time is required to close non-conformities) of the date of completion of the full audit.
Audit reports shall remain the property of the company commissioning the audit and shall not be released, in
whole or part, to a third party unless the company has given prior consent (unless otherwise required by law).
The audit report shall be uploaded to the BRC Directory in a timely manner irrespective of whether a
certificate is issued. The owner of the audit report may allocate access to the audit report to customers or
other parties via the BRC Directory.
The audit report and associated documentation, including the auditors notes, shall be stored safely and
securely for a period of five years by the certification body.
10 Certification
After a review of the audit report and documentary evidence provided in relation to the non-conformities
identified, a certification decision shall be made by the designated independent certification manager.
Where a certificate is granted, this shall be issued by the certification body within 42 calendar days of the
audit. (Up to 104 days will be permitted for initial audits where the additional time is required to close nonconformities.) The certificate shall conform to the format shown in Appendix 4. Logos used on certificates,
e.g. BRC and accreditation body logos, shall comply with their respective usage rules. In addition:
The certificate will detail the scope of the audit. The certificate shall be issued to the company and
include the location of the office applicable.
The certificate will include the six-digit auditor registration number of the lead auditor.
The date(s) of audit specified on the certificate shall be the date of the audit relating to the granting of
that certificate, irrespective of whether later visits were made to verify corrective action arising from the
audit.
Whilst the certificate is issued to the company, it remains the property of the certification body, which
controls its ownership, use and display.
11 BRC Logos
Achieving BRC certification is something of which to be proud. Companies that achieve certification are
qualified to use the BRC logo on company stationery and other marketing materials. Information and
conditions relating to the use of the BRC logo are available at www.brcglobalstandards.com
If a company is no longer certificated because of certificate expiry, withdrawal or suspension, it shall no longer
use the logo or display any certificate claiming certification.
The BRC logo is not a product certification mark and shall not be used on products or product packaging.
Any certificated company found to be misusing the mark will be subject to the BRC complaints/referral
process and may risk suspension or removal of its certification.
BRC
35
The Global Standards Directory was developed to publicise the list of certificated companies, provide key
information to retailers and other specifiers, and improve the management of the BRC Global Standards
scheme. It provides a system of data storage of audit information, both live and archived. Data is centrally
managed and controlled to maintain accuracy and integrity.
a searchable list of certificated companies, including contact details, the standards against which they
are certificated, their scope and links to their websites
a searchable list of approved certification bodies, including local offices and contact details.
Note that whilst all reports and certificate details shall be uploaded to the Directory, companies may choose
not to appear on the public directory site if they so wish. This will not, however, exempt companies from the
registration fee.
The Global Standards Directory provides additional functionality to key user groups, including companies,
retailers and certification bodies. This includes user-specific access to certification information, audit reports
and management reporting, further enhancing the value of obtaining BRC certification.
36
BRC
situated in a specific country or an area within a specific country where there is government advice not
to visit and there is no suitable local auditor
situated in an area that has suffered a natural or unnatural disaster, rendering the auditor unable to visit.
Moving the audit date to a more acceptable later date for reasons of combining audits or lack of personnel is
not a justifiable circumstance for missing the due date.
If renewal of the certificate is prevented due to these exceptional circumstances, the customer may still decide
to take products from that company for an agreed time, as it may still demonstrate legal compliance by other
means, such as risk assessment and complaints records, until another audit can be arranged.
The audit report will detail the reasons why an audit has been brought forward.
The audit due date will be reset to be 12 months from this audit date.
The certificate shall be issued with an expiry date of 12 months + 42 days from the new audit date.
product recall
change of ownership.
The certification body in turn shall take appropriate steps to assess the situation and any implications for the
certification, and shall take any appropriate action.
Information shall be provided to the certification body by the company on request, so that an assessment can
be made as to the effect on the validity of the current certificate.
The certification body may as appropriate:
undertake a visit to verify the control of processes and confirm continued certification
Changes to the certificate or certification status of a company shall be recorded in the BRC Directory.
BRC
37
16 Appeals
The company has the right to appeal against the certification decision made by the certification body. Any
appeal should be made in writing to the certification body within seven calendar days of receipt of the
certification decision.
The certification body shall have a documented procedure for the consideration and resolution of appeals
against the certification decision. These investigative procedures shall be independent of the individual
auditor and certification manager. Individual certification bodies documented appeals procedures will be
made available to the company on request. Appeals will be finalised within 30 calendar days of receipt. A full
written response will be given after the completion of a full and thorough investigation into the appeal.
In the event of an unsuccessful appeal, the certification body has the right to charge costs for conducting the
appeal.
38
BRC
SECTION IV
MANAGEMENT AND GOVERNANCE
OF THE SCHEME
BRC
39
40
BRC
Section IV
The Global Standard for Agents and Brokers is a product and services certification scheme. In this scheme,
businesses are certificated upon completion of a satisfactory audit by an auditor employed by an independent
third party the certification body. The certification body in turn shall have been assessed and judged as
competent by a national accreditation body.
The process of certification and accreditation is outlined in Figure 2.
In order for a business to receive a valid certificate on completion of a satisfactory audit, the organisation
must select a certification body approved by the BRC. The BRC lays down detailed requirements that a
certification body must satisfy in order to gain approval.
As a minimum, the certification body must be accredited to ISO/IEC 17065 by a national accreditation body
affiliated to the International Accreditation Forum and recognised by the BRC.
Further details are available in the document Requirements for Organisations Offering Certification against the
Criteria of the BRC Global Standards, available from the BRC on request.
Companies looking to become certificated to the Standard should assure themselves that they are using
a genuine certification body approved by the BRC. A list of all certification bodies approved by the BRC is
available in the BRC Global Standards Directory at www.brcdirectory.com
The BRC recognises that in certain circumstances for example, when new standards such as the Global
Standard for Agents and Brokers are introduced, or there are new certification bodies wishing to commence
auditing against the Standard accreditation may not yet have been achieved. This is because the
accreditation process itself requires some audits to have been completed, which will then be reviewed as part
of the accreditation audit of the certification body. The certification body must be able to conduct audits as
part of the accreditation process and so some unaccredited audits will be performed. These will be permitted
where the organisation can demonstrate that:
it has an active application for accreditation against ISO/IEC 17065 from an approved national
accreditation body
accreditation will be achieved within 12 months of the date of application and the experience and
qualifications of the auditors in the relevant product category are consistent with those specified by the
BRC
a contract is in place with the BRC and all other contracted requirements have been met.
The acceptance of audit reports and certificates generated by certification bodies awaiting accreditation but
meeting the above criteria is at the discretion of individual specifiers.
BRC
41
ISO/IEC 17011
General requirements for
accreditation bodies
National
accreditation body
ISO/IEC 17065
ACCREDITATION
Requirements for certification
bodies offering certification
against the criteria of the BRC
global standards
Certification body
CERTIFICATION
BRC global standards website
www.brcglobalstandards.com
Company
42
Company
Company
BRC Directory
www.brcdirectory.com
BRC
The Standard and associated scheme is managed by the BRC and is governed through a number of
committees, each of which works to defined terms of reference. Figure 3 shows the technical governance
structure for the management of the BRCs global standards.
2.1
The technical management and operation of the Standard is governed by the BRC International Advisory
Board, consisting of senior technical representatives of international retail and food manufacturing businesses.
The functions of the International Advisory Board are:
to ensure measures are in place to monitor compliance by companies, certification bodies and
accreditation bodies.
2.2
Each BRC global standard is supported by at least one Technical Advisory Committee (TAC), which meets
regularly to discuss technical, operational and interpretational issues related to the Standard. The BRC provides
the technical secretariat for these groups.
The TAC is made up of senior technical managers representing the users of the Standard and includes
representatives of retailers, food manufacturers, trade associations, certification bodies and independent
technical experts.
The Standard is reviewed every three years to assess the need for updating or production of a new issue. This
work is undertaken by the TAC, which is expanded for the purpose to include other available expertise.
The TAC also reviews auditor competence requirements, proposed training materials and supplementary
technical documents supporting the standards.
BRC Executive
Scheme management
BRC
43
2.3
The BRC encourages and facilitates meetings of the certification bodies participating in the scheme
(cooperation groups) to discuss matters arising from the implementation of the Standard and issues of
interpretation. These groups report regularly to the BRC on operational issues, implementation and suggested
improvements. Representatives from the cooperation groups attend the TAC meetings.
The maintenance of a high and consistent standard of audit and certification and the ability of the certificated
companies to maintain the standards achieved at the audit are essential to ensure confidence in the scheme
and to the value of certification. The BRC therefore has an active compliance programme to supplement the
work of accreditation bodies and ensure high standards are maintained.
The BRC scheme may only be provided by certification bodies registered and approved by the BRC and
accredited by a BRC-recognised accreditation body. All auditors undertaking audits against the Standard must
meet the BRC auditor competency requirements and shall be registered with the BRC. All audits undertaken
against the Standard shall be uploaded to the BRC Directory, which provides the BRC with an oversight of the
activity of the certification bodies and the opportunity to review the quality of the reports produced.
To support the Standard, the BRC operates a compliance programme, which reviews the performance of
the certification bodies, samples the quality of audit reports and levels of understanding of the scheme
requirements, and investigates any issues or complaints. As part of this programme the BRC provides
feedback on the performance of each certification body through a key performance indicator (KPI)
programme.
On occasions, the BRC may audit the offices of certification bodies and accompany auditors on audits at sites
to observe their performance. The BRC may also undertake independent visits to certificated companies to
ensure standards of food safety and quality are being maintained in line with their certification status and to
ensure that the audit and reporting process is to the expected standard.
3.1
Calibrating auditors
A key component of the scheme is the calibration of auditors to ensure a consistent understanding and
application of the requirements. All certification bodies are required to have processes to calibrate their own
auditors. An essential element of the training and calibration of auditors is the witnessed audit programme.
Auditors are observed during an audit and provided with feedback on the performance of the audit. In order
to ensure consistency between certification bodies and for the purposes of accreditation, an audit may be
witnessed by a BRC representative or accreditation body auditor. Guidelines apply to these activities to ensure
that companies are not disadvantaged by the presence of two auditors. This process forms an essential part of
the scheme and companies are obliged to permit witnessed audits as part of the conditions for certification.
3.2
Feedback
Companies audited against the Standard may wish to provide feedback to the certification body or the BRC
on the performance of the auditor. Such feedback sent to the BRC will be considered in confidence. Feedback
provides a valuable input to the BRC monitoring programme for certification-body performance.
3.3
The BRC has implemented a formal complaint and referral process, which is available to organisations involved
with the global standards. A document detailing the global standards referral process can be found on the
website www.brcglobalstandards.com
From time to time, failure to apply the principles and criteria of the BRC global standards at certificated
companies may be reported to the BRC by, for example, retailers and companies conducting their own audits.
In this event, the BRC will request a documented report of the reasons for the complaint and refer this report,
in confidence, to the certification body conducting the audit. The BRC will require a full investigation of
the issues raised and a report from the certification body submitted to the BRC within 28 calendar days (or
shorter time as specified by the BRC in urgent cases).
44
BRC
Appendices
APPENDICES
BRC
45
46
BRC
Appendices
Appendix 1
BRC
47
Appendix 2
Education
The auditor shall have a degree in or shall have successfully completed a higher education course in a foodrelated, packaging or bioscience discipline, or other relevant subject.
Work Experience
The auditor shall have a minimum of five years post-qualification experience related to the food packaging
or logistics industry. This shall involve work in quality assurance functions within manufacturing, logistics,
retailing, inspection or enforcement. The verification of the auditors ability to carry out work within specific
product categories is the responsibility of the certification body.
Qualifications
The auditor must have:
passed a registered management-system lead assessor course (e.g. International Register of Certificated
Auditors IRCA) or the BRC third-party auditor course delivered by a BRC-approved trainer
completed a training course in HACCP (Hazard Analysis and Critical Control Point) (as evidenced by
examination), based on the principles of Codex Alimentarius and of at least two days duration, and be
able to demonstrate competence in the understanding and application of HACCP principles. It is essential
that the HACCP course is recognised by the industry (and its stakeholders) as being appropriate and
relevant.
Audit Training
Auditors must have successfully completed a period of supervised training, including witnessed audits, in
practical assessment through 10 audits or 15 audit days involving agents and brokers, food or packaging
safety audits against Global Food Safety Initiative (GFSI)-approved Standards, ISO 22000 or ISO 9000 series
(at a food business), of which at least five audits must be against one or more of the BRC global standards.
Certification bodies must be able to demonstrate that every auditor has appropriate training and experience
for the particular categories for which they are considered competent. Auditor competence shall be recorded
at least at the level of each category as indicated in Appendix 3.
Certification bodies must establish training programmes for each auditor, which will incorporate:
48
successful completion of the BRC auditor training course for the Global Standard for Agents and Brokers,
delivered by a BRC-approved trainer
a period of initial training covering product safety, HACCP and prerequisite programmes, and access to
relevant laws and regulations
a period of supervised training to cover quality management systems, audit techniques and specific
category knowledge
BRC
Appendices
Each auditors training programme shall be managed and approved by a technically competent person within
the certification body who can demonstrate technical competence in the categories in which training is given.
Full detailed training records of the individual shall be maintained by the certification body throughout the
term of employment, and retained for a minimum period of five years after leaving the employment of the
certification body.
Exceptions
Where a certification body employs an auditor who does not fully meet the specific criteria for education
but has been assessed as competent, there shall be a fully documented justification in place to support the
employment of the auditor.
BRC
49
Appendix 3
Product Categories
The following product examples are given as guidance only; this is not an exhaustive list. The BRC will publish
updated examples on the BRC website www.brcglobalstandards.com
Food
products
Cat no.
Category description
Product examples
Dairy
50
BRC
Appendices
Food
products
continued
Cat no.
Category description
Product examples
Ambient grocery
products
Packaging
Glass
BRC
51
Packaging
continued
Cat no.
Category description
Product examples
Paper
Paper bags
Paper sacks
Paper labels, tags and neck collars
Board cartons
Board sleeves
Chipboard cartons and layer pads
Corrugated cases and trays
Corrugated fitments
10
Metals
Cans
Aerosol containers
Tubes
Aluminium foil
Foil trays
11
Plastics
12
Pallets
Boxes and crates
Decorative wooden boxes
Natural cork
Wood for food and cosmetic use
Hessian sacks
Wooden utensils
52
BRC
Appendices
Appendix 4
Certificate Template
CERTIFICATION BODY NAME OR LOGO
Auditor number
Associated offices
Offices included within certification (this may also be presented as an appendix to the certificate)
Has been evaluated by certification body name (a national accreditation body)
accredited certification body no. x and found to meet the requirements of
SCOPE
Product categories
Services:
Date(s) of audit: if an extension to scope, include original audit date and visit date
to
___________________
Authorised by
Accreditation
body logo
BRC logo
If you would like to feed back comments on the BRC global standard
or the audit process directly to the BRC, please contact [email protected]
BRC
53
Appendix 5
Event
Date
Initial audit
(Audit 1)
1 February 2014
12 March 2014
Explanation
Recertification
audit
(Audit 2)
Certificate expiry
date
14 March 2015
4 January to
1 February 2015
26 January 2015
25 February 2015
Certificate expiry
date
54
14 March 2016
BRC
Appendices
Appendix 6
Glossary
Accreditation
Agent/nonmanufacturing
service provider
Allergen
Announced audit
An audit where the company agrees the scheduled audit day in advance with the
certification body.
Assured status
Audit
BRC
55
56
Branded food
products
Pre-packaged food products bearing the logo, copyright and address of a company
which is not a retailer.
Broker
Business
continuity
Calibration
Certificate
withdrawal
Certification
Certification body
Codex
Alimentarius
Commission
Company
The person, firm, company or other entity with which a confirmed purchase order
is placed, or which owns premises where products in whatever form originate, or
which is otherwise responsible for employing or procuring the services of food
handlers in the production and preparation of food.
Competence
Contamination
Control measure
Any action or activity that can be used to prevent or eliminate a food safety hazard
or reduce it to an acceptable level.
Cook
A thermal process designed to heat a food item to a minimum of 70C for two
minutes or equivalent.
Corrective action
Critical Control
Point (CCP)
Customer
Customer focus
End consumer
The ultimate consumer of a foodstuff, who will not use the food as part of any
food-business operation or activity.
Exporter
Factored goods
Goods not manufactured or part-processed on site but bought in and sold on.
BRC
Final
manufacturer
The site where the last processing act is undertaken on a product before supply to
the agent or broker.
Flow diagram
Food handler
Food safety
Assurance that food will not cause harm to the consumer when it is prepared and/
or eaten according to its intended use.
Genetically
modified
organism (GMO)
An organism whose genetic material has been altered by the techniques of genetic
modification so that its DNA contains genes not normally found there.
Good
manufacturing
practice (GMP)
Hazard
Hazard Analysis
and Critical
Control Point
(HACCP)
A system that identifies, evaluates and controls hazards which are significant for
food safety.
High-care area
High-care product
High-risk area
High-risk product
Identity preserved
Importer
Incident
An event that results in the production or supply of unsafe, illegal or nonconforming product.
Initial audit
Internal audit
The general process of audit, for all the activity of the company. Conducted by or
on behalf of the company for internal purposes.
Job description
Low-risk area
Non-conformity
BRC
Appendices
57
58
Office
For the purposes of this Standard, an office is a dedicated workplace where two or
more people work, that has accessibility to company files and is a registered postal
address for the company.
Performance
indicators
Prepared primary
product
A food product which has undergone a washing, trimming, size-grading or qualitygrading process and is pre-packed.
Prerequisite
The basic environmental and operational conditions in a food business that are
necessary for the production of safe food. These control generic hazards covering
good manufacturing practice and good hygienic practice and shall be considered
within the HACCP study.
Primary packaging
Procedure
Processed food
A food product which has undergone any of the following processes: aseptic filling,
baking, battering, blending, bottling, breading, brewing, canning, coating, cooking,
curing, cutting, dicing, distillation, drying, extrusion, fermentation, freeze drying,
freezing, frying, hot filling, irradiation, microfiltration, microwaving, milling, mixing,
being packed in modified atmosphere, being packed in vacuum packing, packing,
pasteurisation, pickling, roasting, slicing, smoking, steaming or sterilisation.
Processing aids
Product recall
Any measures aimed at achieving the return of an unfit product from final
consumers and customers.
Product
withdrawal
Any measures aimed at achieving the return of an unfit product from customers
but not final consumers.
Provenance
Quantity check/
mass balance
A reconciliation of the amount of incoming raw material against the amount used
in the resulting finished products, also taking into account process waste and
rework.
Ready-to-cook
food
Ready-to-eat food
Ready-to-reheat
food
Recognised
laboratory
accreditation
Retail brand
Retailer
BRC
Retailer-branded
food products
Risk analysis
Risk assessment
Root cause
Seasonal
production site
A product harvested and processed on a site that is opened specifically for the
duration of the short term of that harvest (typically 12 weeks or less) during a
12-month cycle.
Shall
Should
Signifies that compliance with the contents of the clause is expected or desired.
Site
Standard, the
The BRC Global Standard for Agents and Brokers, Issue 1, January 2014.
Stock
reconciliation
The process by which the location and quantity of raw material, intermediate
product and finished product is identified and matched to product schedules and
quantities.
Supplier
The person, firm, company or other entity to which a companys purchase order to
supply is addressed.
Suspension
Where certification is revoked for a given period pending remedial action on the
part of the company.
Traceability
The ability to trace and follow a food, feed, food-producing animal or raw material
intended to be, or expected to be, incorporated into a food, through all stages of
receipt, production, processing and distribution.
Trend
Unannounced
audit
User
The person or organisation that requests information from the company regarding
certification.
Utilities
Validation
Confirmation through the provision of objective evidence that the requirements for
the specific intended use or application have been fulfilled.
Verification
Where
appropriate
In relation to a requirement of the Standard, the company will assess the need for
the requirement and, where applicable, put in place systems, processes, procedures
or equipment to meet the requirement. The company shall be mindful of legal
requirements, best-practice standards, good manufacturing practice and industry
guidance, and any other information relating to the manufacture of safe and legal
product.
BRC
Appendices
59
Appendix 7
Acknowledgements
The BRC is grateful to the members of the Working Group who prepared this document:
Geoff Austin
Gary Barr
Colette Bishop
Phillip Knight
Knight International
Inspectorate
Sarah Marsden
Maria Borg
3663
David Brackston
Tom Owen
Jeremy
Chamberlain
Tony Plant
Lamex Foods
Paul Rust
Waitrose Ltd
Alison Cousins
Chris Sturman
Su Dakin
BFFF
Saveria De Susini
Tulip
Jon Tugwell
Fyffes
John Figgins
Chris Walker
Weetabix
Paul Hankin
ASDA
Chris Ward
Booker Ltd
Jock Harmer
WW Giles
Sue Williams
Norman Hatcliff
Norish Coldstore
Daniel Kingdon
Tesco
We would also like to thank the following companies that kindly participated in trial audits to test the
Standard:
Mardon plc
Silbury Marketing Ltd
Westbridge Foods Ltd
60
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