Professional Documents
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CERTBODYREQUIREMENTSFINAL
CERTBODYREQUIREMENTSFINAL
CERTBODYREQUIREMENTSFINAL
Document Distribution:
Registered Certification Bodies
Participating National Accreditation Bodies
BRC Members
BRC Technical Committee Members
Section
1. Introduction
1.1. History
1.2. Quality
1.3. Legislative Requirements
2. Purpose
4. BRC Procedures
4.1. General
4.2. Referrals
4.3. Communication
7. Appendices
7.1 BRC Registration Form for Certification Bodies
7.2 BRC Technical Standards Referral Process
7.3 BRC Referral Registration Form
7.4 BRC Technical Standard Sample Certificate
7.5 BRC Food Technical Standard Requirements
7.6 BRC/IOP Technical Standard Requirements
1.1 History
The British Retail Consortium (BRC) is the trade association that represents 90% of
the retail trade in the UK. Its members operate a variety of outlets from large
multiples and department stores through to corner shops. The BRC is directly
involved in a number of important issues affecting retailing and the consumer,
including product safety, all forms of legislation, e-commerce, the environment and
retail crime. The BRC lobbies opinion formers in the UK and the EU, on these and
many other issues.
The British Retail Consortium has actively been involved with the development and
implementation of Technical Standards since 1996. Standards currently available
are;
The BRC Technical Standard and Protocol for Companies Supplying Retailer
Branded Food Products Issue 3 (BRC Food Technical Standard)
The BRC/IOP Technical Standard and Protocol for Companies Manufacturing
and Supplying Food Packaging Materials for Retailer Branded Products
(BRC/IOP Packaging Standard)
The BRC/FDF Technical Standard for the Supply of Identity Preserved Non-
Genetically Modified Food Ingredients and Product (BRC/FDF IP Standard)
The development of such Standards was initially driven by the need to meet
legislative requirements, but were quickly seen as having significant benefits to the
suppliers of product to the UK Retailers, and as a consequence there has been
considerable interest internationally as these Standards have been implemented.
Work on the first BRC Technical Standard, the Technical Standard and Protocol for
Companies Supplying Retailer Branded Food Products began in 1996, which
culminated in the publication of the first issue of a BRC Standard in October 1998.
For the first time UK Retailers, working within a highly competitive market place, had
realised that food safety is a non-competitive issue and that by sharing experience
and developing robust systems together, there were distinct advantages legally,
technically and commercially.
Following the success of the BRC Food Technical Standard there has been continued
co-operation between UK Trade Bodies, with the encouragement of the UK
Government, to develop an approach to a number of issues such as the Genetically
Modified Food Ingredients and control parameters within the Food Packaging
Industry.
The UK Retail Industry is unique in that retailer branded products represent a very
high level of sales, which is increasing year on year, e.g. retailer branded product
represent over 38% of sales in the food grocery market.
In many sectors notably food the retail branded products are market leaders and
therefore protection and integrity of their ‘brand’ is business critical to the majority
of UK Retailers.
It is also important to understand that within the UK market the vast majority of
retailer branded products have been developed as ‘high quality’ and not as ‘second
quality’ competing on price with branded products. The UK retail market is extremely
competitive and consumer expectations are high and demanding.
Over 60% of all grocery sales in the UK are held by the largest five food retailers and
these companies compete aggressively on quality, price and innovation. As a
consequence the UK sources imports high volumes of products and ingredients from
overseas companies to meet this consumer demand for innovation and to compete
commercially. The consumer has the right therefore to expect that standards within
companies supplying these products and ingredients are comparable to that found in
the UK and there should be no compromise on safety or quality.
The Certification Bodies who wish to gain accreditation to audit against the
BRC Technical Standards must fully understand their responsibility and role
to provide assurances that required Standards are monitored and
maintained.
The UK is one of the very few countries which has a statutory ‘due diligence’
defence requirement within its legislative framework. This effectively means that a
retailer cannot accept and rely on a ‘warranty’ defence, if legal proceedings were
presented.
The due diligence defence is a general defence of “all reasonable precautions and all
due diligence” against principal offences in the relevant UK Statutes and can be
defined as:
“…it shall…be a defence for the person charged to prove that he took all reasonable
precautions and exercised all due diligence to avoid the commission of the offence by
himself or by a person under his control.”
The relationship that existed between the individual retailer and it’s suppliers was
recognised by those involved with the development of guidelines, and the
considerable influence of the retailer over recipe formulation/design, standards
existing within the production environment and control systems was reflected by the
content of guidelines. The responsibility for the safety and legality of product was
now shared between the supplier and the retailer, with emphasis for the retailer
being placed on five main areas of control, namely:
The BRC Technical Standards have been developed to ensure that these
requirements are met and monitored.
The purpose of this document is to ensure that the Certification Bodies and
Accreditation Bodies are fully aware of;
• the importance of the BRC Technical Standards to the UK Retailer and their
suppliers
• their responsibility with respect to legal liability
• the procedures supporting the BRC Technical Standards
• the communication network to ensure a consistent and harmonised approach
The following diagram illustrates the mechanism by which BRC wishes to interact and
communicate with both Certification Bodies and Accreditation Bodies.
Maintains
Accreditation
Standards
UKAS
National Accreditation Mutual
Service Suppo
rt
National Accreditation
Service
tion
l Informa
& Referra
ent Doc
equirem
a l Su pport- R
Mutu
BRC
UK Standard Other Country
Owner
Mutu
al Su
ppor
t-Req
uirem
ent D
oc &
R eferr
al Info
rmati
on
Certification Bodies Mutual Support- Food Technical Co-operation Group Certification Bodies
3.1 General
The objective of the BRC Technical Standards is to specify safety and quality criteria
required to be in place within a manufacturers organisation to supply product to UK
Retailers. The format and content of each Standard is designed to allow an
assessment of the supplier’s premises and operational systems and procedures by a
competent third party against the requirements of each individual Standard.
BRC recognise the importance of accreditation and during the development of all the
Technical Standards has worked closely with the United Kingdom Accreditation
Service (UKAS) to ensure the all requirements of product certification are met.
Third party bodies carrying out assessments must gain accreditation to EN45011
(ISO/IEC Guide 65) and meet the requirements within the relevant Standard’s
protocols.
Significant efforts have been made to promote openness and transparency in the
development and implementation process and to work closely with all stakeholders to
ensure the integrity and robustness of the system.
It is of the utmost importance that those involved with certification and accreditation
are included with the continued development and implementation of BRC Technical
Standards and this document will assist with the understanding of the aims of the
BRC Technical Standards and their significance.
This section of document has been drafted to emphasise key specific requirements of
BRC Technical Standards and assist Certification and Accreditation Bodies. It is
important to understand that these requirements may differ between individual BRC
Technical Standards where factors such as Industry sector practice, product risk and
case law have dictated the requirement.
The qualification, training and experience will differ relevant to the product and
technology covered by the scope of the individual BRC Technical Standards, however
the auditing skills will not differ and shall be monitored to maintain a high standard.
The Certification Body will hold a detailed and complete skills matrix for all
evaluators undertaking their evaluations.
Individual BRC Technical Standards may have specific defined sector groups within
the overall product class determined by factors such as technology, risk or raw
material source.
Certification Bodies shall only work within the specific fields of expertise relating to
these product categorisations. They must demonstrate that their staff have the
knowledge and expertise to work within these fields. Certification Bodies must
demonstrate appropriate training for evaluators has been undertaken before
assigning them to any additional fields of evaluation for which they do not have the
relevant product knowledge.
The specific fields of evaluation can be found within Appendices of this document.
Audit frequency is governed by product risk and supplier competence and may differ
within and between BRC Technical Standards.
The duration of audit is dependant on a number of factors, which are specified within
the appropriate Standards.
The Certification Body shall be mindful that the audit format is one of systems review
and physical inspection of the site and manufacturing process. Time allocation during
the audit shall be such to provide sufficient and proportionate time for each process
to be carried out in full, and where appropriate, additional time given when the
evaluator is required to carry out further investigation.
Where a Certification Body undertakes an audit and they are accredited to carry out
evaluation against similar Standards i.e. ISO 9000 and HACCP, then where clauses of
the Standards are equivalent, there is no requirement to duplicate evaluation of
these clauses.
Certification Bodies shall have an internal audit programme for on-site assessments
and this programme will be designed to ensure that every year it shall include at
least one assessment of every field, type and range for which the Body is accredited.
At the same time, the programme shall ensure that each evaluator is assessed on-
site at least once in a four year period for each field, type and range for which
he/she is considered to be competent.
3.7 Reporting
The Certification Body will provide a full report of the outcome of the evaluation. The
report shall follow the format prescribed within the Appendices of this document and
shall include details of the evaluation visit along with timescales for corrective action
agreed with the auditee at the closing visit.
The report shall be produced as soon as practicable after the evaluation visit to the
supplier normally within 28 days.
The certification process for each individual Standard is documented within the
respective protocols.
The principles of the ‘foundation’ and ‘higher’ level certification shall be followed as
defined within the respective Standard.
Initial certification (to a first time auditee) will not be awarded where any non-
conformance remain outstanding. The definition of nonconformity is described in
EA6/01 (EA Guidelines on the Application of EN45011);
‘Deviation of product from specified requirements, or (if the product certification
system includes assessment of the supplier’s management system) the absence of,
or failure to implement and maintain, one or more required management system
elements, or a situation which would, on the basis of available objective evidence
raise significant doubt as to the conformity of what the supplier is supplying.’
The Certification Body must be mindful of this definition in relation to assigning the
critical, major and minor status of an observation at the time of the evaluation.
The duration of the issued certificate will be specified within each BRC Technical
Standard or within documents issued to support these Standards and may vary
between the individual BRC Technical Standards, Appendix 7.4 (BRC Technical
Standard Certificate Content)
The auditee shall have available at the evaluation site the correct version of the
relevant Standard against which they are being evaluated.
BRC would point out that under no circumstances shall any copies of the BRC
Technical Standards be made without the permission of BRC. Certification Bodies
shall be aware of issue of infringement of copyright.
A contract may be required between the Certification Body and the Retailer. The
issue of this contract shall be at the discretion of the individual Retailer.
4.1 General
BRC has recognised that to ensure the continued integrity of Standards it was
imperative to develop a structured approach to their development, implementation
and maintenance by establishing Technical Committees with defined responsibilities
and terms of reference
The management control of the BRC Technical Standards rests with a Governance
and Strategy Committee who oversee individual Technical Advisory Committees for
each Technical Standard.
Each committee has its own Terms of Reference under which they conduct business.
4.2 Referrals
To ensure that any interpretation issues, enquiries, disputes are resolved effectively
and efficiently, BRC has implemented a formal referral process which will be available
to those organisation actively involved with the BRC Technical Standards; this will
include accredited Certification Bodies.
4.3 Communication
Upon registration with BRC by Certification Bodies, an e mail address for referrals will
be issued to them allowing effective communication to be maintained.
BRC have developed a section of their web site specifically for those wishing to find
out more about Technical Standards or make enquiry.
The BRC web site address is;
www.brc.org.uk
The Certification Body prior to notifying BRC of its intention to gain accreditation to
EN45011 (ISO/IEC Guide 65) for the appropriate BRC Technical Standard must apply
for accreditation to a national Accreditation Service; this would normally be expected
to be their ‘home’ Accreditation Body, and that this Body be a member of EA
( European Co-operation for Accreditation) or IAF (International Accreditation
Forum)
If a Certification Body wishes to include any BRC Standard under their scope of
accreditation to EN45011 (ISO/IEC Guide 65), they must formally write to the BRC
confirming their intention. This shall information will be presented to BRC in the
format specified in Appendix 7.1 (Registration Form for Certification Bodies).
The Certification Body shall inform BRC when they have gained accreditation. A copy
of the accreditation certificate shall be provided to the BRC.
The Certification Body shall make BRC aware when the national Accreditation Body
has carried out surveillance upon their organisation and the result of this surveillance
shall be made known along with any change of accreditation status.
5.4 Training
It is recommended that the Certification Body should undertake training under the
guidance of BRC; this will be in the form of formal training courses. This is seen as
being particularly important in the case of non UK Certification Bodies where there
may be a lack of understanding of legal issues and procedures associated with the
effective maintenance of the BRC Technical Standard’s requirements e.g. the due
diligence defence.
On completion of the BRC Third Party Auditor Training course, individual evaluators
can use the BRC Quality Mark, which incorporates a unique reference number, on the
certificate issued by the accredited Certification Body. However BRC would stress
that in all cases before carrying out any BRC audit, the evaluator must meet all the
competences specified within the Appendices of this document.
In the event of legal challenge the Certification Body may be required to act as an
expert witness.
Where requested the Certification Body shall undertake to provide any BRC member
with the necessary information in relation to audits carried out against the individual
BRC Standard. The permission of the client to release this information must be
obtained
Once registered with BRC, the Certification Body shall become involved with the
referral process. As such the Certification Body will from time to time receive
information from BRC about the Standards.
Conversely the Certification Body shall be expected to refer any significant issues,
observations or comment about the Standards back to the BRC for investigation and
resolution.
To ensure effective lines of communication are in place the Certification Body shall be
required to complete a BRC Referral Registration Form (Appendix 7.3 BRC Referral
Registration Form)
All records and documentation related to BRC Technical Standards evaluations must
be retained by the Certification Body and available to therefore available to BRC for a
minimum of five years. This will also include all personnel and training records.
Such documents shall be made available to BRC, or its members, upon request.
All documents submitted to BRC members shall be in English, this includes the
Evaluation Report and Certificate. Any documents, i.e. audit notes shall be provided
upon request and translation made by BRC or its members.
5.8 Liability
The Certification Body shall ensure that appropriate liability insurance is in place.
This insurance shall incorporate employer’s liability, public and product liability and
professional indemnity.
Any registered Certification Body shall but channel its referrals and enquiries to BRC.
The BRC may wish to discuss or consult with its ‘home’ Accreditation Body (UKAS) to
resolve issues and will encourage dialogue between the national Accreditation Bodies
and UKAS.
Name of Organisation
Address of Organisation
Telephone Fax
Name of Contact
Position of Contact
Telephone of Contact E mail Address
Scope of Application
Date of Application
Fields of Evaluation
Accreditation Body
Address
Telephone Fax
Name of Contact
Position of Contact
Telephone of Contact E mail address
Date of Registration to BRC
Accreditation
Trade Bodies BRC Members Certification Bodies Licensees
Bodies
BRC Referral
E mail
Address
Referrals@brc.org.uk
Reference Referral
Investigate
(Optional)
Refer to Working
Group Members
Discussion
Amend Standard
Agreement
Amend Training
Communication
Accreditation
Trade Bodies BRC Members Certification Bodies Licensees
Bodies
Address of Organisation:
Six broad areas of evaluation have been identified. Food Processing has been
categorised into six fields, as listed below. Organisations applying for accreditation or
extensions of scope should use these fields in their applications:
Food Processing
Entry level
Qualifications
Training
The evaluator shall have successfully completed an QMS lead assessor course, or the
BRC Third Party Auditor Training Course and have undergone a supervised period of
training in practical assessment. He or she shall also have successfully completed a
training course in HACCP based on the principles from Codex Alimentarius, and be
able to demonstrate competence in the understanding and application of HACCP
principles.
It is essential that training courses are recognised by the industry (and its
stakeholders) as being appropriate and relevant. For example, approval or
certification by an independent body with the relevant expertise can provide some
assurance that a course meets specified criteria.
BRC would encourage Certification Bodies not based in the UK, to ask their auditors
to attend the BRC Third Party Auditor Training Course.
Experience
The evaluator shall have a minimum of five years post-graduate experience related
to the food industry. This shall involve work in Quality Assurance or food safety
functions within manufacture, retailing, inspection or enforcement.
Evaluation Report
Evaluation Details
Evaluator: Evaluation Date: Date of Previous
Evaluation:
Company Name:
Address:
Postcode: Country:
Scope of Evaluation
Key Personnel
Name/Job Title Present at Evaluation (a)
Company Profile
Section of Standard
HACCP System:
Product Control:
Process Control:
Personnel:
Major
Minor
Recommendation
The British Retail Consortium (BRC) and the Institute of Packaging (IOP) worked
closely together to develop and implement the Technical Standard and Protocol for
Companies Manufacturing and Supplying Food Packaging Materials for Retailer
Branded Products. The sections of this appendix specify concise requirements in
relation to this Standard.
Board sleeves
Chipboard cartons and layer pads
Corrugated cases and trays
Corrugated fitments
3 Metals Cans
Aerosol containers
Tubes
Closures
Aluminium foil
Foil trays
4 Plastics Bottles and jars
Caps
Thermoformed trays
Tubs and pots
Adhesives
Buckets and pails
Bulk containers
Plastic film, including vacuum
metallised films, and labels
1. Qualifications
Evaluators will be drawn generally from two distinct disciplines. Those with expertise
and a qualification in Food/Hygiene Technology and those with expertise and a
qualification in Packaging Technology. Qualification requirements will take account of
this, expecting evaluators to offer their major qualifications as either a Food/Hygiene
Technology or a Packaging Technology qualification. This main qualification will be
supported by a minimum secondary qualification in the other disciplines as
appropriate. Where equivalence of qualification is unclear this shall be referred to the
BRC for review
3. Training
The Evaluator shall have successfully completed an 1S09000 Lead Assessor Course
and have undergone a period of supervised training in practical assessment. He or
she will also have studied, as part of the core curriculum or part of a training course,
Hazard Analysis based on the principles of Codex Alimentarius and be able to
demonstrate competence in the understanding and application of hazard analysis
principles.
4. Experience
The Evaluator shall have a minimum of five years post-qualification experience in his
or her main qualification discipline. This shall involve work in quality assurance,
manufacturing, auditing, inspection or enforcement.
Address:
Postcode: Country:
Scope of Evaluation
Exemptions:
Key Personnel
Name/Job Title Present at Evaluation (a)
Company Profile
Section of Standard
Organisation & Management:
Factory Standards:
Contamination Control:
Personnel:
Major
Minor
Recommendation