Interim Waiver Process for BRC Audits During Corona Outbreak
This content outlines the interim waiver process and scheduling procedures for local office client audits during the Corona outbreak. It includes steps for completing waiver applications, conducting remote audits, and handling certification extensions. The document also provides guidelines for remote and GMP audits, along with calculation rules for audit time. The process involves communication between the client, audit team, and lead auditor to ensure compliance with BRC standards despite the challenging circumstances of the pandemic.
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-Corona Outbreak- Interim Waiver Process BRC Planning / Scheduling Process of Local Office Client Approaches TUEV NORD Fill in Form A22F240 PART A of Waiver Application and BRC self assessment Checklist BRC Client Schedule and Conduct Audits and subsequent activity acc. to regular Process information letter / mail to client no Client affected by Corona yes Lead Auditor Schedule and Agree on Remote Audit date and schedule GMP Audit. Complete PART B of A22F240 Send A22F240 to client resp. Local Office Send A22F240 to client Lead Auditor Check Part A and review self assessment Checklist of the related BRC Standard resp. Local Receive Approve Waiver A22F240: Inform client and Audit team Create / renew ATEA/ Assignment application if needed Information receive d via standard ATEA Process / Workflow Office Update / Renew resp. inform Client and Audit team, Conduct remote Audit / NCM acc. to regular Process 1 Receive A22F240 cr.Location CSM Food/ Feed Check no Waiver approved PART A and fill out Part C yes ATEA Team no ATEA approved? Follow standard ATEA Process yes database Team Update BRCDirectory Database with agreed Remote audit date of PART B Cert. and TNCERT Update BRCDirectory Database with agreed Remote audit date of PART B A22AA240-Interim Corona Outbreak BRC Interim Waiver Process Rev.01/03.20 Rev.01 / 03.20
-Corona Outbreak- Interim Waiver Process BRC BRC Client Lead Auditor resp. Local Office Schedule and Follow up GMP Audit Lead Auditor Start WF and add Form A22F240 and self assessment checklist resp. Local Office correct / complete audit documents 1 CSM Food/ Feed yes Veto Team no no Review and certification decision correction possible No Certificate extension Release possible database Team Certificate validity extension for 12 month Update BRC-Directory Certificate validity extension for 12 month Update BRC- Directory Cert. and TNCERT yes A22AA240-Interim Corona Outbreak BRC Interim Waiver Process Rev.01/03.20 Rev.01 / 03.20
INTERIM WAIVER REQUEST back back A22AA240-Interim Corona Outbreak BRC Interim Waiver Process Rev.01/03.20 Rev.01 / 03.20
BRCDIRECTORY back back A22AA240-Interim Corona Outbreak BRC Interim Waiver Process Rev.01/03.20 Rev.01 / 03.20
CALCULATION RULES FOR REMOTE AND GMP AUDITS Remote Audits: Audit Preparation 2-3 hours (review of self assessment, audit plan, etc.) Calculate the audit time based on rules of A22VA02A03 50% of the calculated audit time shall be used for the remote audit but at minimum 1 day If the outcome of the risk assessment is medium risk: + 20% additional time Report writing: 3 - 4 hours Additional Voluntary Modules: This extension of time should be consistent with the normal time as defined in A22VA02A03 committed to these activities GMP Audits for all BRCGS Standards except Agents & Brokers Calculate the audit time based on rules of A22VA02A03 50% of the calculated audit time shall be used for the remote audit but at minimum 1 day Report writing: 3 - 4 hours back back A22AA240-Interim Corona Outbreak BRC Interim Waiver Process Rev.01/03.20 Rev.01 / 03.20
ATEA APPROVAL Documents to be attached for ATEA approval: A00F030 Self assessment checklist of client Approved waiver A22F240 back back A22AA240-Interim Corona Outbreak BRC Interim Waiver Process Rev.01/03.20 Rev.01 / 03.20
CONDUCT THE AUDIT Instruction for the auditor Before the audit Audit preparation: Interim Waiver for Remote audit is confirmed (A22F240) Timeline: audit due date max. + 1 month Review self assessment (e.g. BRC Auditor Checklist for Packaging or BRCF804 Food 8 Self Assessment) of the company. Completed max 1 month prior to the remote audit request. Not only tick box report evidences like documents and photos are included. Insufficientself assessment reports result in a refused remote audit (see BRC073 document) Links to self-assessment checklists Food Issue 8 https://www.brcgs.com/brcgs/food-safety/help-and-guidance/ Packaging Issue 5 https://www.brcgs.com/brcgs/packaging/help-and-guidance/ Agents & Brokers Issue 2 https://www.brcgs.com/brcgs/agents-and-brokers/help-and-guidance/ Consumer Products Issue 4 - https://www.brcgs.com/brcgs/consumer-products/help-and-guidance/ Duration for audit preparation: 2-3 hours as requestedby assignment Technical equipment: Protected Internet connection (if the auditoris not working in the protected enviroment of T V NORD Internet, the company has to provide a secured internet connection) Internet connection must be stable also in production areas Additional equipmentavailable: Microphone, speakers, Camera, live video capability) back back A22AA240-Interim Corona Outbreak BRC Interim Waiver Process Rev.01/03.20 Rev.01 / 03.20
CONDUCT THE AUDIT Instruction for the auditor Audit plan has to be: Has to be provided and includes the minimum as outlined in BRC073 Appendix 1 and Opening / closing Meeting Virtuel site inspection via live video Review of CCP s or equivalentcontrols Discussiion with relevant staff Traceability test Challenge out come of the self assessment review Controll managing situation caused by restriction Physical contamination controls Complaints, recalls/withdrawals, internal audit results, enviromental monitoring, product testing, PRP Corrective actions from the self assessment result Additional voluntarymodules if required. (see also appendix 1 BRC073) back back A22AA240-Interim Corona Outbreak BRC Interim Waiver Process Rev.01/03.20 Rev.01 / 03.20
CONDUCT THE AUDIT Instruction for the auditor The Audits The Remote Audit The GMP Audit Is always announced Audit duration as assigned The auditor has to take screen shots from the opening and closing meeting Announced: after restriction is lifted or within 6 month after the audit due date Unannounced: within 2 month after restriction is lifted or within Is announced or unannounceddependingon the option choosen The audit will be focused on the production, storage facilities, vehicle operations (where applicable to the Standard) and operating practices, such as hygiene and product handling. Some supporting documentation will be audited to complete audit trails. As a minimum the auditor will: Verify the process flow, by following the process through the site from goods receipt to product dispatch including storage and production areas Confirm correct operation of CCP s Review non-conformities identified during the remote audit, including subsequent corrective actions, root cause analysis and preventive action Audit all requirements that are colour coded in the Standard to audited as part of audits of production facilities and good manufacturing practice (and the equivalent requirements for Storage and Distribution, Packaging and Consumer Products) A review of requirements for complaints, recalls and non-conforming products back back A22AA240-Interim Corona Outbreak BRC Interim Waiver Process Rev.01/03.20 Rev.01 / 03.20
CONDUCT THE REVIEW Instruction for the veto person Required Documents: As listed on Release Protocoll A22F234 plus: Self assessment checklist from client Waiver Request and Justification A22F240 Participant list: could be a screen shot of the webinar members Evidence of opening and closing meeting: screen shot of the webinar Evidence of start and finish times of the video check of the manufacturing process (e.g. through video screen shot) is good practice. A22AA240-Interim Corona Outbreak BRC Interim Waiver Process Rev.01/03.20 Rev.01 / 03.20
CONDUCT THE AUDIT Instruction for the auditor Audit report Report Template will be offert by BRC for the remote audit and GMP Audit Timelines for NC Managament and report writing and Certification decision remains (28, 42 and 49 days) Certificate: Existing Certificate will be extended but remaining scope, grade, and address upon 12 month Information on Certificate, audit type: Remote Certificate will be issued after remote audit. back back A22AA240-Interim Corona Outbreak BRC Interim Waiver Process Rev.01/03.20 Rev.01 / 03.20