THE BRC

GLOBAL STANDARDS

BRC004: REQUIREMENTS FOR CERTIFICATION BODIES

OFFERING CERTIFICATION AGAINST THE CRITERIA OF
THE BRC
GLOBAL STANDARDS

Document Distribution:
BRC Registered Certification Bodies
Participating National Accreditation Bodies
BRC International Advisory BoardGovernance and Strategy Members
BRC Technical Committee Members

Requirements for Certification Bodies

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 Content

1. Introduction
1.1 Purpose
1.2 Relationship to other BRC Documents

2. Registration of Certification Bodies with the BRC and Accreditation requirements

2.1 Application for registration of a Certification Body
2.2 Provisional Recgistrationognition of Certification Bodies
2.3 Extensions to scope for registered Certification Bodies
2.4 Notification of Accreditation Status
2.5 Recognition of Accreditation Bodies
2.6 Pilot Accreditation Schemes
2.7 Inclusion of Certification Bodies and their offices on the BRC Directory

3. Requirements for Continued Registration

4. Contractual Obligations
4.1 Contractual Arrangements with the BRC
4.2 Provision of audit reports and audit results to the BRC
4.3 Contractual Arrangements with Accreditation Bodies
4.4 Contractual arrangements with retailers and other users
4.45 Contractual arrangements between the Certification Body and company to be audited
4.56 Contractual arrangements between the Certification Body and auditors
4.67 Code of conduct and integrity risk assessments
4.78 Logo use, marketing and references to BRC
4.89 Incident Notification
4.190 Liability Insurance
4.101 Documentation Control

5 Communications
5.1 Communication between the BRC and Certification Bodies
5.2 Communication with the BRC
5.3 Updates to Standards, Protocols and Procedures
5.4 Global Standards Conference
5.5 Certification Body Co-Operation Groups
5.6 Communication with Accreditation Bodies
5.7 Communication with BRC audited sites
5.8 Communication with Auditors

6. Performance Monitoring
6.1 Referrals and Complaints
6.2 Review of audit reports
6.3 Independent audits of sites
6.4 Certification Body Office Audits
6.5 Challenge of Auditors
6.6 Additional Costs of Surveillance Activities
6.7 Sanctioning Procedure

7. Certification Body Personnel

7.1 Organisational Structure
7.2 Training on the BRC Global Standards
7.3 Training on BRC Directory
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 7.4 Personnel Involved with the Certification Process
7.5 Auditor Competence
7.6 Sub contracted auditors
7.7 Technical Experts
7.8 Maintaining Auditor Competence
7.9 Product Categories and/or Fields of Audit

Requirements for Certification Bodies

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 1. Introduction
1.1 Purpose

The purpose of this document is to ensure that Certification Bodies are fully aware of:
 their obligations when using the BRC Global Standards
 the requirements for ensuring retention of registration
 the procedures supporting the BRC Global Standards
 the communication network which ensures a consistent and harmonised approach to the
implementation of the BRC Global Standards Schemes
 the performance monitoring, feedback and sanctions undertaken by BRC.
This document will be reviewed at a minimum every three yearsannually by BRC, however and
amendments may be made ed where appropriate.

1.2 Relationship to other BRC Documents

The requirements for Certification Bodies and their relationship with the BRC for the use of the
BRC Global Standards are set out in a series of documents of which this Certification Body
Requirements Document is a part.

When undertaking audits to the Global Standards all requirements within the suite of documents
relevant to that assessment shall be followed.

The contract ‘Framework Agreement’ provides the legal basis for the relationship between the
BRC and Certification Bodies (ie the Company Group).

This document, the Certification Body Requirements document, provides detailed information on
how Certification Bodies shall use the BRC Global Standards and forms an annexe to the
Framework Agreement and therefore forms part of that contract.

The BRC Global Standards – each lay out the criteria to be met for the audit and reporting of
audit result, covered by the scope of that particular BRC Global Standard and the protocol by
which results and certificates may be issued.

Modules - each lay out the criteria to be met for the auditing of modules in conjunction with a BRC
Standard, and the reporting and certification of the audit result.

Participate – is the BRC’s information sharing portal and as such all Certification Bodies, relevant
certification body personnel and auditors shall have appropriate access and use these documents
as reference (see 5.2).

Guidance Documents – Where available provide additional guidance to Certification Bodies,

Auditors and sites seeking an audit on the requirements within particular BRC Global Standards.

Position Statements – Where clarification of interpretation of a requirement of a BRC Global

Standard or its protocol is necessary this will be published on the BRC website
www.brcglobalstandards.com as a position statement and such statements are mandatory in their
use from the date specified for implementation or the date of publication on the BRC website,
where no date is specified.

Best Practice Guidelines and Interpretation Guidelines, where published, provide example
processes and guidance on best practice for demonstrating compliance to the Global Standards
in specific subject areas. These provide a level of expectation of compliance with requirements of

Requirements for Certification Bodies

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 the Global Standards and as such, Certification Bodies and Auditors are expected to be familiar
with, and operate to, the principles and detail which they outline.

Certification Body Bulletin - Regular clarification and updates on ‘operational queries’ are given
via the ‘CB Bulletin’ communications emailed to nominated contacts.

2. Registration of Certification Bodies with the BRC and Accreditation

requirements
2.1 Application for registration of a Certification Body
The use of the BRC Global Standards schemes for audit and certification is only permitted for
Certification Bodies formally registeredcognised by the BRC.
Applications to use the BRC Global Standards are accepted from any Certification Body which is
Accredited to ISO/IEC Guide 65 or ISO/IEC 17065. In conformity with IAF Resolution, a transition
period between ISO/IEC Guide 65 and ISO/IEC 17065 is accepted until 15th of September
2015. After this date, all accreditation will be required against ISO/IEC 17065.
Certification Bodies wishing to register with the BRC need to successfully complete the
application process as outlined in BRC016 which includes an application fee and associated
costs.

2.2 Provisional Registrationcognition of Certification Bodies

Where a Certification Body’s application for registration is accepted for a specified Standard, this
will be provisional and reviewed after 12 months. The Certification Body must meet the following
criteria specified within BRC016 in order to continue to be registeredcognised:-

 Accreditation for the appropriate Standard shall have been successfully achieved and
evidence received by the BRC

 The required minimum standard for the BRC Key performance Indicators (KPI’s) as
specified in the BRC Application for Registration of Recognition for Certification Bodies
with the BRC (BRC016) shall have been achieved.

 The Certification Body shall have at least two BRC registered auditors complying with all
BRC requirements including conducting the minimum number of audits for the scheme.

 Have successfully completed a head office assessment by the BRC

 Have successfully completed a witnessed audit by the BRC.

2.3 Extensions to scope for registered Certification Bodies

Where a registered Certification Body wishes to extend the scope of their activities to include a
new Standard the certification body must submit an application form to BRC as outlined in the
application process BRC 016.

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 Where a Certification Body’s application for a scope extension is accepted for a specified
Standard this will be provisional and reviewed after 12 months. The Certification Body must meet
the following criteria specified within BRC016 in order to continue to be recognised for the new
scope:.-

 Accreditation for the appropriate Standard shall be successfully achieved and evidence
received by BRC

 Have achieved an adequate level of audit report written quality following review

 The Certification Body shall have at least two BRC registered auditors complying with all
BRC requirements in the additional Standard.

2.4 Notification of Accreditation Status

It is the responsibility of the Certification Body to keep BRC up to date with their accreditation
status against ISO/IEC Guide 65 or ISO/IEC 17065. A copy of the accreditation certificate shall
be provided to the BRC.

The Certification Body shall immediately make the BRC aware of removal or suspension by the
Accreditation Body of accreditation against ISO/IEC Guide 65 or ISO/IEC 17065 and this shall
result in removal or suspension of BRC registration until appropriate and agreed corrective
actions have been satisfactorily completed.

2.5 Recognition of Accreditation Bodies

The BRC fully endorses the International Accreditation Forum (IAF) principles of Cross Frontier
Accreditation and actively encourages participation by Accreditation Bodies. The BRC also
endorses the GFSI document GFSI Requirements for the Application of ISO/IEC 17011:2004
which provides guidelines for Accreditation Bodies when assessing certification bodies for
accreditation against GFSI recognised schemes.

Accreditation Bodies offering accreditation for the scope of the BRC Global Standards must be
registered with the BRC. In order for the accreditation of a Certification Body to satisfy BRC
requirements the Accreditation Body must:
 be a member of the European Co-operation for Accreditation (EA) or the Pacific
Accreditation Cooperation (PAC) or International Accreditation Forum (IAF) and
signatories to the Multi Lateral Agreement (MLA) for Product Certification and any other
applicable agreements relevant to the Accreditation for BRC Global Standards.
 be able to demonstrate an approach which ensures that the requirements of the BRC
are understood and effectively assessed as part of the Accreditation process.
 have an agreement in place to respect the requirements of the GFSI Requirements for
the Application of ISO/IEC 17011:2004 for each BRC scheme formally benchmarked
with the GFSI.

The status of Accreditation Bodies can be checked with the BRC.

Registration of a Certification Body by the BRC will only be awarded where their Accreditation
Body is recognised by the BRC.

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 2.6 Pilot Accreditation Schemes

Often when a new BRC Global Standard is developed or an existing standard is taken up in a
new geographical area the Accreditation Bodies choose to operate the accreditation of
Certification Bodies as a group through a pilot scheme. This allows the Accreditation Body to gain
familiarity with the operation of the BRC Global Standard and ensures consistent application.

Where pilot schemes are being operated it is recognised that sometimes the pilot lasts longer
than the usual 1 year permitted for Certification Bodies registered with the BRC to gain
Accreditation. Certification Bodies registered on a pilot scheme will remain Provisionally
Recognised for that scheme until the end of the pilot scheme and will be registered on the BRC
Directory for the duration of the pilot scheme.

2.7 Inclusion of Certification Bodies and their offices on the BRC Directory

The BRC operates a searchable Directory of Certification Bodies www.brcdirectory.com which

enables companies seeking certification to find Certification Bodies registered with the BRC.

Where Certification Bodies operate internationally and have local offices or partners, as part of
their ‘Company Group’ the details of the structure of this ‘Company Group’ shall be defined to
BRC.

lLocal offices can also be registered on the BRC Directory where:-

 The audit and certification processes are covered within the scope of Accreditation of the
Certification Body

and

 The local office has one or more auditors registered with the BRC for the particular BRC
Global Standard (s) for which the office is registered

and

 The nature of the working relationship with the local office is declared in writing to the
BRC e.g. accredited critical location, sub office, sub contracted Certification Body. Further
details including contract details shall be clarified and submitted to BRC on request. It is
the responsibility of the Certification Body to ensure BRC are kept up to date with local
office details.

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 3 Requirements for Continued Registration

Continued registration will be based on continued fulfilment of the requirements covered within
this document and includes an expectation that the Certification Body has a commitment both to
training and investment in personnel to maintain expected standards of performance.
There is a minimum requirement for It is unlikely that Ccertification Bbodies to undertakeing less
than 20 audits per year across all BRC Standards to retain registration.will be in a position to
make a return on the investment needed to maintain the scheme requirements. The BRC will
review the commitment of cCertification bBodies undertaking less than 20 BRC audits within a
calendar year and may withdraw the registration of a Certification Body where this can not be
demonstrated to the satisfaction of the BRC.

Certification Body performance will be monitored through the BRC compliance process. The BRC
reserves the right to remove the registration of Certification Bodies failing to meet the
performance requirements as stated in the KPI procedure BRC009.

4. Contractual Obligations
4.1 Contractual Arrangements with the BRC

A contract known as the Framework Agreement is required between all Certification Bodies
(registered by the BRC) and the BRC. This contract provides the basis by which a Certification
Body can undertake BRC audits and is supported by this document.

4.2 Provision of Audit Reports and Audit Results to the BRC

The BRC maintains a database (the Global Standards Directory) of all BRC audited and
certificated sitesuppliers. This database provides a user specific, fully interactive, web based
system of storage of audit data, both live and archive, which is centrally controlled to ensure
accuracy and integrity. The BRC encourages the use of the Global Standards Directory is the
source of authentication of audit data by stakeholders and the BRCretailers, Certification Bodies
and suppliers and encourages Certification Bodies to promote and support its use. The inclusion
of an Audit Report/ Certificate in the BRC Global Standards Directory should not be construed as
any form of endorsement of the accuracy of that particular Audit or Certification Decision.

The BRC requires a Registration Fee to be collected by Certification Bodies from siteuppliers and
passed to the BRC for every BRC Audit undertaken. Diagram 2 illustrates the process which
should be used to ensure the collection and control of the Registration Fee.

The BRC requires that Certification Bodies submit all completed Audit Reports irrespective of the
outcome in the approved format for that BRC Global Standard to the BRC Directory at the earliest
opportunity after the Certification decision has been made and on request copies of any
certificate issued. On a monthly basis the BRC will provide a report to each Certification Body on
all the supplier audits uploaded and issue an appropriate invoice for the Registration fees.

4.3 Contractual Arrangements with Accreditation Bodies

The BRC works closely with the Accreditation Bodies to ensure that the BRC schemes are being
applied by Certification Bodies correctly and that the integrity and validity of audits, reports and
certificates are not compromised. This relationship is based on the sharing of information.

Requirements for Certification Bodies

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 Certification bodies shall as a condition of registrationcognition by the BRC formally authorise
their Accreditation Body to provide details of assessment activity relevant to the BRC schemes
including assessment reports, non-conformities and auditor details to the BRC.

4.4 Contractual Arrangements with Retailers and other users

A contract may be required between a Certification Body and a retailer or other user. The issue of
this contract shall be at the discretion of the individual retailer/user.

Not withstanding the possible contractual requirements between a Certification Body and a
retailer, the BRC strongly encourages direct contact between Certification Body representatives
and retailers, particularly during the period when the organisation is seeking accreditation. This is
particularly important to establish communication and allow retailers to fully understand the extent
of the Certification Body activities.

4.45 Contractual Arrangements between the Certification Body and company to be

audited

A contract shall exist between the company to be audited and the Certification Body in
accordance with the requirements of ISO/IEC Guide 65 or ISO/IEC 17065 and detailing the
scope of the audit and the reporting requirements.
The contract shall clearly identify that information is required from the site prior to the audit in
order to adequately plan the audit activity. aA copy of the audit report and any subsequent
certificate or audit result shall be supplied to the BRC and where accredited, the Accreditation
Body in the agreed format for the BRC Global Standard used. Certification Bodies must ensure
that their contractual requirements also dictate that all documents in relation to the audit shall be
made available to the BRC upon request. All documents submitted to the BRC shall be copies of
original documents. Documents provided to the BRC will be treated as confidential. The contract
shall also require the company to advise the Certification Body of change of circumstances that
may affect the validity of continuing certification.

The contract shall make it clear that it is a condition of undertaking an audit using a BRC scheme
that the auditor may be accompanied by other personnel for training, assessment or calibration
purposes. This activity may include:
 training of new auditors by the Certification Body
 routine Certification Body shadow audit programmes
 witness audits by Accreditation Bodies
 witness audits by the BRC
 Witness audits by a specifier where a specifier specific additional audit module is
included

The contract shall also state that the BRC reserves the right to conduct its own audit or visit to a
site once certificated in response to complaints or as part of the routine BRC compliance activity
to ensure the integrity of the Global Standard schemes. Such visits may be announced or
unannounced.

The contract shall state that certification status may be affected in the event that access to any
parts of the site or process or requests to these points specified above is unreasonably refused.

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 The contract shall make the site aware that the BRC may contact the site directly in relation to its
certification status or for feedback on Certification Body performance, or investigation into
reported issues.

The contract shall acknowledge any specific requirements for additional audit modules in
accordance with the protocol of those modules. This shall include the confidentiality of
information.

4.56 Contractual Arrangements between the Certification Body and Auditors

Contracts shall exist between the Certification Body and all auditors, whether directly employed or
subcontracted to ensure:
 auditor integrity
 confidentiality of information
 impartiality/conflict of interest
 adherence to the certification body code of conduct
The Certification Body shall have systems in place to ensure auditor compliance to legal
requirements and applicable laws including data protection where applicable.

When employing new auditors satisfactory references shall be obtained from the previous
employer. The BRC reserve the right to refuse registration of an auditor on a temporary or
permanent basis in its sole discretion.

4.76 Code of Conduct and Integrity Risk Assessments

BRC requires all parties conducting business related to the BRC Global Standards whether as a
registered Certification Body, auditor, trainer, employee or subcontractor to behave with integrity
and in a fair, honest and ethical way.

The BRC expects all Certification Bodies to have systems in place to address these issues, which
are documented in a suitable ‘Code of Conduct’ and risk assessed as part of an integrity audit.

The systems in place will cover:

 Confidentiality of information
 Compliance with legal requirements regarding transparency, ethical requirements, anti-
corruption and bribery which apply in the country/ countries of trading
 Avoidance of conflicts of interest
 Address bribery and detail acceptable and unacceptable practices
BRC requires that Certification Bodies have in place a system of regular monitoring and take
action if non compliances are detected. BRC requires Certification Bodies to inform them in a
timely manner if an issue is discovered that has, or may affect the integrity of any of the
certificates / audit outcomes that the Certification Body has conducted.

BRC retains the right to investigate any Code of Conduct issues brought to its notice with the
Certification Body and requires them to take the appropriate steps if any violations are
determined. This may include removing the registration of the Certification Body or removal of
registration of specific offices or auditors if, after investigation, it is determined that they are not
following their Code of Conduct.

Certification Bodies or their personnel may also have contracts with other BRC business units for
example Training. Where issues arise with the integrity of Certification Bodies, their local offices
or their personnel such information will be shared with other BRC business units.
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 4.87 Logo Use, Marketing and References to BRC

The BRC issue logos for use to registered Certification Bodies. All logo usage rules must be
adhered to. Logos must be removed from all communications immediately when requested by
BRC.

BRC actively encourages marketing of the BRC name and Global Standards, however, it is
requested that Certification Bodies make every effort to ensure logos used, material referenced
and statistics quoted are accurate and up to date. Certification Bodies are encouraged to
communicate with the BRCs marketing department.

The BRC name or logo shall not be misrepresented or used in any manner that could be
misconstrued or be defamatory to the BRC.

Certification Bodies are requested to promptly report misuse of BRC logos or the BRC name by
certificated siteuppliers or any other third party, to BRC for investigation.

Diagram 2

4.98 Incident Notification

As part of the contractual relationship with certificated siteuppliers the siteupplier shall notify the
Certification Body of any impending prosecution with respect to product safety or legality or of a
public product recall. The Certification Body in turn must take the necessary steps to fully
understand the implications of the situation and take appropriate actions. This may include a
further visit to the site, further full audit, suspension or withdrawal of the BRC certificate. The
Certification Body shall have a documented procedure for dealing with incident notification. If
there is a likelihood that the legal proceedings will lead to adverse publicity or Government
intervention, the Certification Body must inform the BRC immediately.
The BRC also expects the Certification Body to have in place a system to proactively scan
relevant information such as RASFF and FDA and have a process in place in which to identify
their certificated sites and react where product recall, prosecution or adverse publicity has been
highlighted which may adversely affect BRC or the Certification Body.

4.910 Liability Insurance

Certification Bodies must ensure that appropriate liability insurance is in place. This insurance
shall incorporate employer’s liability, public and product liability and professional indemnity. A
copy of the relevant insurance certificate must be sent to the BRC with registration on application
and as requested by BRC.

4.101 Documentation Control

All records and documentation related to BRC Global Standards audits shall be retained by
Certification Bodies for a minimum of five years (in the case of the Consumer Products Standard
this may be for up 21 years as appropriate). Certification Body personnel and training records
shall be retained for a period of 5 years after the cessation of employment of the relevant
individual.
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 The types of documents which shall be retained include but are not limited to:

 Contracts between the Certification Body and site audited

 Documentation relevant to deciding the audit duration and allocation of auditor
 Auditors notes and versions of audit report from the audit where different from the final
report
 Final audit report
 Evidence of correction of non conformities provided by the site
 Notes relating to decisions on acceptance of documentary evidence
 Notes relating to the decision on audit result/Certification
 Copy of the certificate issued
 Evidence of any supplementary audits, visits or correspondence with the site relating to
the maintenance of certification during the duration of the certificate issued
 Records relating to auditor qualifications and competency
 Records of auditor witnessed assessments.
 Records of complaints or appeals

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 5. Communication
5.1 Communication between the BRC and Certification Bodies and ‘company group’

Applications for the registration of Certification Bodies with the BRC shall include the name and
contact details for the nominated Certification Body contact – ‘the BRC scheme technical
specialist’ according to BRC041, their deputy and an organisation chart. The nominated contact
will be used as the primary contact by the BRC for the transmission of information about the BRC
Schemes. It is essential that the contact details are maintained up to date.

Where Certification Bodies offer audits to the BRC Global Standards through a network of local
offices the additional offices and their structure within the ‘Company Group’ shall also be detailed
to the BRC and kept up to date. The channels of communication between the BRC registered
Certification Body and their affiliated offices shall be clearly defined.

BRC require a confirmed list of sub offices within the company group and the relationship to the
head office eg whether an accredited critical location, subcontracted Certification Body, whether
wholly owned or joint venture. BRC require the contact details of the senior contact person at
these offices. Any BRC direct contact with these sub-offices shall be copied to the principal
Certification Body contact.

It is expected that the nominated Certification Body contact(s) will be responsible for
disseminating information from the BRC within the organisation including to auditors and sub
offices as appropriate. BRC reserves the right to contact directly any specified persons in sub
offices within the company group.

5.2 Communication with the BRC

Where information is provided in hard copy all correspondence should be addressed to the
Compliance Manager
British Retail Consortium
nd
2 Floor
21 Dartmouth Street
London
SW1 9BP

Telephone: +44 (0) 207 854 8900 Fax: +44 (0) 207 854 8901

The Management Structure of the Global Standards team can be found on the BRC Global
Standards website http://www.brcglobalstandards.com ‘Meet the team’/about-the-standards/brc-
team/

The BRC has a dedicated Customer Services Administrator supported by a team of Technical
Directors and Managers. Questions relating to interpretation and operation of the BRC Global
Standards should in the first instance be directed to the Global Standards Customer Services
Administrator on the team mailbox enquiries@brcglobalstandards.com@brc.org.uk

Queries relating to use of the BRC Directory, upload of audit data to the database or related
invoices should in the first instance be directed to the Directory team at
submissions@brcglobalstandards.com.org.uk

Queries relating to training and BRC examination processes should in the first instance be
directed to the BRC Academy at training@brcglobalstandards.com

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 5.2 Subscription to BRC Participate

BRC Participate allows access stakeholders to view content online from all BRC publications
including BRC Global Standards, Interpretation Guidelines, Sector Guidelines and supporting
documents. All the content is mapped across publications providing easy reference and guidance
for auditors. Certification Bodies shall, as part of the contractual arrangements with the BRC,
ensure that they continue with the subscription of BRC participate to ensure access is available to
auditors and appropriate certification body personnel.

5.3 Updates to Standards, Protocols and Procedures

From time to time the BRC will issue new or revised requirements in relation to the BRC Global
Standards or documents supporting these Standards. The BRC will make Certification Bodies
aware of these changes via the nominated contact provided.

All supportive documentation (ref 1.2) will be issued by the BRC and, when requested to do so,
the Certification Body will confirm acceptance of specific information. Where appropriate such
documents will also be displayed on the BRC Global Standards website
www.brcglobalstandards.com log in members area or BRC Participate. Certification Bodies shall
ensure that information is communicated to their clients and staff within their organisation as
appropriate.

5.4 Global Standards Conference

On an annual basis the BRC will hold a conferences for Certification Bodies to discuss issues
relating to the BRC Global Standards and to provide information on current developments. These
may occur on a number of continents. Certification Bodies shall as part of the contractual
arrangements with the BRC send the BRC technical specialistan appropriate representative to
attend this annual conference relevant to their continent, in order to keep themselves up to date
with the latest information.

Where local conferences or invitations to specific events such as meetings or webinars are set up
by the BRC, the Certification Body is expected to attend.

5.5 Certification Body Co-operation Groups

The BRC actively encourage involvement of Certification Bodies in the development of the BRC
schemes to assist in the continuous improvement of BRC Global Standards and supporting
documentation.

In some countries the Certification Bodies have formed Co-operation Groups, to promote
communication and co-operation between the BRC, its members and Certification Bodies. Details
of Co-operation Groups are available from the displayed on the member’s area of the BRC
website.

The Co-operation Group(s) have a direct interface with the BRC Global Standards Technical
Advisory Committee(s) and provide a forum which the BRC consults for advice on changes to the
standards and supporting processes.

Where Co-operation Groups have been established it is expected that all registered Certification
Bodies in that Country/Region shall play an active part through attendance at meetings.

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 The BRC actively encourages the establishment of new Co-operation Groups where none
currently exist in a country or region. The BRC will provide any relevant information to assist in
the formation of new Co-operation Groups.

5.6 Communication with Accreditation Bodies

In order to facilitate effective Accreditation of Certification Bodies the BRC may share some data
with the Accreditation Body responsible for the accreditation of that Certification Body. This may
include:-

 Summary information on audits undertaken – names of certified sites, audits by country,

by auditor, by field/category
 Lists of auditors registered with the BRC by field/category
 Complaints or referrals submitted to the BRC which following investigation with the
Certification Body are considered to be justified
 Results of performance monitoring activities
 Information resulting in the temporary suspension or removal of registracognition of a
Certification Body

To assist the sharing of information Accreditation Bodies are permitted limited access to the BRC
Directory. Certification Bbodies shall allow their Accreditation Body access to their Directory
information

5.7 Communication with BRC audited sites

The BRC may contact certificated sites directly to ask for feed back on the audit and certification
process as part of the Certification Body performance monitoring process. The BRC may also
contact sites directly to review certification status in the event of investigation of issues, or
suspension or withdrawal of Certification Body registration.

5.8 Communication with Auditors and Other Certification Body Personnel

The BRC reserves the right to request contact details of auditors or other personnel involved with
a BRC audit and to contact them directly. The Certification Body shall provide such contact
information on request and shall ensure that consent has been obtained from the relevant
personnelauditor to pass their contact details to the BRC for this purpose. The BRC all notify the
Certification Body in due course having contacted the personnelauditor.

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 6 Performance Monitoring
The BRC is committed to maintaining the reputation and integrity of the BRC Global Standards.
The competence and capability of the accredited Certification Bodies and their auditors is critical
to this objective.

The BRC will monitor the performance of Certification Bodies to try to ensure that the BRC Global
Standards are being applied consistently, that audits are undertaken to the required protocols and
that the information required for users of the certificates and reports is provided in a timely
manner.

Performance monitoring may include, but is not limited to:

 The review of audit reports, audit data and certificates for quality and consistency
 Undertaking of audits of siteuppliers either independently or witnessing of auditors
 Audits of Certification Body head offices and sub offices within the company group
 The review of auditor competency records
 Challenge of auditor competency through practical tests
 Adequate provision of BRC requested data eg quarterly reports

 Audited Ssiteupplier feedback surveys

 Referrals and complaints
 The timely supply of information on audited sites to the Directory
 Contributions to development of the BRC Global Standards and protocols e.g. through
marketing activities, participation in working groups and Certification Body co-operation
groups.
 Communications with BRC

Key Performance targets for the operation of the BRC Global Standards will be agreed in writing
between the BRC and Certification Bodies and form part of the contract. Reference KPI
Procedure BRC009. Overall performance of Certification Bodies will be published and made
available to users of the BRC schemes. Detailed performance information on individual
Certification Bodies is made available for discussion to the BRC Global Standards International
Advisory BoardsGovernance and Strategy Committee and relevant Technical Advisory (TAC)
Committees for each Global Standard.

Where a Certification Bodies performance does not meet the agreed standards the Certification
Body may be suspended or removed from the scheme. Reference Suspension procedure BRC
014.

6.1 Referrals and complaints

The BRC actively encourages communication between interested parties to ensure issues are
resolved satisfactorily and to receive reports on performance. To ensure that any interpretation
issues, enquiries and disputes are resolved effectively and efficiently, the BRC has implemented
a formal referral process which is available to all organisations actively involved with the BRC
Global Standards.

BRC also have a confidential reporting hotline for employees, sites, clients and other
stakeholders to report concerns they may have about a manufacturing site that is certificated
against a BRC Global Standard. TELL BRC is available 24 hours a day, 7 days a week, 365 days
a year on +44 (0)20 7717 5959 answered in English, Spanish and Mandarin from our London-
based call centre.
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 complaints can also be notified through the complaints form and submitted to
enquiries@brcglobalstandards.com. Reference referral procedure BRC005.

From time to time, failure to apply the principles and criteria of the BRC Global Standards at
audited sites may be reported to the BRC by, for example, retailers and suppliers conducting their
own audits, or other agencies. Reference referral procedure BRC005.

In this event, the BRC will undertake appropriate action dependent on the issues raised which
may include:
 undertaking its own audit or visit to the site or Certification Body (announced or
unannounced)
 accompanying the Certification Body to the site on a visit or audit (announced or
unannounced)
 or requesting a documented report from the Certification Body following an investigation
Failure to address any valid issues raised in the referral to the satisfaction of the BRC will result in
sanctions.

Where a complaint is considered by the BRC (in its sole discretion) to have been justified, costs
relating to the additional work undertaken may be charged back to the Certification Body. The
information relating to a justified complaint will be made available to the Accreditation Body for
that Certification Body.

The BRC will notify the person referring the issue of the outcome of the investigation and ensure
closure of any issues raised.

6.2 Review of Audit datareports

There are agreed report formats and guidance documents for each BRC Global Standard which
prescribe the presentation and levels of information required in a report for that BRC Global
Standard.

The BRC will carry out reviews of a sample of audit reports and/or audit data available from the
BRC Directory to ensure the quality and consistency of the information provided. Where audit
datareports do not conform to the agreed standards this will be discussed with the Certification
Body responsible. Inadequate audit reports will not be accepted onto the Directory and it will be
the responsibility of the Certification Body to rewrite and resubmit any such reports.

Where the BRC request further information to support information given in the audit report, for
instance copies of original notes these shall be provided and where necessary parts or all
translated within 10 working days of request.

The BRC cannot however be held responsible for the accuracy of the information contained
within the audit reports which is the responsibility of the Certification Body submitting the audit
report.

6.3 Independent Audits of Sites

As part of the routine compliance programme, Iin response to referrals or complaints or where
concerns have been raised by BRC following compliance activities, the BRC reserves the right to
undertake audits or visits to an audited site as deemed appropriate by BRC. These may be

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 announced or unannounced and be full audits or part thereof. BRC may undertake these
independently or accompany the auditor of the Certification Body.

Where a complaint or poor performance is found by the BRC (in its sole discretion) to be justified
and the fault of the Certification Body, the costs of these visits will be covered by the Certification
Body.

6.4 Certification Body Office Audits

Following compliance activities, tThe BRC may undertake visits or audits to the Certification Body
head office or any localsub office or partners to investigate specific issues or undertake a full
audit orf BRC requirements. This may be announced or unannounced. Any costs relating to
additional work undertaken in relation to an investigation where justified by the BRC (in its sole
discretion) may be charged back to the Certification Body The costs of the visit will be covered by
the Certification Body.

6.5 Challenges to Auditor competency

The BRC may undertake an assessment of an auditor’s competency by witness audit, telephone
interview or examination to ensure that an auditor’s knowledge and or skills are adequate to audit
against such standards. The routine review of audit reports, data analysis from the Directory or
complaints from customers may identify concerns with an auditors approach, calibration or
understanding of the relevant BRC Global Standard. The BRC may undertake an assessment of
an auditor’s competency by witness audit, telephone interview or examination to ensure that an
auditor’s knowledge and or skills are adequate to audit against such standards. Any such
challenges will be organised in association with the Certification Body and the results made
available to the Certification Body and auditor concerned. It may be necessary in some
circumstances for the BRC to temporarily suspend audits by an auditor until an assessment has
been undertaken. Certification Bodies may be required to undertake appropriate corrective action
with the auditor such as additional training or further witness audits to be demonstrated as
completed to the satisfaction of BRC within an appropriate timescale for the auditors continued
registration to be confirmed. In exceptional circumstances the registration of an auditor may be
removed at the sole discretion of BRC.

6.6 Additional Costs of Surveillance Activities

The costs of Aany additional work undertaken by BRC in response to the requirement for review
or increased surveillance due to poor performance will be recovered fromcharged back to the
Certification Body. The BRC will outline to the Certification Body the estimated costs of such
additional activities.

6.7 Sanctioning Procedure

The emphasis of the Certification Body performance review procedures shall be to assist
Certification Bodies to comply with the scheme rules and protocols of the Standards and
therefore promote confidence in the BRC Certification Schemes.

Wherever a Certification Body’s performance falls short of a specified requirement this will be
brought to their attention. It is expected that any shortfalls are addressed by the Certification Body
and an acceptable plan provided to the BRC to correct issues. Confirmation that action has been
taken or, in exceptional circumstances an action plan, shall be provided by the Certification Body
within 10 working days. BRC shall review any plan and evidence submitted within 10 working
days of receipt.
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 Appropriate sanctions shall be put in place and may include but not be limited to:
 Increased surveillance or review processes by BRC or the Accreditation Body
 Requesting additional controls / reviews are put in place by the Certification Body
 Ensuring auditors are accompanied on audits by an appropriate witness auditor either
from the Certification Body, BRC or the Accreditation Body

6.7.1 Temporary Suspension

Poor performance against the BRC KPIs (ref BRC009), Rrepeated failures, a failure to co-
operate in the investigation of an issue, failure to address an issue satisfactorily or the occurrence
of a significant failure which could bring the scheme into disrepute will result in the suspension of
a Certification Body or a specified local office or partner.. The suspension may be for a single
BRC Scheme or all BRC Schemes depending on the nature of the issue.

Reference Suspension and Withdrawal of BRC registrationcognition from a Certification Body

procedure BRC014.

Suspended Certification Bodies will have their details removed from the Directory website
pending the satisfactory resolution of the issue(s) which had caused suspension.
Notice of status of suspension will be posted on the BRC Directory and Global Standards
websites to allow existing and potential clients to be aware of the Certification Body status.
Retailers and specifiers of the BRC schemes, members of the BRC International Advisory Board
and the Technical Advisory Committees for the relevant Schemes shall also be notified by BRC of
the change in status of that Certification Body. Certification Bodies shall agree with the BRC the
communication plan for certificated and future clients.

No audits against the BRC scheme may be carried out and no certificates issued whilst a
Certification Body is under suspension.

The Accreditation Body responsible for the suspended Certification Body will be notified of the
suspension and reasons for this so that the issues can be followed up at surveillance audits as
necessary.

6.7.2 Removal of registrationcognition of a Certification Body

The removal of registrationcognition of a Certification Body, its local office or partner may occur
where:
 a suspended Certification Body fails to adequately rectify the issues leading to their
suspension
 there is a significant issue affecting the credibility of the audit standards
 there is a significant continued failing of performance against the KPIs
 there is a breach material to section 12 of the Framework Agreement
 the Certification Body no longer has the resources to continue to operate a scheme
according to BRC requirements eg sufficient registered auditors
 the Certification Body does not fulfil the requirements of section 3

 a repeated failure of performance – a second suspension

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  removal of Accreditation by the Accreditation Body for the relevant BRC schemes

The removal may be for a single BRC Scheme or all BRC Schemes depending on the nature of
the issue. The permanent removal of registrationcognition will be subject to ratification by the
BRC Global Standards Trading Board.Governing Board of BRC Global Standards. Reference
Suspension and Withdrawal of BRC registrationcognition from a Certification Body procedure
BRC014.

Where the withdrawal of registratcognition of a Certification Body has been ratified, the BRC shall
contact the certificated sites affected to advise them accordingly. The Accreditation Body shall be
informed so that accreditation for the applicable Global Standard is also withdrawn.

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 7. Certification Body Personnel
7.1 Organisational Structure

Certification Bodies shall have a nominated Manager ‘the Technical Specialist’ whom shall have
accountability for the activities for the BRC Scheme as defined within BRC041 who is responsible
for the management of the BRC Global Standard schemes and for communication with the BRC.
A deputy shall also be identified.

There shall also be at least one nominated senior auditor or manager who shall be the technical
contact point for auditor calibration activities.

An organisational chart shall be available which identifies the key roles in relationship to the
management of the BRC Global Standards to include the following responsibilities:
 Nominated BRC contact person and deputy
 Manager for the BRC contact person
 Manager responsible for maintaining Accredited Quality systems
 Person(s) or committee responsible for making Certification Decisions
 Person(s) responsible for Training on BRC schemes (where appropriate)
 Persons responsible for approval/shadow auditing of auditors
 Persons responsible for review of audit reports and / or corrective evidence (if
appropriate)
 Auditors
7.2 Training on BRC Global Standards

Certification Bodies must ensure that a sufficient level of understanding of the BRC Global
Standards exists within their organisation at all times.

All staff with a key role in the certification process i.e. the review of reports and/or corrective
actions and making a decision on the audit outcome shall have completedattended the
appropriate BRC training. course as required by that issue of the BRC Global Standard.Staff
making a decision on the audit outcome ie the ‘certification decision’ shall and Wwhere
certification decisions are made by a committee at least one member of the Committee, shall
have attended the appropriate BRC course delivered by a BRC Approved Training Provider
(ATP) and passed the relevant examination (as the auditor requirement). The Certification Body
shall ensure that processes are in place to keep appropriate staff up to date with communications
from BRC as specified in 1.2.

7.3 Training on BRC Directory

All staff with a key role in use of the BRC Directory, whether for upload of audit data or
implementation of auditor data shall be fully conversant with the system. A large quantity of
training materials including videos is available on the ‘Information’ tab of the Directory. All
administrators should have successfully passed the Directory ‘User Tests’ available. Additional
training is available at cost.

7.4 Personnel Involved with the Certification Process

All staff with a key role in the certification process i.e. the review of reports and/or corrective
actions and making a decision on the audit outcome shall have an appropriate working technical
knowledge of the processes sufficient to evaluate the audit report and outcomes eg those
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 involved in certification to the Packaging Standard shall understand the key risks and control
processes as well as an understanding of relevant legislation.

7.5 Auditor Competence

Every person undertaking certification audits must have the appropriate qualification, training,
experience and skills to perform an audit against the relevant BRC Global Standard. Auditors
shall have attended the appropriate BRC course delivered by a BRC Approved Training Provider
(ATP) and passed the relevant examination.

The qualifications, training and experience will differ according to the product and technology
covered by the scope of the individual BRC Global Standards. However, the auditing skills will not
differ and shall be monitored to maintain a high standard.

The BRC requires Certification Bodies to register all auditors, through the BRC Directory auditor
profile system, with the BRC and to provide details of the Fields and/or product categories in
which they are qualified to audit. The initial registration and regular updating of information is the
responsibility of each Certification Body. Audits will only be accepted where carried out by a
registered auditor. The BRC Directory shall be used as the master listing specifying the fields
and/or product categories for which an auditor is validated.

A fee may be charged for the registration of auditors with the BRC.

Certification Bodies shall hold a detailed and complete skills matrix for all auditors undertaking
audits on their behalf and this shall be in accordance with their published Accreditation Schedule.

Records shall be maintained demonstrating how auditors comply with the requirements for
qualifications, training and experience defined for any BRC Standard for which the auditor
undertakes audits. Records shall be made available to the BRC on request.

Under exceptional circumstances auditors may be approved by the BRC where they do not fully
meet all of the requirements for competency and training. Justifications and supporting evidence
for the approval of the auditor must be provided to the BRC before the auditor is nominated to
audit to a particular BRC Global Standard and/or Field/Category.

Where the justification is accepted the Certification Body will be notified in writing. A summary of
such exceptions will be presented to the relevant TAC for scrutiny.

7.6 Sub Contracted auditors

Where auditors are not fully employed by the Certification Body but work on a sub contracted
basis all of the requirements detailed within this document relating to auditors shall apply.

Contracts shall exist with such sub contract auditors to ensure that confidentiality of information
and impartiality/conflict of interest are maintained as per a full time employee.

Where sub contracted auditors are used their work shall be covered by indemnity insurance to
the levels stated within the Framework agreement.

7.7 Technical experts

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 Where a Certification Body does not have an auditor with suitable knowledge to qualify as an
auditor for a particular Field or Category, an audit may be carried out using an audit team made
up of an experienced auditor registered for that particular standard and a Technical expert.

The Technical expert shall meet the following criteria:

 Contracted to the Certification Body for the work undertaken which shall include clauses
to ensure the confidentiality of information and prevent conflict of interest.
 The Technical expert shall meet the criteria for work experience as laid out in the auditor
qualifications for the particular BRC Global Standard, field and /or category where the
expert is to be used.
 Shall have completed a training course in HACCP or Risk Management as defined in the
auditor requirements for the applicable standard or have demonstrable competence in
HACCP/Risk Assessment.
 Shall have received background training on the applicable BRC Global Standard from the
Certification Body or other party.

The Certification Body shall maintain on file evidence of the experience and qualifications
justifying the person’s status as a Technical expert. This shall be made available on request to
the BRC.

The role of the Technical expert within the assessment team shall be clearly defined and the
qualified BRC auditor shall be considered as the team leader. The Technical expert must be
accompanied during the audit by the Lead auditor.

The name of the Technical expert and auditor shall appear on the BRC report.

7.8 Maintaining Auditor Competence

Certification Bodies must be able to demonstrate that they operate programmes for ensuring that
the skills and knowledge of auditors are maintained through:
 on site assessments (witnessed audit program)
 calibration meetings/exercises to ensure consistent interpretation of requirements
including BRC calibration webinars as available
 ensuring auditors are kept up to date with legislative and technological changes in the
scopes in which they audit
 the conduct of a minimum number of audits per year (as defined in individual Standard
competency requirements).
 Completion of examinations where available and as required by BRC and specific
Standard protocols.

7.8.1 Witnessed audit programmes

Certification Bodies must have an audit programme for the on-site assessment of auditors to
ensure compliance to BRC018..

This programme must also ensure that each auditor is assessed on-site at least once every two
years and over a four year period for each BRC Global Standard for which he/she is considered
to be competent.

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 The onsite assessment programme shall be designed to be representative of the range of Fields
of audit for which the Certification Body is Accredited.

7.8.2 Calibration

Certification Bodies shall operate programmes to ensure the internal calibration of auditors to
ensure consistent interpretation of the Standard and non conformity grading. This should be
through organised meetings (real or web based) or through the use of calibration exercise.
Calibration meetings shall be carried out at least once per year.
Certification Bodies shall ensure that an appropriate representative participates in calibration
processes organised by the BRC and cascaded to all auditors as appropriate.

7.8.3
Certification Bodies shall ensure that appropriate systems are in place to clearly state
requirements for conduct and that systems are in place to monitor its compliance. Reference
section 4.6

7.9 Product Categories or Fields of Audit

Individual BRC Global Standards may have specific defined categories or fields within the overall
audit 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
categories. Certification Bodies must demonstrate that their staff have the knowledge and
expertise to work within these fields or categories, have had . Certification Bodies must also
demonstrate that appropriate training and where applicable comply to the relevant BRC protocols
to ensure that for auditors has been undertaken before assigning them to any are registered with
BRC for additional product categories or fields for which they previously did not have the relevant
product knowledgeprior to auditing in these categories or fields. Where available, auditors must
have successfully completed the category examination to continue auditing within the specified
category.

The importance of product categories and fields of audit as well as auditor qualifications,
training and experience cannot be over emphasised and for the BRC, its members and
other Global Standard users, these are essential criteria, which are required to support a
legal due diligence defence.

Change to document
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EN45011 to ISO17065

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