BRC GSFS Reporting – A Fresh Start

Siarl Siviyer Dixon

17 Sept 2013

Quick Question

• A BRC Food audit is about 60 pages long and contains thousands of words of text.

• In an ideal world, which elements would need to be checked each and every time?

BRC Reports – Is There A Problem?

• A history of feedback? Maybe this was insufficient.• Recent feedback from stakeholders:• UK – negative• Clients – negative• Personal experience – negative

• Is it a total disaster? No.• Does it need urgent attention? Yes.

Where are the problems?

• Scopes and exclusions• Actual example of an exclusion: “Processing of snow crab, ground

fish and pelagic products, (squid, caplin mackerel V isually distinct product”

• Dates• Actual example: 21/1/13 in an xml field

• Content• Actual example: referencing a site in Calgary in a Montreal report

(copy and paste?)

• And so on…..• NB – I know the format is a real pain to write up

Key requests from stakeholders

• We need to improve the following according to the BRC Directory administrators:

• write dates using format yyyy-mm-dd in xml fields• complete all fields (first few pages)• do not delete any merge fields• do not remove any rows• do not add additional spaces before/after clauses, times, etc.• for initial audit reports, the previous audit date is “select a date”• seasonal operations should include statement “This is a seasonal operation” under Section 4

“Company Description” to maintain re-audit dates• Use Guideline on limit of characters allowed for each field• One clause number per NC box

• We need to improve the following according to reviewers:• Sufficient content to show compliance against as many clauses as possible• Detailed descriptions to satisfy high risk / high care / low risk clauses and guidance• Properly formatted product safety rationales• Properly written NCs and good root cause analysis• Proper identification of product claims (e.g. organic, kosher etc)

Where is the guidance?

• Example reports (2 available – the BRC version (F003) and GH’s version) – imperfect, we know

• F001: Guidance on completion of the audit report• F048: Understanding High Risk and High Care• BRC026: Understanding Root Cause Analysis &

F004: Guidance on Review of CARs• F033: Guideline for defining wording of scope• F050: Understanding Product Safety Rationale• F042: Position Statements For Issue 6• This is not exhaustive – you are expected to keep yourselves appraised.

You are also expected to glean these documents from the internet yourselves.

What next?

• SSD to be signed off ASAP as report reviewer• SSD to identify other report reviewers (both F/T

and contractual)• “An imperfect world” – therefore there will NOT be

a “zero tolerance” approach nor a “blame culture”• However, we will protect our reputation vigorously• Updates from monthly conference calls held with

the scheme owners at SAI UK will be provided

Questions?

• Any questions? (For those watching the recording please CALL SSD with questions, no email conversations please)

• Auditors have 2 weeks to review this presentation and associated paperwork

• Please sign the electronic agreement at:• Qmidirect.com / my profile / electronic

agreements / training