MSBSR41629 Revision 0, 28 J uly 2008

CLIENT INFORMATION NOTE -

BRC/IoP PACKAGING, ISSUE 3, AUDIT PROCESS

Overview
In this Client Information Note we explain the
key stages of the LRQA process for audit
against the British Retail Consortiums (BRC)
Global Standard for Packaging and
Packaging Materials Issue 3, which we will
refer to below as the Global Standard.
In preparation for the visit, you must have a
copy of the BRC Global Standard for
Packaging and Packaging Materials Issue 3.
You can get this from The Stationery Office,
telephone +44 (0)870 243 0123 or online at
www.tso.co.uk/bookshop/brc.
LRQA will prepare a summary of any
nonconformities during the audit visit,
outlining where your arrangements do not
meet the requirements of the standard, if this
is the case. We will provide a full formal
report after the visit. If you successfully
complete the audit, we will award you a
certificate. Once we have awarded
certification, we will carry out on-going re-
audit visits to maintain your approval.
We will discuss and agree with you visit
dates, start and finish times, the audit team,
visit duration, and the locations we will visit,
before visits take place.
Conduct of the visit
The Auditor will start the visit with an opening
meeting. At this meeting, we will:
explain the LRQA assessment approach
to your management team
confirm the Product category the audit
will be conducted against
request an introduction to your company,
and
agree a visit plan with you.
The auditor will then:
review your quality systems and
procedures, and your Hazard and Risk
Management system
carry out an assessment of the
effectiveness of the implementation of
the documented systems and
procedures, and
carry out a site inspection
We will carry out the audit against the Audit
Checklist (forming part of the Global
Standard) relevant to the specific product
group you fall into. This includes audit of
your arrangements for:
adoption and implementation of your
Hazard and Risk Management system
a documented and effective quality
management system, and
control of factory environment standards,
product, process and personnel.
Conformance with the Global Standard
We will grade the findings of the audit in
accordance with the requirements of Clause
8 of the Global Standard Protocol.
Critical a critical failure to comply with
a product safety or legality issue.
We cannot award a certificate of
approval until you provide satisfactory
evidence to us that you have
implemented corrective action on all
critical nonconformities. Our follow up
must be an on-site follow up visit.
Major a substantial failure to meet the
requirements of a statement of intent
and any mandatory clause of the
Standard. And/or a situation which
would, on the basis of available objective
evidence, raise significant doubt as to


MSBSR41629 page 2 of 3 Revision 0, 28 J uly 2008
the conformity of the product being
supplied.
We can only award a certificate of
approval when you provide satisfactory
evidence to us that you have
implemented corrective action on all
major nonconformities.
Minor absolute compliance to the
statement of intent and a mandatory
clause has not been demonstrated, but
based on objective evidence, the
conformity of the product is not in doubt.
We can award a certificate of approval
when you provide satisfactory evidence
to us that you have taken, or have
planned, corrective action on all minor
nonconformities.
Closing meeting
At the closing meeting, the auditor will:
present a verbal summary of the visit,
and any nonconformities raised during
the visit
confirm the method selected for the
verification of corrective action on any
nonconformities, and indicate what
objective evidence will be needed for
verification
confirm that a certificate of approval will
only be authorised after LRQA has
verified corrective action on any
nonconformities and carried out a full
independent technical review of the
complete BRC Audit Report.
We will ask you to accept any nonconformity
raised. This confirms that they are a true
reflection of the information presented during
the audit.
After the visit
The auditor will complete the visit report off-
site. This report will provide feedback on
conformity with each section of the Audit
Checklist. We will send a copy to you, when
the corrective action has been verified and
the technical review has been completed.
Verification of Corrective Action
In all but exceptional circumstances, the
original evaluator will verify corrective action
on all nonconformities.
If we have raised Critical Nonconformities,
you should take corrective action immediately
and we must verify the action taken before we
can award certification. We can only verify
corrective action at a full re-evaluation visit.
If we have raised both Major and Minor
Nonconformities, we can verify corrective
action by a remote review or by a further visit.
The Auditor will determine the appropriate
method of verification, agree a date for
verification with you, and confirm this in the
Audit Report.
Under normal circumstances, you should
complete corrective action within 28 calendar
days from the date of the audit.
In exceptional circumstances, we can extend
this time up to a maximum period of 90 days.
Such a situation may arise when corrective
action cannot reasonably be expected to be
completed within 28 calendar days (such as
where capital expenditure is needed).
The above assumes that you submit
documented evidence of a corrective action
plan to us. During the period of 90 days, you
must demonstrate significant progress on the
corrective action plan. If we cannot verify
corrective action within 90 days, then a full
re-audit will be necessary before we can
issue a certificate of approval. If you have
not carried out corrective action within the
agreed timescale, we cannot issue a
certificate of approval.
If we have only raised Minor
Nonconformities, and, in the opinion of the
auditor, you have addressed the nonconformity
but not fully implemented corrective action, the
auditor will document this on the nonconformity
record, but leave the nonconformity open to
ensure that we verify the full corrective action
at the next routine audit visit. In these
circumstances, the technical reviewer may
consider the nonconformity to have been
addressed.
Note: If you do not take corrective action in
accordance with these criteria, we will not be
able to authorise an initial certificate of
approval or, in the case of an existing
approval, we will have to suspend or
withdraw the current certificate of approval.
Technical review
All reports are subject to an independent
technical review. The technical reviewer is
solely responsible for the decision to
authorise a certificate of approval. After a
satisfactory review, we will issue a certificate
of approval to you indicating the product
group and scope of the approval.
Ongoing re-audit visits
Approvals under this scheme are subject to
on-going re-audit visits. The number of days
for both the first audit visit and subsequent
routine re-audit visits is the same, as each
visit requires a full evaluation against the
Global Standard.
The re-audit visit frequency may be 6- or 12-
monthly and is determined by the number of


MSBSR41629 page 3 of 3 Revision 0, 28 J uly 2008
major NCNs raised at the previous audit. If
three or more Major NCNs are raised, the
subsequent re-audit will take place at a
frequency of six months.
Certificates
New Approvals
If you meet the requirements with no
nonconformities outstanding, we will issue a
certificate of approval. This will be valid for 6
or 12 months from the date of the initial
evaluation, plus 42 days.
If you do not meet the requirements and
have some nonconformities outstanding, we
will authorise a certificate of approval only
after we have verified corrective action. The
certificate will be valid from the date of the
verification, to the 6 or 12-month anniversary
of the initial evaluation, plus 42 days.
Re-audit
We will carry out annual or 6-monthly re-
audits on or before the re-audit due date
stated on your current certificate of approval
(this is normally the 6- or 12-month
anniversary of the initial evaluation). We will
normally carry out your re-audit within a two
week window before the due date on your
current certificate.
If you meet the requirements with no
nonconformities outstanding, we will issue a
certificate of approval. The certificate will be
valid for 6 or 12 months from the date of
expiry of the previous certificate.
If you do not meet the requirements and fail
to take corrective action, the certificate will
lapse and you will no longer be able to claim
approval.
Suspension and withdrawal
We are required to initiate suspension and
withdrawal if:
we raise a critical nonconformity at any
visit
we raise a major nonconformity against
a fundamental clause at any visit
we confirm information that comes to our
notice regarding a lack of legality or
safety of products covered by LRQA
certification.
Sampling
An important point to remember is that the
absence of nonconformity against any area
of activity does not necessarily imply that no
nonconformity exists. Audit work uses
sampling techniques, and thus statistically it
is possible that issues will remain unidentified
during an audit. Please bear this in mind as
you carry out your own management system
audits.
Confidentiality
We will not disclose any of the information
we gather about your organisation, including
the contents of reports, to any other party
without your written consent, except as
required by the accreditation body or in line
with our contract with the BRC.
To help LRQA to submit reports directly to
designated customers, we will ask you to
complete an authorisation form, either
allowing LRQA to release the report to
designated customer(s), or confirming that
the report should not be distributed.
BRC Global Register
Under the terms of the BRC contract with
certification bodies, LRQA are required to
send the BRC a PDF copy of the BRC
certificate, with contact names and address.
The BRC levy a 75 administration charge to
enter the details on the Register. LRQA will
pass this charge on to their clients.
Accreditation
LRQA is accredited by the United Kingdom
Accreditation Service, UKAS, for BRC
Packaging audits under EN45011.
Further information
To find out more about how LRQA can help
your business meet industry requirements and
stay competitive, please visit the corporate
website www.lrqa.com. Here you can find out
more about our verification services and also
our procedures for complaints and appeals.
From here you can also visit one of our country
specific websites to find out about LRQA in
your country.
For further information on BRC Global
standards, please see www.brc.org.uk.








We have taken care to ensure that the information in this Client Information Note is accurate at the time of issue. However, the
requirements that this document is based on can change. If in doubt, please contact your local office to ensure that you have
the latest version.