Ref : GLT.GRP.

008
SABMiller plc Group Technical
Page: 1 of 13

Version : 0
Title: Group Deviation Management Procedure Version Date: 14th June 2010

Owner: Group Technical Scheduled Review:1 June 2014

Contents
1 Version & Revision History......................................................................................2
2 Purpose.................................................................................................................. 3
3 Scope...................................................................................................................... 3
4 References............................................................................................................. 3
5 Definitions............................................................................................................... 4
6 Deviation Situation, Type of Approval Required and Authorisation.........................5
7 Process of Deviation Management.........................................................................6
7.1 Concessions..................................................................................................6
7.2 Permits........................................................................................................... 7
7.3 Injunction.......................................................................................................7
7.4 Brewery Passport Recording of Injunction..................................................7
7.5 Record Keeping & Reporting.........................................................................7
8 Appendix................................................................................................................. 8
8.1 SABMiller Standards - Specification Structure...............................................8
8.2 Example of a Composite Concession / Permit / Injunction Form.................10
8.3 Blank Composite Concession / Permit / Injunction Form:............................12
8.4 Examples of Completed Concession / Permit / Injunction Forms................12

POSITION NAME SIGNATURE DATE

Originator Head of Technical Stewardship A.J.L. Kennedy May 2010

Review Group Chief Brewer B. Axcell June 2010

Approval Global Technical Forum c/o T van Kralingen June 2010

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Title: Group Deviation Management Procedure Version: 0
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1 Version & Revision History

This is the original Version.

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2 Purpose

As a Global Brewer, SABMiller will set and maintain technical standards regarding quality,
corporate governance and the environment, safety and operational excellence and there is the
clear intention that standards should be achieved at all times. However, it is recognised that for
various reasons this is not always possible and the Deviation Management System exists to
formally recognise deviations, and to ensure there is a formal record of the appropriate
management decisions taken with regard to non-conforming materials, processes and product.
Use of this Deviation Management System will ensure that:

Across our business there is a standard procedure to deal with deviations from SABMiller
Technical Standards;
Any Packaged Product that does not conform to quality specifications has a formal record
regarding its release or destruction;

There is a formal business process to authorise a temporary deviation from SABMiller

Technical standards.
This system will assist the company in maintaining good technical governance, systematically
addressing underperforming suppliers, plant and processes, and maintaining control over
operating standards.

3 Scope

The Deviation Management system shall apply to all Technical operations (Brewing, Packaging
and Utilities) in SABMiller. This includes specific or unique standards that may be contained in
Brand or Franchising standards. The system covers materials, process / equipment and
packaged product.

4 References

The following documents are useful SABMiller reference documentation (philosophies, polices,
procedures, methods and standards), which should be read in conjunction with this procedure.
Global Brewing Philosophy (GLT.BR.03)
Brand Technical Footprints (Developed at HUB level for each brand)
Group Technical Auditing Procedure (GLT.GRP.010)
Brewery Passport (GLT.GRP.009)
Global Brewing Standards
Global Packaging Standards
Global Engineering Standards
The complete list of SABMiller documentation that is philosophies, policies, procedures,
standards and methods can all be found in a single document on the Global Portal use the
following link to access this document.
http://webrew.gcn.local/functions/technical/ourways/Pages/home.aspx
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All brewing related documents can be accessed via the Home Brewing Page on the Global
Portal. Using the following links takes you to this page,
http://webrew.gcn.local/functions/technical/whatwedo/brewing/Pages/FreqUsersPg.aspx
All Packaging related documents can be accessed via the Home Packaging Page on the Global
Portal. Using the following links takes you to this page,
http://webrew.gcn.local/functions/technical/whatwedo/packaging/packstandards/Pages/home.aspx
All Quality related documents can be accessed via the Home Quality Page on the Global Portal.
Using the following links takes you to this page,
http://webrew.gcn.local/functions/technical/whatwedo/quality/Pages/home.aspx

5 Definitions

Concession A concession is a management authorised document to accept material, continue

processing in process product or to release for sale a batch of packaged product which fails to
meet SABMiller Standards. The concession applies only to that specific batch of material. A
concession is requested after the material or product has been produced.
Permit A permit is a management authorised document to allow the manufacture of materials,
operation of a process / equipment or the release of packaged product that does not comply with
SABMiller Technical Standards and is authorised before the material is made / the process
operated / the product packaged. A permit has a maximum duration of one year.
Injunction An injunction is identical to a permit but has a duration of greater than one year.
Passport A document produced by each SABMiller Brewery which holds key operational
information relating to that brewery including a complete list of Brewery Injunctions.
Standard Parameters These are defined as important parameters for which upper and lower
specification limits are set.
Critical Parameters - These are defined as parameters which can be considered injurious to
health, critical to consumer quality and/or detrimental to the brewing and packaging process for
which absolute Upper and or Lower Outer Limits (Material, Process or Brand Limits) are set.
Target - This is the desired value, and is the mean value that inputs / outputs should be aimed at
achieving.
Specification Limits - This normally comprises the Upper Specification Limit (USL) and Lower
Specification Limit (LSL), and specifies the amount of variation from the Target that is permitted
for the material, process or product to be considered normal.
Outer Limits Is the general term that refers to Material Limits, Process Limits and Brand Limits.
All parameters that have outer limits are called critical parameters.
Material Limits - These are known as Upper Material Limit (UML) and Lower Material Limit (LML)
and their attainment is deemed critical in order to assure product food safety standards, a safe
operation and overall brand quality standards.
Process Limits - These are known as Upper Process Limit (UPL) and Lower Process Limit (LPL)
and their attainment is deemed critical in order to assure product food safety standards, a safe
operation and overall brand quality standards.
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Brand Limits These related to packaged product and are known as Upper Brand Limit (UBL)
and Lower Brand Limit (LBL) and their attainment is deemed critical in order to assure product
food safety standards and overall brand quality standards.

6 Deviation Situation, Type of Approval Required and Authorisation

The following two tables provide a summarised view of the different situations, which may occur
with materials, process / equipment or packaged product, in relationship to a deviation from
Lower and Upper Specification Limits and Lower and Upper Outer Limits (Material Limits,
Process Limits or Brand Limits).

Out of Specification Limits

(but within Outer Limits (Material Limits / Process Limits / Brand Limits) where these exist)
Situation Type of Approval Minimum Authorisation Level
Required

One-off batch produced

Concession Level 1 Brewery Management

Continuous production
fixable in < 12 months Permit Level 2 Brewery Management

Continuous production Will

not fix or fixable or fixable in >
Injunction Hub Management
12 months

Table 1: Deviation Approval Out of Specification Limits

Out of Outer Limits

(Material Limits / Process Limits / Brand Limits - where these exist)
Situation Type of Approval Minimum Authorisation Level
Required

Materials & In Process

- One-off batch produced Concession Level 2 Brewery Management

- Continuous production
fixable in < 12 months Permit Level 3 Brewery Management

- Continuous production -
Will not fix or fixable in > 12 Injunction Hub Management
months
Packaged Product
All situations NO SALE / RELEASE PERMITTED

Table 2: Deviation Approval Out of Outer Limits (Material, Process or Brand Limits)
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The following table indicates the job roles relating to Minimum Authorisation Level

Minimum Authorisation Level Recommended Job Roles

Level 1 Brewery Management Area Manager

e.g. Brewhouse Manager or Bottle Line 1
Manager.
Level 2 Brewery Management Department Manager
e.g. Brewing Manager or Packaging Manager.

Level 3 Brewery Management Brewery General Manager, or

Brewery Technical Director, or
Brewery Manufacturing Director
Hub Management Hub Technical / Manufacturing Director and
Hub Functional Head (e.g. Chief Brewer for
Brewing Standards and Packaging Consultant
for Packaging Standards)

7 Process of Deviation Management

7.1 Concessions

A concession is a formal request to accept material, continue processing in process product or to

release for sale a batch of packaged product which fails to meet SABMiller Standards. The
concession applies only to the specific batch of material or product referred to and does not apply
to any future batches, which may have similar defects. A concession is normally requested after
the material or product has been produced. The decision to authorise a concession is a
management decision and is not automatic.
The Concession system is particularly useful for:

Ensuring that no material is accepted, in process product is processed or packaged

product is released to trade without appropriate management attention;
That recurring problems are highlighted and so forming the basis for effective problem
solving.
Characteristics of a good concession system:

The process is formally documented

Each concession is acknowledged

Where appropriate, corrective action is identified

A periodic review is conducted (Pareto analysis) to identify the main causes of non-
compliance
Able to be audited

There is a list of approved signatories

There is a clear record of what happened to the product (e.g. destroy / release)
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7.2 Permits

A permit to accept material, produce in process product, to run a process / operate equipment or
release packaged product that do not comply with SABMiller Standards may be requested when
circumstances arise which preclude normal production expertise from achieving the Technical
Standards set by SABMiller. The permit only sanctions the deviation temporarily and specifies the
degree of deviation allowed and the duration of the permit. An approved permit will be issued with
an expiry date, and this is never longer than one year after approval. A permit is requested before
the product is made and includes the proposed corrective action.
The Permit system is particularly useful for:

Highlighting plant / process deficiencies that preclude the achievement of manualised

standards. These permits should form the basis of on-going capital and maintenance -
spend decisions;
Highlighting technical problems so that problem solving and process improvements
projects can be initiated.
The granting of a permit DOES NOT replace the manualised standard. If product is produced
outside the specification with permit approval, it is still out of specification. The only change is that
management approval has been given for this condition to exist for a fixed period of time and
temporary specifications have been set.

7.3 Injunction

An Injunction is identical to a Permit in all aspects other than,

the duration,

the requirement to record the injunction in the Brewery Passport, and

to make available the complete list of injunctions by brewery to the Global Technical
Forum (GTF) on an annual basis.
The injunction is used where the deviation is indefinite (that is will not be fixed until the equipment
is totally replaced at the end of its usable life) or the duration of the noncompliance is greater
than one year.

7.4 Brewery Passport Recording of Injunction

All breweries within SABMiller will be required to complete a Brewery Passport. This document
will hold key operational information relating to the Brewery. One section of the document will
contain the complete list of Brewery Injunctions.

7.5 Record Keeping & Reporting

In addition to the holding of Brewery Passports, Hubs / Breweries should keep records of all
concessions, permits, injunctions and management decisions that have been applied for and the
resulting management decision. The records should be reviewed at least annually and maintained
for three years after approval.
Each Hub will make available to the Group Functional Forums (Brewing Operations Network and
Packaging Coordinators Group) and the Global Technical Forum on an annual basis by brewery
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the numbers of permits closed and the number of permits opened along with a complete list of
Injunctions.

8 Appendix

8.1 SABMiller Standards - Specification Structure

SABMiller uses the following structure to describe specifications and allowed tolerances for all
Standards (Material, Process and Packaged Product):

Target: This is the desired value, and is the mean value that inputs / outputs should be
aimed at achieving.
Specification Limits: This normally comprises the Upper Specification Limit (USL) and
Lower Specification Limit (LSL), and specifies the amount of variation from the Target that
is permitted for the material, process or product to be considered normal.
All parameters in a Standard have specification limits.
Parameters which only have specification limits are known as Standard Parameters.
Parameters which have specification limits and outer limits are known as Critical
Parameters.

Outer Limits (Material Limits, Process Limits and Brand Limits): All Critical Parameters
have Outer Limits to ensure that our commitment to material, process and brand integrity
is maintained. These Outer Limits have different names depending on the specific
standard.
o Material Limits These are known as Upper Material Limit (UML) and Lower
Material Limit (LML) and their attainment is deemed critical in order to assure
product food safety standards, a safe operation and overall brand quality
standards.
o Process Limits - These are known as Upper Process Limit (UPL) and Lower
Process Limit (LPL) and their attainment is deemed critical in order to assure
product food safety standards, a safe operation and overall brand quality
standards.
o Brand Limits These related to packaged product and are known as Upper Brand
Limit (UBL) and Lower Brand Limit (LBL) and their attainment is deemed critical in
order to assure product food safety standards and overall brand quality standards.
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The following diagram indicates the specification structure for Standard Parameters

LSL USL

A
B B

Fig 1: Specification Structure for Standard Parameters

(T = Target ; LSL = Lower Specification Limit ; USL = Upper Specification Limit)

Zone A: Results here are in specification. The mean of the process should be aimed at
the target value (T).
Zone B: Results here are out of specification.

The following diagram indicates the specification structure for Critical Parameters

LOL LSL USL UOL

X T X

A
B B

Fig 2: Specification Structure for Critical Parameters

(T = Target ; LSL = Lower Specification Limit ; USL = Upper Specification Limit ; LOL = Lower
Outer Limit ; UOL = Upper Outer Limit)

Zone A: Results here are in specification. The mean of the process should be aimed at
the target value (T).

Zone B: Results here are out of specification.

Beyond Zone B: Results here are out of specification and out of Outer Limits that is
Material Limits, Process Limits or Brand Limits.
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8.2 Example of a Composite Concession / Permit / Injunction Form

The following is an example of a form that could be used by a Brewery / Hub.

Breweries / Hubs are permitted to use there own system as long as it covers all the aspects as
indicated in the form below.
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The following points should be noted with regard to the use of these forms:

Document number all deviation management forms must have a unique identification
number. The Hub should define the numbering system to use.
Date date of application.

Brewery identifies the producing site.

Standard Name and Number refers to the relevant SABMiller Technical Standard.

Actual or Estimated Quantity some deviations are time based, some may be quantity
based.

Parameter the item that is deviating from the standard is described here.

What is the reason for the deviation from the standard? explain why the need for the
deviation has arisen.
What is the planned corrective action? as all deviations are granted for a define quantity
or fixed time duration, it is required that there is a plan of action to correct the deviation
from the manual. This will vary, and could include problem solving exercises, capital
expenditure, maintenance spend and even a request for a revision to the manual standard
in the case of continuous improvements.

Potential impact of deviation the person applying for the permit must consider what the
potential impact to the business is of allowing the deviation from the manualised standard.
This allows for a review of the risk / benefit position.
Expire Date (Permits only) permits should have a fixed date for closure.

Comments or Special Conditions this may be required in order to maintain good

governance.

8.3 Blank Composite Concession / Permit / Injunction Form:

Master Deviation
Managment Form

8.4 Examples of Completed Concession / Permit / Injunction Forms

Examples - Deviation
Management Form