Mandatory Unannounced Audits for BRCGS and IFS

Constanze Illner Food Safety & Hygiene, News, Uncategorized

Earlier this year, the Global Food Safety Initiative published Version 2020 of its benchmarking requirements. The consequences are significant: unannounced audits will become mandatory for all GFSI-benchmarked certification schemes. This includes, but is not limited to, leading schemes such as IFS, BRCGS and FSSC 22000.

The Global Food Safety Initiative (GFSI), founded in the year 2000, aims to find collective solutions to global food safety challenges. One of its main objectives is facilitating the comparability of the different food safety standards. In order to achieve this objective, GFSI has created benchmarking criteria, which scheme owners must comply with in order to achieve GFSI recognition. 

Certification schemes like IFS, BRCGS and FSSC 22000 are currently benchmarked and recognized by GFSI. However, in order for these schemes to maintain that recognition, they must align with the most recent version of the benchmarking requirements and adjust their scheme rules accordingly.

Previous versions of the GFSI requirements specified that scheme owners needed to have the option of unannounced audits. The new version goes one step further: unannounced now become mandatory in regular intervals. 

Unannounced IFS Audits

IFS has updated its doctrines for multiple IFS Standards. The IFS Doctrines are additions or changes to the standard, which become part of the certification requirements. For the following standards, the updated doctrines require one unannounced audit per period of three years:

IFS Food, IFS Logistics & IFS PACsecure

From January 1st, 2021 onwards, at least every third certification audit must be unannounced. The preferred option is to perform an unannounced recertification audit, but it is also possible to do an initial audit unannounced.

To register for an unannounced audit, the certified site needs to inform its certification body before the start of the audit time window. This applies both to sites who remain with their current certification body as to sites who have decided to change to a new certification body.

For IFS Food and IFS PACsecure, it is possible to move the audit time window in exceptional circumstances. However, this may have as a consequence that the validity of the certificate is shortened. Gaps in certification status need to be discussed between the site and their certification body.

If a site lets their certificate expire when their next audit would have been an unannounced audit, and then later resumes certification, their initial audit will need to be an unannounced audit.

Unannounced Audits BRCGS

BRCGS has also published a position statement that makes unannounced audits for the standards BRCGS Food Safety Issue 8, BRCGS Packaging Materials Issue 6, and BRCGS Storage & Distribution Issue 4 mandatory. At least one unannounced audit must now be carried out every three years.

Time schedule

For food safety and packaging materials audits, this regulation applies from February 1, 2021. Issue 4 of BRCGS Storage and Distribution does not come into force until May 1, 2021, therefore the requirements only apply to audits from this point in time.

The regulation only affects locations that use an announced audit program, locations that are already using an unannounced audit program are not affected by the new regulation.

After the certificate has been issued, the certification body will notify the site whether the next audit will take place announced or unannounced. The conversation between the certification body and the location must take place within three months of the last audit.

The unannounced audit can take place at any time during the 4 months prior to the audit due date. This period, during which an audit can occur, includes the 28 days immediately prior to the audit due date. It should be remembered that BRCGS audits cannot take place after the audit due date, except by concession in the event of exceptional circumstances.

A site may nominate a maximum of 10 days when they are not available for an audit. Sites on a 6 month audit schedule may nominate a maximum of 5 days. Days when the factory is not operating (e.g. public holidays or site holidays) are not included with the 10 days (or 5 days). Any such non-production days must be notified to the certification body. Any nominated non-audit days must be for a justifiable reason, for example due to a customer visit for a scheduled first production, which involves technical and managerial staff. By contrast, non-audit due to a specific colleague being absent is not justifiable, nor is booking a single day every week. The dates and reasons must be provided to the certification body as soon as known and at least 4 weeks in advance. The certification body may challenge the reason where this does not appear appropriate and at its discretion refuse these nominated dates if they are not justifiable.

You can access the position statement here. There you will also find detailed information on the audit process.

Unannounced Audits FSSC 22000

For this scheme, it was already mandatory to have one unannounced audit every three years. As of Version 4, at least one of the two surveillance audits needed to be unannounced. This means that the FSSC 22000 scheme already complied with the new GFSI requirement, even before it existed.

How DQS can support

As an accredited certification body for the IFS, BRCGS and FSSC 22000 schemes, we are happy to assist with questions you may have. Contact us to discuss the changes or subscribe to our newsletter, to receive food safety updates on a monthly basis.

Constanze Illner Administrator
Constanze Illner is Research & Communication Officer at DQS CFS GmbH
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Constanze Illner Administrator
Constanze Illner is Research & Communication Officer at DQS CFS GmbH
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