Due to the additional confidence provided by unannounced audits, the GFSI Benchmark Version 2020 introduces a new requirement for unannounced audits.
Certified organizations with GFSI benchmarked standards (BRCGS, IFS) active in food safety, packaging materials or storage and distribution areas should have at least one unannounced audit every 3 years. This means that all organizations that are certified with the above standards, must receive at least one unannounced audit during the period of 2021-2024, with subsequent unannounced audits to be carried out at least once every 3 years.
The protocol for unannounced audits is included in each standard separately.
Companies certified with BRCGS standards
The requirement applies to all BRCGS standards that are GFSI benchmarked, thus:
– BRCGS food safety issue 8
– BRCGS packaging materials issue 6
– BRCGS storage and distribution v4
ASDA module: mandatory unannounced audit.
Other AVMs, e.g. FSMA + Meat Supply: follows the rules of the main BRCGS inspection
For companies that achieve C or D in their audits (certificate duration 6 months), there is still a requirement to receive an unannounced audit every 3 years, but in these cases there will obviously be a higher number of announced audits in the meantime.
The year (but not the exact date) on which the company will receive unannounced audit will be agreed between the company and the certification body.
When the organization decides to participate in the unannounced audit program, it notifies the certification body within 3 months from the last audit date, so that the audit application is compatible with the window in which the unannounced audit can take place, i.e. 3-12 months after the last audit. The audit usually takes place during the last 4 months of the audit window.
Each company has the right to exclude 10 working days, during which the unannounced audit cannot be carried out.
The requirement of unannounced audits also applies to companies that operate seasonally. In these cases, the audit is carried out during the production activity of the company, and for this reason, the details of the production period must be notified by the company to the certification body and update them with any changes. In case the production period is less than 4 months, the total number of days that the company can exclude is reduced proportionally, e.g. if for a company the production period is 2 months, then the days it can exclude are 5 instead of 10.
Companies certified with IFS standards
The requirement applies to all IFS standards that are GFSI benchmarked, so:
– IFS Food issue 6.1 & 7
– IFS Broker issue 3
– IFS Logistics issue v2.2
The year (but not the exact date) on which the company will receive unannounced audit will be agreed between the company and the certification body.
To register a company to receive an unannounced audit, the company must notify the certification body 4 weeks before the unannounced audit window opens. Given that this is [- 16 weeks, + 2 weeks] from the previous audit, the request for unannounced inspection must be lodged with the certification body 20 weeks before the anniversary date of the previous inspection. In case of audits carried out for more than one day, the audit is carried out on consecutive days.
Companies reserve the right to exclude 10 business days, which may not be included in the audit days. These 10 days cannot be “broken” in more than 3 periods, i.e. the 10 days can be consecutive, or be in different periods (up to 3), e.g. 5 + 2 + 3, or 3 + 3 + 4, or 9 + 1. The days that the company wishes to exclude are notified to the certification body, together with the days on which the company does not operate, e.g. weekends, 4 weeks before the unannounced audit window opens, which is [- 16 weeks, + 2 weeks] from the anniversary day of the previous audit.
Companies that operate seasonally, have no right to exclude days and the rule [- 16 weeks, + 2 weeks] from the anniversary day of the previous audit does not apply. In these cases unannounced inspection may take place at any time during the production season.
In the event of an interruption
of the certification cycle where an unannounced audit was to be performed, the
next certification audit (= initial audit) must also be performed unannounced.
Audits carried out in more than one day, the audit is carried out on consecutive days.
Special requirements exist for companies with multiple production units and central management. Briefly:
- Headquarters / central administration are evaluated either by an announced or by an unannounced audit.
- The assessment of the headquarters/central administration is always carried out before the evaluation of each production unit and is carried out before the start of the unannounced audit.
- The evaluation of the production units is done only without warning.
- When the headquarters and the central administration are evaluated through an announced audit, the announced audit of the central administration and the unannounced audit of the production unit will not take place on consecutive days (eg if the headquarters is located in one of the production units, there will be two (2) different audits: an announced audit for the centrally organized processes and an unannounced audit for the production unit).
- When the headquarters and the central administration are evaluated through unannounced audit, the unannounced audits of the central administration and the production unit can be organized to take place on the same day, e.g. if the headquarters is located within one of the production sites, there may be an unannounced audit which covers both the centrally organized processes and the production unit. This audit will begin with the production unit processes.
- All inspections, including headquarters, will be carried out within a maximum period of 12 months.
- If an unannounced audit fails and does not result in the issuance of a certificate, the next inspection should be announced.
- If only one major non-conformance (Major) is documented during an unannounced audit, the subsequent audit to confirm the measures taken to address the major non-conformance will be announced.