BSI food safety audits during the Coronavirus pandemic (COVID-19)

For operational sites where physical audits can’t take place and not conducting an audit will lead to a certificate expiring, with approval from BSI scheme management, the site’s certificate will be extended for six months. Extensions will be approved by BSI’s BRCGS programme manager and based on documented eight-hour risk assessments which will cover:

1. Certification history
2. The site’s COVID-19 emergency response plan
3. Internal audits
4. Significant changes
5. Customer complaints, recalls and withdrawals
6. Management meetings

Non-conformities can still be raised and shall be actioned by the site as per the standard BRCGS close-out timeframe.

Once the site becomes accessible, the full onsite audit will need to take place as normal

BRCGS Packaging: If your site is certified to Issue 5, the risk assessment will be conducted against Issue 5. When travel restrictions are lifted, a full on-site Issue 6 audit must be conducted as soon as possible.

BRCGS Gluten Free: If your site uses a third-party programme that allows remote audits to underpin the GFCP, the third-party’s remote audit principle can be used.

Unannounced audits: All unannounced audits are suspended and will occur as announced audits.

New or transfer clients: BSI can’t accept new or transferring clients without a physical site visit. Therefore, clients in the process of transferring must return to their original certification body.

Depending on where you are in the certification or audit cycle, BSI is applying different techniques to site located in places where travel and/or access is restricted.

Certification audits: depending on circumstances certification audits will either be postponed by up to six months or take place using remote auditing technology. To qualify for a remote audit your organization will have to show BSI, in advance that your site has the technological capability to support remote audits.

Recertification audits: if a risk assessment shows a low level of risk associated with using remote audit technology this is how your audit will be conducted. An on-site will still be required when the travel and/or access restrictions are lifted. If the risk assessment results don't suggest that remote auditing is appropriate, your certificate may be extended for up to six months depending on the circumstances.

Certification audits: depending on circumstances certification audits will either be postponed by up to six months or take place using remote auditing technology. To qualify for a remote audit your organization will have to show BSI, in advance that your site has the technological capability to support remote audits.

Surveillance audits: if a risk assessment shows a low level of risk associated with using remote audit technology this is how your audit will be conducted. An on-site will still be required when the travel and/or access restrictions are lifted. If the risk assessment results don’t suggest that remote auditing is appropriate, your certificate may be extended for up to six months depending on the circumstances.

Recertification audits: if a risk assessment shows a low level of risk associated with using remote audit technology this is how your audit will be conducted. An on-site will still be required when the travel and/or access restrictions are lifted. If the risk assessment results don’t suggest that remote auditing is appropriate, your certificate may be extended for up to six months depending on the circumstances.

If your Costco audit is normally done using a Costco addendum to a GFSI standard, if that GFSI permits remote audits, your Costco Addendum annual recertification audit will be delivered remotely. How each GFSI programme owner is managing travel restrictions varies, but currently they include certificate extension periods, remote audits and audit postponements.

If your business has put a No Visitation Policy in place, on one email you are required to send your policy to FSA@costco.com and foodglobal.admin@bsigroup.com to be considered for a three-month postponement of your audit.

If your business has temporarily closed, your audit can be postponed but you are required to raise this in an email addressed to FSA@costco.com and your local country BSI Customer Service Officer. You also have to include the date you expect to start production again.

For operational sites where, physical audits can’t take place and not conducting an audit will lead to a certificate suspension or a certificate expiring, the course of action to be taken will be based on a risk assessment. The risk assessment will determine if the certified site has developed/adjusted its procedures and operations to ensure continued compliance to the FSSC Scheme and the supply of safe products.

The documented risk assessment will review:

• The history of the FSSC food safety management system
• Any pending compliance activities or legal proceedings
• Your organization’s current and expected future situation as per IAF ID3:2011
  • Emergency preparedness and response including the impact of the COVID-19, including changes to processes or services outsourced following the COVID-19 epidemic
• Key changes since the last audit
• Performance evaluation:
  • Status of your FSMS objectives
  • Status of the key process performance including, but not limited to, the monitoring and corrective actions of OPRPs and CCPs
  • Management review
  • Internal audits: throughout the pandemic it’s expected that certified organizations increase the frequency of internal audits in support of the FSMS and to ensure food safety
• Customer complaints as well as product recalls and withdrawals

The outcome of your risk assessment will determine the short-term course of action and establish limitations.

Surveillance audits

Low-risk outcome: your v4.1 certificate will be maintained and your surveillance v5 upgrade audit will be postpone by a maximum of six months within the calendar year. The timeframe between the 2019 and 2020 audits can't exceed 18 months. The exception will also apply to the first surveillance audit following an initial certification.

High-risk outcome: your v4.1 certificate will be suspended.

Re-certification audits

Low-risk outcome: your v4.1 certificate will be extended for up to six months. Your full v5 re-certification audit must be completed within the validity extension window with sufficient time to complete the certification process and prior to the expiry of the extended certificate. Your new V5 certificate dates have to be aligned with the current certification cycle.

High-risk outcome: your v4.1 certificate will be suspended.

The opportunity for twelve-month extensions to GlobalG.A.P. certifications are already part of the GLOBALG.A.P. system. To help offset travel and/or access challenges presented by COVID-19, this may be extended by six months using a risk assessment.

There are some circumstances where this extension can't be used, including if:

1. Your site currently isn't producing product and within the extension period you don't expect to sell any product and the next expected harvest won't start before the end of the six-month extension.
2. You haven't confirmed to BSI that your site will continue with the certification after the extension.
3. Your site has a complaint against it that must be investigated on-site.

Corrective actions: if you can provide proof that presenting corrective actions isn't possible within the normal 28-day period, an additional 28-day extension may be granted.

How ISO 22000 audits are managed depends on which type of audit is scheduled.

Stage 1 audits can be conducted remotely, however the stage two certification audit must occur within six months of the stage one.

Stage 2 audits must be conducted within six months of the Stage 1 audit, but remote audits are not allowed.

Surveillance audits can be postponed for up to 6 months from the planned audit date but must take place before 31 December 2020. To be considered for the postponement, a BSI-led risk assessment that results in a low risk rating must be completed.

Recertification audits can be postponed for up to 6 months from the planned audit. To be considered for the postponement, a remote interview and BSI risk assessment that doesn’t identify any major issues. This activity does not replace the actual audit which will still take place after the postponement.

McDonald’s is offering various solutions across their supplier audit programme.

SQMS If your SQMS audit is normally delivered using an SQMS addendum to a GFSI standard, if that GFSI permits remote audits, your SQMS audit will be done remotely. If your business is not audited using a GFSI programme addendum and a physical on-site audit cannot occur, your audit can or may be postponed for 90 days. Please note, the 90-day period will be re-evaluated as the pandemic evolves.

DQMP and GAP audits have been postponed for 90 days. Please note, the 90-day period will be re-evaluated as the pandemic evolves.

Unannounced Category 1 GMP audits will be performed as announced audits.

New suppliers in the onboarding process with McDonald’s are still being asked to meet the usual onboarding requirements at this time.

How travel and/or access issues are managed for RSPO P&C sites depends on what stage you are at in certifying your site.

Initial audits: are postponed until travel and/or access restrictions and on-site audits can take place.

Surveillance and Recertification audits: can be postponed for up to six months. The six-month total is made up of the regular three-month license extension plus an additional three months. To qualify for the additional three months, a remote audit is required. The remote audit does not replace your on-site audit, it only postpones it by the total six-month period.

RSPO remote audits:

• Will not be used where and when on-site audits are possible
• Can only take place after the regular three-month extension has passed, but must take place before the end of the extended three-month period
• Will focus on:

1. The list of RSPO P&C indicators identified by the RSPO Secretariat that can be audited remotely and any major non-conformity must be closed within the timeframes included in the RSPO P&C 2018 or before the license extension submission is made (if this does not happen, the certificate will be suspended until an on-site audit can take place)
2. Assessing the documentation to support the status of any pending non-conformities from your previous audit.

If a travel ban is in place that impacts your site, RSPO is currently allowing remote audits for initial certification, surveillance and recertification audits. When conducting remote audits, documentation review (including the purchase and sales of certified material) will be carried out according to RSPO Supply Chain Standard requirements. PalmTrace management, including License Extension, will be carried out according to the current practice.

BSI can submit a formal request to SQF asking for that change of up to six months is made to your audit date. To support our request to SQF, we must include a documented risk assessment conducted by an SQF-qualified auditor.

The four to eight-hour risk assessment will focus on:

• the level of risk associated with granting the audit date change is sufficiently low
• a document review that adequately supports the risk level rating of low

Unannounced audits: Sites in the third year of their audit cycle that require an unannounced audit can change to an announced audit due in 2020 and have the mandatory unannounced audit in 2021 by notifying BSI.

Surveillance audits: may take place using remote auditing if your risk assessment is low and indicates that your site can support this service, if not the alternative is to apply for six-month surveillance audit date extension.

Woolworths is updating their processes on a regular basis.

The information here only applies to the following WSE audit types: WSE Food Manufacturing Standard, Industry Standards (Egg Grading Floors and Meat – Retail Ready Packing Operations, Feedlot cattle Australia, Service providers), Woolworths Liquor, Woolworths Produce Standard, HARPS, WSE Consumer Goods Program and Woolworths Ethical.

If your WSE audit is scheduled between now and 30 June 2020, the following applies to your site.

If there are no restrictions in place to prevent a BSI auditor from visiting, your audit will take place on-site as planned.

If there are restrictions in place that prevent an onsite audit:

1. A remote audit will be considered and take place provided both your organization and BSI agree.
2. If a remote audit is not possible, a Woolworth’s Quality Specialist (WQS) will complete a risk assessment according to the appropriate option below (a, b, c or d)

a) Annual audit frequency, GFSI base (either accepted or not accepted by Woolworths)
The relevant WQS will risk assess your site’s previous audit history as well as it’s complaints and recall/withdrawal trends. Sites with successful reviews will have a six-month extension applied. If your review is unsuccessful a WQS will contact you to outline audit requirements, which may require a remote audit to be conducted.

b) Biannual audit frequency, GFSI base (either accepted or not accepted by Woolworths)
The relevant WQS will risk assess your site’s previous audit history as well as it’s complaints and recall/withdrawal trends. Sites with successful reviews will have a three or six-month extension applied. The length of your extension will be determined by the quality of your performance. If your review is unsuccessful a WQS will contact you to outline audit requirements, which may require a remote audit to be conducted.

c) Woolworths Supplier Excellence base (standalone) and Harmonised Australian Retailer Produce Scheme (HARPS)
The relevant WQS will risk assess your site’s previous audit history as well as it’s complaints and recall/withdrawal trends. Depending on the results of the review, your will either have to undergo an on-site or remote audit or your certificate will be extended for a three or six-month period.

d) Woolworths FoodCo. Asia WSE
If your organization is a FoodCo. Asia (FCA) site, FCA is managing each supplier on a case-by-case basis, granting extension approval accordingly.