Global Quality Pork Charter Rules

The BMPA Quality Pork Charter underpins the Red Tractor Standards for pork and pork meat products therefore, members who are also Red Tractor License holders may use the following logos on retail packs:

The Red Tractor ‘standards’ logo

• All BMPA Quality Assured Pork (BQAP) and processed pork meat products, as long as each product contains a minimum of 95% BQAP pork:
• Ham and Cooked Pork (Module 4)
• Pork Sausage (Module 5) 

The Red Tractor ‘Pork’ logo

• All products certified by the BMPA Quality assured Pork (Module 2)
• All products certified by the BMPA Quality Assured Ham & Cooked Pork (Module 4)
• All products certified by the BMPA Quality Assured Pork Sausage (Module 5)
• All Pigs-in-Blanket products approved against either the BMPA Quality assured Bacon & Gammon (Module 3) or Pork Sausage (Module 5)

The Red Tractor ‘Bacon’ logo

• All products certified by the BMPA Quality Assured Bacon and Gammon (Module 3) 

The Red Tractor ‘Gammon’ logo

• All products certified by the BMPA Quality Assured Bacon and Gammon (Module 3) 

The Red Tractor ‘Ham’ logo

• All products certified by the BMPA Quality Assured Ham & Cooked Pork (Module 4)

The ‘Made with Red Tractor Assured Pork’ logo: this logo has been discontinued. Where this logo was used, the logo of the characterising ingredient may now be used, where the Red Tractor certified ingredient(s) makes up 94% or less of the finished product (subject to the terms and conditions outlined on the Red Tractor Assurance website).

The Red Tractor logos have been updated from March 2020, and there is an 18-month implementation period from this date to allow for artwork changeover.

Red Tractor logos incorporating the British flag shall only be applied to pork of United Kingdom origin (i.e. pork derived from assured pigs that are born, reared and slaughtered in the United Kingdom). In any other circumstances, contact Red Tractor Assurance for guidance. 

Members of the BMPA pork scheme who wish to display the Red Tractor logo and/or make a Red Tractor claim on their products are required to apply for a license from Red Tractor Assurance. For more information on the use of Red Tractor logos visit Red Tractor, or contact the licensing team at: licensing@redtractor.org.uk. 

The copyright of the charter is held by the BMPA and no unauthorised copying or alteration is permitted. Any queries relating to the charter should be directed to:

BMPA Technical Policy Manager
17 Clerkenwell Green, London, EC1R 0DP
Tel: 020 7329 0776
Email: info@britishmeatindustry.org

The BMPA Quality Pork Charter is owned and managed by the BMPA through its Pigmeat Technical Advisory Committee (PTAC). This committee consists of representation from existing charter participants and other BMPA stakeholders who have the relevant technical knowledge and processing experience to offer guidance in the technical content and ongoing development of the charter. 

The charter provides the pork supply chain with integrity and quality assurance for pork products. Approval and product certification against the individual pork modules and gives assurance to retailers and consumers about the pig welfare, biosecurity, food safety, integrity, provenance and traceability of the pork products they manufacture. The BMPA Quality Pork Charter requirements are above current legislation and are indicative of best commercial practice in line with the recommendations made in the ‘Elliot Review into the Integrity and Assurance of Food Supply Networks’. 

The requirements are periodically updated to ensure that the charter remains current and relevant by providing food manufacturers, retailers and most importantly consumers with quality assured pork and pork meat products. 

The routes for participation in the BMPA Quality Pork Charter are outlined below: 

Charter participants undergo announced and unannouced surveillance audits carried out by BMPA approved service providers who are required to have accreditation to the international standard for bodies certifying products, processes and services (ISO17065) assessed by the United Kingdom Accreditation Service (UKAS). UKAS provide an assurance of the competence, impartiality and integrity of conformity assessment bodies.

The BMPA Quality Pork Charter rules are provided to guide new applicants, Charter participants and service providers through the procedures for application, audit, certification, complaints and appeals that are relevant to its administration and management. The scope of the BMPA Quality Pork Charter rules includes BMPA Pig Welfare, Slaughter and Biosecurity, BMPA Quality Assured Pork (BQAP), BMPA Quality Assured Ham & Cooked Pork, BMPA Quality Assured Bacon and Gammon and BMPA Quality Assured Pork Sausage modules.

It is expected that Charter participants and service providers shall be conversant and compliant with these rules at all times. 

Auditable

The auditable requirements of the Charter rules are highlighted this way, to point out the areas that shall be assessed during audits.

The following interpretation of key words shall be used throughout the BMPA Quality Pork Charter:

Animal Welfare Officer is defined by EC Regulation 1099/2009

Applicant is a site seeking approval against one or more of the pork modules

At cost to the applicant or Charter participant relates to the cost of the audit, certification, mileage, reasonable travel expense and where necessary, hotel accommodation

BMPA Quality Pork Charter certificate of conformity is the documentation issued by the service provider on behalf of the BMPA to the Charter participant which details the name of the site and the products that are approved against the pork modules

Certification period is the specific period that the participant is certified to be an approved participant of a pork module(s) and this runs from 1 April to 31 March each year

Charter participant is an existing Charter member

Core standards relate to the BRC Global Standards (Food Safety and Storage & Distribution) and Red Tractor, Quality Meat Scotland Pigs or an equivalent farm assurance standard recognised by the BMPA

Critical non-conformance occurs where there is objective evidence that indicates that the welfare of the pigs being processed, and/or the safety and legality of the food products being produced is at significant risk. Critical non-conformance would also occur where there is evidence that the Red Tractor logo has been used incorrectly, either knowingly (i.e. fraudulently) or erroneously (e.g. pigs from non-assured farms) and that the integrity of the BMPA Quality Pork Charter and Red Tractor Assurance Scheme is compromised.

Derogation is an exemption from a Charter rule or requirement and all requests shall be communicated to the BMPA and service provider for review before they are granted

Farm assured relates to pigs assured by the Red Tractor, Quality Meat Scotland (Pigs) or an equivalent farm assurance standard recognised by the BMPA

Major non-conformance occurs where there is objective evidence, that indicates that the welfare of the pigs being processed, and/or the safety and legality of the food products being processed could be at risk. Major non-conformance would also occur where there is evidence that the Red Tractor logo could, through lack of control or identification, be used incorrectly (e.g. isolated incidents of missing batch cards) which if not addressed could place the integrity of the BMPA Quality Pork Charter and Red Tractor Assurance Scheme at risk.

May indicates a best practice aspiration that is not a mandatory requirement of the Charter

Minor non-conformance occurs where there is objective evidence that an error or anomaly has occurred against the requirements of Charter, but which does not impact on animal welfare, food safety, product legality, or the integrity of the BMPA Quality Pork Charter or Red Tractor Assurance Scheme

Module Participant Number (MPN) is the coded identity for Charter participants that appears on the BMPA Quality Pork Charter certificate of conformity and on any non-conformance summary reports presented to the BMPA PTAC

Non-eligible material refers to any pork that fails to meet the requirement of the BMPA Quality Pork Charter

Observation is an advisory term that is used by the auditor to describe a situation, during a Charter surveillance audit, where compliance to an individual clause within a pork module has been met but it falls short of the requirements of the BRC Global standard. Observations raised shall be closed out by the Charter participant. 

Pork module(s) is a reference to a specific product standard(s)

PTAC relates to the BMPA Pigmeat Technical Advisory Committee

Quality Pork Charter or Charter is a reference to the collection of the Charter rules, procedures and pork modules  

Renewal notice relates to the notice given to a Charter participant by the service provider to renew certification against one or more of the BMPA pork modules usually 6-8weeks before the next certification period begins

Renewal period relates to the period preceding the expiry date of the participant’s pork module certification

Surveillance Audit is a routine Charter audit (announced or unannounced) carried out by the Service Provider on behalf of the BMPA to seek assurance that Charter participants are compliant with Charter rules, protocols, and derogations that have been approved by the PTAC. Should a derogation be in place at the participants site this will be checked for compliance. 

Spot Check Audit is a non-routine check carried out by the Service Provider or other nominated body, on behalf of the BMPA to investigate concerns that have been raised about certain aspects of the Charter and observations raised shall be closed out by the Charter participant.

Service provider is an independent certification body approved by the BMPA to audit applicants and existing Charter participants against the requirements of the Quality Pork Charter

Standard operating procedure (SOP) a set of step-by-step instructions compiled by an organization to help workers carry out routine operations

Shall is a mandatory requirement of the Charter

SIRA (stable isotope reference analysis) refers to the AHDB Pork stable isotope reference analysis test which allows the country of origin of pork bearing the Union Jack flag, the Red Tractor logo or which is British, to be established.

The shelf life of all chilled pork raw material shall be compliant to that specified within legislation (853/2004). Consideration should also be given to the FSA guidance The safety and shelf-life of vacuum and modified atmosphere packed chilled foods with respect to non-proteolytic Clostridium botulinum. Chill temperature, traceability and shelf-life records shall be maintained.

The table below displays the shelf life that may be permitted for BQAP pork and products within scope of the BMPA Quality Pork Charter modules.

1.1.1 Types of audits – There are three types of traceability audit, which may be carried out on either chilled or frozen product (where applicable).

• Forward trace of non-eligible product which may comprise primal, consumer packs, bulk packs or whole carcases
• Forward trace of assured product which may comprise primal and bulk packs 
• Backward trace of assured product which may comprise primal, consumer packs, bulk packs, or assured product e.g. the assured bacon and pork sausage used in pigs in blankets

1.1.2 Documentation – The auditor shall use appropriate documentation to record the traceability audit information in electronic format. 

A requirement of the BMPA Quality Pork Charter is for the charter participant to undertake traceability and mass balance checks to monitor the robustness of the site’s systems. These checks can either be undertaken in house or by a company acceptable to the scheme however, they shall be carried out by someone who is suitably qualified, competent and independent of the manufacturing operation.

This guidance note provides clarification on the requirement for the competency and independence of internal /external auditors undertaking traceability and mass balance checks for the BMPA Quality Pork Charter. 

1.1.1 Suitably Qualified – There would be no requirement for the person to hold a recognised vocational qualification. It would, however, be appropriate for the company to be able to demonstrate through adequate training records or by interview that the individual undertaking these traceability inspections has received training and/or has relevant experience appropriate to the process chain under audit.

1.1.2 Competency – The individual shall be able to demonstrate to the charter that he/she has a thorough understanding of the process chain. It is also important to establish that they are familiar with the process quality management system relevant to the scope of the site and the processes involved. These shall include relevant traceability documentation, farm assurance web sites and an understanding of the relevant BMPA Quality Pork Charter. 

1.1.3 Independence – The individual shall be independent of the area under audit. The company shall be required to demonstrate through the use of the company’s organogram/job description, the named person’s position within the company’s management structure or if an external resource is used the name of the approved person.

Examples of independence would be:

• Member of the technical team from within the company (where the company has an in-house technical resource)
• An external consultant
• A third party e.g. official veterinarian (OV)

Any extension of shelf life greater than kill+4 days shall be subject to satisfactory documented shelf-life verification (sensory and microbiological evaluation) that shows that the extension of life does not, under worst case conditions, adversely affect product safety or quality. The microbiological limits shall not exceed the levels that will impact the quality and food safety of any finish products. 

NOTE: the UK has a derogation for the extension to the 6-day kill to mince.

The scope of a forward trace of non-eligible products audit covers All BMPA Quality Pork Charter modules

1.2.1 Objective – The objective of the forward traceability exercise shall be to verify that non-eligible raw material has been correctly processed and labelled in accordance with the BMPA Quality Pork Charter. Non-eligible raw material shall be defined as:

• Pork raw material from pigs that have not met the requirements of the BMPA Pig Welfare and Slaughter module (i.e. pigs that are not born and reared for their lifetime on an assured farm that is certified by Red Tractor, Quality Meat Scotland Pigs or an equivalent farm assurance scheme recognised by the BMPA) 
• Boars with a slaughter weight in excess of 110kg.
• Sows may only be used for the manufacture of comminuted meat preparations approved by the BMPA pork scheme e.g. sausage, providing that the pork complies with all aspects of the BQAP product quality standards with the exception of the P2 measurement. Any other use is not permitted within the BMPA pork scheme.
• Pork raw material processed under the Red Tractor or Quality Meat Scotland pork schemes

1.2.2 Selection of product – The auditor shall be responsible for the selection of the product. Product selected for the trace exercise shall be from a previous production date to allow the product to have been processed through to dispatch. The consignment shall be confined to a discrete batch. This shall be interpreted as single pallet, dolav or batch size aligned to the site’s traceability system, aligned to the current audit observations or previous site history. 

The auditor shall have the discretion to select a larger quantity of product for the trace exercise. The charterparticipant shall be required to present all traceability information and weight calculations aligned to the traceability exercise for review. It is important that the information recorded can be cross referenced to the corresponding trace documentation presented by the site. 

There is no requirement to copy sensitive commercial information unless the information is required to support non-conformance. Any copying of sensitive commercial information shall be agreed by the charter participant.

The scope of the backward trace on BMPA quality assured products audit covers the following modules:

• BMPA Quality Assured Pork 
• BMPA Quality Assured Bacon and Gammon
• BMPA Quality Assured Ham and Cooked Pork
• BMPA Quality Assured Pork Sausage

1.3.1 Objective – The objective of the backward trace shall be to verify that incoming assured pork raw material/pork meat products is sourced from a participant of the BMPA Quality Pork Charter, and that the supplier holds a valid BMPA Quality Pork Charter certificate of conformity. It shall be sufficient for the assured backward trace to be verified to the point of intake at the site.  There is no requirement for the backward trace to be verified back to farm. However, to maintain traceability, all pork carcases and raw material shall be accompanied by clearly marked delivery documentation which confirms its assured status and country of birth, rearing and slaughter or statement of pig’s origin. 

Where pigs are born, reared and slaughtered in one country, a single statement of origin shall be sufficient for the traceability declaration. For co-located abattoirs with cutting and packing facilities, the objective of the backward trace shall be to verify that pork raw material is derived from pigs, which have been certified by Red Tractor, Quality Meat Scotland-Pigs or an equivalent farm assurance scheme recognized by the BMPA. 

1.3.2 Selection of product – The auditor shall request to see a copy of the participants’ current BMPA Quality Pork Charter certificate of conformity. Only products that are listed on the BMPA Quality Pork Charter certificate of conformity shall be deemed to be approved. The auditor shall be responsible for the selection of the product for the backward trace. The sample shall comprise a single sample of finished product. Finished product at some sites may be product that is to be despatched to another site for further processing/final packing.

For BQAP, dependent on the scope of the site’s processes the auditor shall choose a use-by date, date of packing or kill date. From the corresponding kill sheet, the auditor shall randomly select three different pig suppliers and verify the status of the haulier, collection centre, country of birth and farm assurance. Where pigs are born, reared and slaughtered in one country, a single statement of origin shall be sufficient for the traceability declaration. The animal movement document shall be included in the backward trace.

Product selected for the trace shall be taken from a different production date and not from product manufactured on the day of the audit unless the surveillance audit is unannounced.  The auditor shall request that all relevant trace information is presented for review. It is important that the information recorded can be cross referenced to the corresponding trace documentation presented by the site. 

There is no requirement to copy sensitive commercial information unless the information is required to support non-conformance. Any copying of sensitive commercial information shall be agreed by the scheme participant. 

A forward mass balance audit shall be undertaken on assured product. A mass balance or quantity check is generally defined as a reconciliation of the amount of incoming raw material against the quantity of finished product taking into account process waste and rework. The finished product shall be aligned to the scope of activities of the pork module under audit. Finished product shall have a different interpretation for an abattoir/cutting plant operation as opposed to a site that that undertakes finished packing of processed product e.g. BMPA quality Assured Ham and Cooked Pork, Bacon or Sausage. 

The scope of mass balance audits covers All BMPA pork modules (including external cold stores)

1.4.1 Objective & frequency – The overarching objective of a mass balance exercise shall be for the site to demonstrate through their traceability systems, procedures and control of operations that the quantity of assured finished product does not exceed the quantity of received assured pork material. The frequency of the mass balance audits shall be aligned to the requirements of the pork module.

1.4.2 Principles of mass balance – It is recognised that manufacturing operations differ; therefore, charter participant may have developed systems for undertaking mass balance specific to the type of operation. The following principles are therefore for guidance only:

Prior to instigating a mass balance challenge the auditor shall take into consideration the complexity of the operations of the site and a reasonable and acceptable volume of product to be challenged. 

• Select a batch or consignment of assured product
• Identify the quantity of assured product supplied with that batch code
• Identify all the final products in which the assured material was used
• Use production records e.g., production planning records, butchery records, recipes, weigh out records to calculate the quantities used
• Account for any known waste, yields reports, residuals or rework
• Calculate the quantity of any unused material held in storage
• Reconcile the quantity delivered against the amounts used including any residual stock unused
• The target for the reconciliation of weight shall fall within the range of 95 to 100%.

1.4.3 Recommended time for reconciliation of data – It is expected that a mass balance challenge shall be completed by the conclusion of the day’s audit.  Where a site is unable to complete the mass balance challenge within the recommended time, a non-conformance shall be raised.

1.4.4 Recording calculations and data – All calculations relating to the mass balance challenge shall be prepared in electronic format by the site and presented for review to the auditor.  The report shall be included as an appendix to the mass balance audit report. See example below, mass balance may be done by both weight and count or a combination of both.

1.4.5 Examination of financial records – The BMPA Quality Pork Charter rules stipulate that a charter participant shall make readily available on request to the auditor, financial records of the company that shall be deemed appropriate where issues have occurred and specifically related to the purchase of pork material. 

The rationale to undertake an examination of the financial records shall be to verify the quantity of pork material purchased against quantity of finished product.  Where an examination of the financial records is undertaken, the auditor shall prepare a short summary report.  In compiling the summary report, the auditor shall make every effort not to compromise the scheme participant’s confidentiality.

1.4.6 Mass balance as part of internal risk assessment – The expectation concerning the annual risk assessment of the participant’s traceability system and procedures is to evaluate the robustness of both product identification, forward and backward traceability and mass balance at each step of the process from intake through to dispatch, and the consequence and corrective actions to be taken if the capability to identify and trace product is lost. (A process flow diagram would ensure that each touch point for traceability is assessed). It should also include a review of the trace and mass balance audits carried out in the previous 12 months, providing evidence of whether the system is effective or not. Evaluation of any non-conformances previously raised, root cause analysis, and corrective actions taken, should take place. This review should highlight any long-term developing trends and thus provide early opportunity for intervention.

One of the core requirements of the BMPA Quality Pork Charter is that all participants shall be compliant with current EU and UK food standards, hygiene and animal welfare legislation and their associated codes of practice.

Auditable

2.1.1 All new applicants and Charter participants shall hold a valid certificate of conformity (minimum Grade B) against the current version of the British Retail Consortium Global Standard for Food Safety (BRC GFS) that shall cover the scope of the operational activities relevant to the Quality Pork Charter and its module(s) and take into account any seasonal lines e.g. pigs in blankets or pancetta that the Charter member or applicant is being assessed against. 

In the case of composite products, e.g. pigs in blankets, each product component i.e. the bacon and the sausage shall be certified against the appropriate pork module. The site at which the composite product is being produced shall have current certification against one of the pork modules. 

Auditable

2.1.2 All new applicants and Charter participants shall inform their BMPA Quality Pork Charter service provider if an external cold store is in use.Where an external cold store is not subject to a BRC GFS audit, the facility shall be accredited against the current version of the BRC Global Standard for Storage and Distribution and the scope of certification shall reflect the activities of the site.

2.1.3 The Charter applicant and participant shall give consent to their BRC status and audit reports being made available to the BMPA through the BRC.

2.1.4 Where a Charter participant’s BRC GFS certification falls below Grade B, is suspended or withdrawn, the participant shall inform the BMPA Technical Policy Manager and provide details of the areas of non-conformance so that the PTAC can decide the appropriate action to be taken in accordance with BMPA Quality Pork Charter rules and procedures.

Participation in the BMPA Quality Pork Charter is open to all abattoirs, cutting plants and further pork processors however, only those that are independently approved by the BMPA for compliance with the requirement of the pork modules shall be certified to the BMPA Quality Pork Charter. There is no obligation for participants to become a member of the BMPA trade association.

2.3.1 Only products listed on the Charter participants’ BMPA Quality Pork Charter certificate of conformity shall be recognised as being compliant to the BMPA Quality Pork Charter requirements and may therefore display the appropriate Red Tractor logo on pack. It is the responsibility of the Certification Body to ensure that the information supplied by the Charter participant meets the requirements of the BMPA Charter. The signing off for new products will not be carried out at the participating site on the day of an audit. 

Auditable

2.3.2 Charter participants who choose to display the Red Tractor logo on their packaging shall be registered for a licence through Red Tractor Assurance prior to applying the logo and where the logo is applied to any new products the licence shall be updated accordingly.

The BMPA in collaboration with AHDB Pork shall use stable isotope reference analysis (SIRA) testing to periodically verify if the pork used in the Quality Pork Charter is British.

• SIRA Sampling Protocol for BQAP Pork and Bacon
• SIRA Sampling Protocol for BQAP Ham and Sausage

Non-eligible material shall be defined as:

2.4.1 Pork raw material from pigs that have not met the requirements of the BMPA Pig Welfare, Slaughter and Biosecurity module (i.e. pigs that are not born and reared for their lifetime on an assured farm that is certified by Red Tractor, Quality Meat Scotland Pigs or an equivalent farm assurance scheme recognised by the BMPA) 

2.4.2 Boars which have a slaughter dead weight of more than 110kg.

2.4.3 Sows may only be used for the manufacture of comminute meat preparations approved by the BMPA Quality Pork Charter, providing that the pork complies with all aspects of the BQAP product quality standards with the exception of the P2 measurement. 

Sow raw material shall not be used for BQAP unless it is intended for the manufacture of processed pork meat products approved within Modules 3 (Bacon & Gammon), Module 4 (Ham & Cooked Pork) and/or Module 5 (Pork Sausage) of the BMPA Quality Pork Charter. For clarification of raw materials please refer to the Charter rules for accredited supply.

Any other use is not permitted within the BMPA Quality Pork Charter.

2.4.4 Pork raw material processed under the Red Tractor or Quality Meat Scotland pork schemes can be used

3.2.1 Charter participants shall inform the BMPA and their service provider if their circumstances change during the period of certification which may affect their compliance with the Quality Pork Charter. For example, a significant change to facilities, management or scope extension etc. The service provider and BMPA shall assess whether a re-audit is necessary to confirm continued suitability for Charter certification. 

All Charter participants shall notify the BMPA and their service provider in writing of any change in contact details. Communication of these changes to the BMPA shall be via email to info@britishmeatindustry.org.

3.2.2 Service of any communication or notice from the BMPA, any appointed representative of the BMPA or service provider, shall be valid if addressed to the last contact address notified to the BMPA by the participant. Notices to the Charter participant may be served by email and shall be deemed to have been served on the same day of transmission. 

3.2.3 Prior to any changes to Charter rules and procedures, or extension of scope within the pork modules, the BMPA shall seek the views of current participants and other stakeholders through a four-week period of consultation. Following this Charter participants and stakeholders shall be notified in writing of approved amendment to the Charter rules or pork modules by the BMPA. Prior to any major change or extension to scope being implemented, the BMPA shall ensure that there is a three-month notice period for existing Charter participants and stakeholders however, there may be extraordinary circumstances where the Charter needs to respond immediately to developments/challenges within the industry and the notice period may be reduced at the discretion of the PTAC. 

Charter participants and service providers shall be issued with a receipt acknowledgement and summary document which details any changes made to the Charter rules, procedures or individual pork modules. Receipt acknowledgement documents shall be signed and dated by the participating site and then returned to the BMPA Technical Policy Manager as evidence of receipt, understanding and commitment to any update. It shall be the Charter participants’ and service providers’ responsibility to ensure that there are satisfactory systems in place for the receipt and dissemination of any revised requirements to appropriate personnel within their business. 

Charter participants shall conduct their business and any dealings with the BMPA and its service providers in an open and transparent manner that supports the integrity inherent to the Quality Pork Charter and its stakeholders. All inappropriate actions or conduct shall be viewed seriously and shall be liable to investigation and action.

Any false or misleading statement and/or conduct during an audit, incident investigation or within any other communication may lead, depending on the circumstances, to Charter participants’ suspension, withdrawal or in extreme cases exclusion from future BMPA Quality Pork Charter participation. 

4.1.1 Charter approval, audit and certification of applicants and existing Charter participants are administered by BMPA approved service providers. Contact details can be found on the Quality Pork Charter application form and the BMPA Quality Pork Charter website.

4.1.2 To assure the quality of service support the BMPA shall set and monitor measurable KPIs for the service providers and performance assessment against these shall take place twice a year at a business review meeting.

4.1.3 Any costs relating to audits shall be agreed between the Charter participant and the service provider.

4.1.4 The service provider shall treat all information relating to Charter applicants and participants including audit reports, in the strictest confidence and shall not divulge this to any third party without the written permission of the Charter participant. However, the service provider shall respond to third parties who wish to confirm the certification status of any Charter participant. 

4.1.5 The decision of the service provider in all matters relating to the administration of the audit and certification process, subject to appeal, shall be final.

4.2.1 Charter participants are permitted to transfer from one BMPA approved service provider to another as long as there are no outstanding non-conformances with the existing service provider. To ensure a smooth transition without compromising the integrity of the Quality Pork Charter or the participant’s period of certification, the following transfer procedure shall be followed:

4.2.2 A formal request for transfer of service provider shall be made through the BMPA. The site shall hold a valid certificate of conformity against the BRC GFS Standard (minimum B grade) at the time of transfer, in addition to holding a valid Quality Pork Charter certificate of conformity aligned to the respective BMPA module. The scope of transfer may be extended to cover all BMPA modules at the site. If valid certificates are not supplied, the Charter participant shall need to apply as a new applicant and a certificate shall not be issued until an assessment has taken place and all the non-conformances closed off. 

4.2.3 Where a current service provider is contacted by a prospective service provider, the current service provider shall disclose all previous assessment and certification information for the new service provider to complete a pre-transfer review. A copy of the current service provider’s BMPA Quality Pork Charter conformance summary report shall be made available to the prospective service provider and all non-conformances including observations shall be closed out prior to any transfer. 

4.2.4 Additional information may be requested for the pre-transfer review including:

• Reasons for seeking the transfer
• Historical audit reports
• Any complaints made, and action taken
• Details of any previous and pending prosecutions. 

4.2.5 Once the transfer has been completed the Charter participant shall return the original Quality Pork Charter certificate of conformity to the relevant service provider. The Charter participant shall have no recourse to the service provider or the BMPA for a refund of audit fees already paid for certification. 

Note: Sites can only transfer once during a certification period.

4.2.6 In the event of a Charter participant obtaining BRC certification from an alternative service provider to that used for Charter certification, the following requirements shall apply:

• The announced surveillance audit shall be undertaken on an alternative day to the BRC audit.
• The Charter participant shall be required to forward a copy of their latest BRC audit report to the BMPA Quality Pork Charter service provider. 
• Where a critical or a major non-conformance is raised against a BRC GFS requirement, the participant shall inform the BMPA and the BMPA Quality Pork Charter service provider without delay. 
• If a non-conformance is raised against BRC GFS at the time of the BMPA Quality Pork Charter audit, the previous BRC report shall be reviewed to ascertain whether the non-compliance is a repeat non-compliance and if this has been satisfactorily closed out. 

The BMPA Quality Pork Charter service provider reserves the right to charge for costs incurred in any administration relating to non-conformance raised against the BRC GFS standard.

5.1.1 All new applications and any scope extensions by existing Charter participants shall be made through the BMPA Technical Policy Manager (see Appendix 1). 

5.1.2 The senior technical representative of the business shall sign the application form. In signing the form, the applicant subscribes to many declarations which constitute a contract with the BMPA to comply with the Charter rules, procedures and specific requirements of the pork modules and relevant appendices. 

Each Charter participant shall be given a unique module participant number (MPN) with the letter confirming the date of audit, approximate time and scope of the audit. On successful completion of the approval audit, the MPN shall be used on the BMPA Quality Pork Charter certificate of conformity. 

The initial audit shall be carried out within 6 months of the date of the application (ideally within 8 weeks).

Under certain exceptional circumstances, the BMPA may allow a derogation from the requirements of the Quality Pork Charter. For this to be affected, the following steps shall be taken:

• The Charter participants shall make an application for a derogation in writing to the BMPA detailing the relevant clause(s) and reasons why the requirements cannot be met, the suggested action to be taken and the timeframe that the derogation is required to be in place until full compliance with the Charter requirements can be achieved
• The BMPA shall, where appropriate, consult the PTAC for a ruling on the acceptance of the suggested derogation and respond accordingly to the Charter participant
• A derogation shall only be deemed as granted once it is confirmed by the BMPA in writing and that the Charter participant has provided written assurance that all conditions will be met and maintained. A copy of the derogation and conditions relating to this shall be forwarded to the Charter participant and service provider for their records. 
• All derogations shall be subject to review once the stated timeframe has lapsed
• Where a derogation has been granted and a subsequent Charter audit or spot check highlights that the conditions agreed with the Charter participant have not been met, the derogation shall lapse with immediate effect
• If a Charter member requires a long-term derogation (for example, using off-site washing facilities), the Charter participant mustrequest that the PTAC consider an appropriate solution. The proposed solution must ensure that the integrity of the Charter is not undermined, and the quality of the product maintained. The PTAC will only consider a long-term proposal if a site is unable to comply due to circumstances that are beyond their control. Any additional premises or sites associated or named in a derogation of this nature shall be included in the scope of the audit for the duration of the derogation.
• It is the Charter participants’ responsibility to ensure that any additional premises or sites associated or named in a long-term derogation conforms to all aspects of the Charter including, where relevant, documentation and internal audits and Charter auditors may, in addition to reviewing this documentation, visit these additional premises.

For existing Charter participants to operate from new premises and manufacture BMPA Quality Pork Charter products approved at a different site, prior to the new site’s BRC approval (usually a new site needs to have been in production for three months before it can be audited against the BRC GFS). The BMPA shall require the following conditions to be met by the Charter participant for a derogation to be granted:

• A request shall be made to the BMPA for a derogation for the new premises and the reasons for this
• The Charter participant shall have a long-standing record of compliance against the BRC GFS and the relevant BMPA pork module
• There shall be evidence that the site has been approved by the relevant licensing authority
• An application form shall be completed and sent to the BMPA for the new site with details of the pork module(s) it intends to manufacture
• A written assurance shall be sent to the BMPA Technical Policy Manager stating that all relevant technical policies, procedures and other systems of operation, including staff training, have been transferred to and operate at the new site
• A written commitment shall be given to the service provider(s) to undertake a BMPA pork module approval audit within 4 weeks of the site opening and a BRC GFS audit within 3-4 months of the site being operational
• The BMPA pork module audit shall incorporate a review of the sites HACCP plan to verify that the food production system is safe

If a critical or major non-conformance is raised against either BRC GFS or the requirements of the BMPA pork module(s) at the time of this audit, then the derogation shall be withdrawn, and the new site shall register as a new applicant in line with the BMPA Quality Pork Charter rules and procedures. Under such circumstances assured product cannot be manufactured until the site has successfully been approved against the requirements of the relevant BMPA pork module.

7.1.1 Participation in the BMPA Quality Pork Charter shall be subject to the successful completion of an initial approval audit, annual announced surveillance audit, unannounced surveillance audit and where deemed necessary, spot check audits (either announced or unannounced) if requested by the BMPA PTAC. 

Where a site’s scope covers more than one BMPA pork module, e.g., bacon and ham, both surveillance audits may be undertaken at the same site inspection. However, depending on the scope of the processes involved it may necessitate the audit program continuing into a second day. 

7.1.2 The service provider shall arrange for the annual BMPA surveillance audit to coincide with the annual BRC GFS audit. An exception to this may apply where the BRC GFS is undertaken by a different service provider or when the surveillance audit is unannounced. Where the service provider is responsible for the BRC GFS audit and the BMPA Charter audit, the service provider shall arrange for the unannounced surveillance audit to be conducted at the time of the BRC GFS unannounced visit. 

7.1.3 A letter confirming the date of audit, approximate time and scope of the audit shall be sent to the site for all announced audits at least 5 working days before the audit date. 

All Charter participants shall make themselves available for audit and this shall take place within one month of the date that the service provider was contacted by the Charter participant. Failure to do so may result in the Charter participant being suspended. If the Charter participant has difficulty agreeing an audit date with the auditor, then the participant shall contact the service provider to explain and resolve the issue. Continued failure to gain access to the site shall be brought to the attention of the BMPA Technical Policy Manager by the service provider with an explanation of the circumstances that have prevented site access. 

If access to site for an unannounced surveillance audit is not possible, the Charter participant shall be liable for the cost of both the cancelled and re-scheduled audit.

7.1 4 A surveillance audit report comprised of a copy of the completed audit checklist, conformance summary report, traceability and mass balance report shall be sent by the service provider to the Charter participant with the confirmation of certification status.

Where a participant wishes to reschedule a pre-arranged audit at short notice, the service provider may charge a fee appropriate to the period of notice. An example of how this is calculated is as follows:

• If an audit is cancelled within 5 working days prior to a confirmed date, 75% cancellation fee is applied
• If an audit is cancelled within 6-10 working days prior to a confirmed audit, 50% cancellation fee is applied

Where a request to re-schedule an audit at short notice is received by the service provider, the full circumstance aligned to the request to re-schedule the audit shall be taken into consideration when a charge is made.

Surveillance audits carried out by the BMPA service provider shall cover the full scope of the relevant pork module(s). This shall require the auditor to talk to staff to establish their understanding and training, and to review relevant processing records, procedures, and traceability records.

The person responsible for the day to day management or a nominated representative who has a full understanding of the operations/processes of the site shall be available to accompany the auditor throughout the audit to answer any queries which are raised.

The auditor shall review products against quality attribute specifications (QAS). 

The Charter participant shall allow the auditor to take copies of relevant records, including financial records (where applicable); to satisfy themselves that the Charter participant is complying with the required undertaking.

If any aspect of the audit cannot be completed on the day of the audit the applicant or Charter participant shall contact the service provider, in advance, to explain the situation and if necessary the audit may be rearranged. If the audit cannot be completed in full on the day of the appointment the application cannot be progressed, and an additional audit fee shall be payable to the service provider for a return audit. 

7.4.1 Where an external cold store is used as part of a ‘process step’ e.g. freezing and/or tempering and where the original batch has been broken down and/or packaging removed, there shall be an announced audit undertaken by the BMPA service provider. The announced audit shall be arranged in conjunction with the Charter participant and a representative of the Charter participant’s site shallbe in attendance. Where possible, the external cold store audits shall be arranged following the Charter participant’s announced surveillance audit.

Auditable

7.4.2 Where the use of a cold store is solely for the chilled or frozen storage of assured pork raw material, work in progress (WIP) or finished product during which time the original batch details remains intact, there shall be no additional audit undertaken by a BMPA service provider. However, the Charter participant shall include the cold store in their supplier approval system, which shall form part of their quality management system aligned to the BRC GFS evaluation.

Auditable

7.5.1 To facilitate traceability, the Charter participant shall demonstrate an understanding of their assured pork supply chain. The supply chain map shall include the name, address and, where applicable, the registration number of each facility processing or storing the assured pork raw materials. Where agents or brokers are used at any point in the supply chain these shall be identified.

7.5.2 The service provider shall carry out a traceability exercise at each surveillance audit and in addition, a mass balance exercise of the assured pork raw material shall be carried out once during the certification period, ideally at the time of the unannounced BMPA surveillance audit. 

An exemption to this requirement shall be made when the unannounced surveillance audit is combined with the BRC GFS unannounced audit. Where the BMPA and BRC GFS unannounced surveillance audits are combined, the requirement to undertake a mass balance exercise shall be deferred and undertaken at the next surveillance audit.

Guidance on traceability and mass balance is given in Appendix 2 and 3 of the BMPA Quality Pork Charter rules.

Prior approval of new products may be granted for the BMPA Quality Pork Charter before the next scheduled surveillance audit. This is done to minimise unnecessary audits, particularly in the case of seasonal products. Where applicable, the Charter participant shall be required to submit the following evidence to the service provider: 

• A copy of the product specification and the documented quality attribute specification (QAS) that has been formally agreed between the supplier and the customer. This may be a shortened version but shall include relevant technical information including product origin
• Examples of QAS inspection records undertaken for the finished product
• Relevant processing records
• Micro and chemical analysis reports of finished product including shelf life
• Artwork approval must be gained from RTA, a copy of finished packaging must be sent
• Any other information the service provider may request to support the prior approval process
• Full backward trace to the point of intake at the manufacturing site

Once the evidence has been verified by the service provider, the site shall receive written confirmation of the product(s) that have received prior approval. 

Products that have received prior approval shall be listed on the certificate of conformity. The service provider shall send an updated certificate of conformity to the participant. On receipt of the updated certificate the participant shall return the previous certificate to the service provider.

The service provider shall review a maximum of 10 products against each module aligned to the system for prior approval. Where the number of prior approvals exceeds the maximum of 10 over the period of certification, the service provider may charge for each subsequent prior approval. These costs shall be agreed between the service provider and the participant. The participant will be cleared to sell Red Tractor Assurance approved product once the certificate has been updated on the Red Tractor website. 

The BMPA may become aware of concerns regarding certain aspects of the Quality Pork Charter or its participants. To address this and to gather more information a Charter service provider, or other nominated body, can be requested by the PTAC to carry out a spot check on one or more Charter participants. By definition the scope of the audit will be variable and is therefore not classed as a surveillance audit. Where concerns are found these will be raised as observations which will require closure by the Charter participant. The PTAC will review the outcome of all such spot checks, on a case by case basis, to decide if further action is required. The BMPA in conjunction with PTAC will decide if audit costs are to be recovered from the participant. 

7.9.1 To assess the quality of delivery of audits by the service provider, the BMPA shall, at pre-determined intervals, seek to request from participants a copy of the completed BMPA Charter audit documentation provided by the site’s nominated service provider. Where a site is a participant of more than one module any such request may be extended to cover the full scope of the site’s certification. 

The audit documentation shall be reviewed by the Technical Policy Manager of the BMPA or an independent reviewer to evaluate the quality of audit reporting. Where a request has been made, the scope of the review documentation shall be confined to the following documents: 

• Conformance summary report
• Audit checklist(s)
• Traceability and mass balance reports undertaken by the service provider

Where the overall quality of content of reporting is deemed not to meet expectations, following the next surveillance audit a further request may be made to the site for a copy of the audit documentation. All audit documentation shall be handled in a confidential manner.

The BMPA shall prepare a summary report of findings following the review and make it available to the service provider.

7.9.2 The BMPA accepts no liability for any error or omission in any information or opinion relating to the provision of the Quality Pork Charter. 

7.9.3  The BMPA and service provider shall not be liable for any potential or estimated loss of earnings by applicants or Charter participants with regard to any audit or the exercise of any of their rights, powers or duties under the provision of the Quality Pork Charter. This includes any losses that arise from any industrial action or the failure of any machine, data processing system, transmission link or any other events outside its reasonable control without limitation.

All non-conformances and observations raised during a surveillance audit shall be assigned minor, major or critical status. Where a non-conformance/observation has been noted during a surveillance audit, it shall be brought to the attention of the applicant or participant at the time by the auditor. The auditor shall detail the findings of the non-conformity within the conformance summary report. 

If more than 10 minor non-conformances are raised during a surveillance audit, this shall automatically be categorised as a major non-conformance.

At the closing meeting, the auditor shall confirm and discuss any non-conformance/observation that has been raised. The Charter participant shall be asked to sign the conformance summary report as acknowledgement of receipt and commitment to address the non-conformance(s).

The following actions shall be taken following the identification of a major or critical non-conformance during a surveillance audit:

8.2.1 The Charter participant shall make every effort to rectify the non-conformance/observation before the auditor leaves the site.

8.2.2 Details relating to the immediate corrective action taken at the time of the audit shall be recorded in the conformance summary report to prevent re-occurrence.

8.2.3 The conformance summary report including the immediate corrective action, shall be emailed to the BMPA by the service provider to the BMPA Technical Policy Manager who shall communicate this information to the PTAC within two working days. Where clarification on the acceptance of the proposed corrective action the PTAC shall make a decision within a further two working days.

8.2.4 Where a critical/major observation is made against the BRC GFS the Charter participant shall inform the certification body responsible for the site’s BRC status.

8.2.5 Where a Charter participant is also certified with Red Tractor Assurance for the use of the Red Tractor logo, the Charter participant shall notify Red Tractor Assurance on the same day.

8.2.6 Where a critical non-conformance is raised, the Charter participant shall not make any claim relating to the assured status of the product until the critical non-conformance is rectified, verified by re-audit and the Charter participant re-instated in line with BMPA Quality Pork Charter certification procedures.

8.2.7 In the event of critical non-conformance being raised, the BMPA Technical Policy Manager shall be kept informed on a daily basis, or as agreed, with the Charter participant until the issue is resolved. 

8.2.8 Where a critical non-conformance is raised or dependant on the number and/or nature of a major non-conformance raised (e.g., where a major non-conformance has been raised due to a site not having a valid Quality Pork Charter certificate of conformity aligned to BRC GFS) and dependent on the previous compliance record, the participant may be suspended from the BMPA Quality Pork Charter and/or be subjected to an unannounced re-audit to verify that the root cause has been established and that the required corrective action has been satisfactorily implemented. 

8.2.9 Where a critical or major non-conformance leads to suspension, this shall be dealt with on a case-by-case basis to protect the integrity of the BMPA Quality Pork Charter. Depending on the circumstances it may be possible that assured product can continue to be despatched under enhanced supervision defined by the PTAC.

8.2.10 If a participant fails to close out a minor non-conformity fully or is found to have given misleading assurance that the non-conformities have been dealt with within the agreed timescale during a subsequence Charter inspection or spot audit, the service provider, with the agreement of the BMPA PTAC may upgrade this non-conformity to a major or critical status, depending on the circumstances.

8.3.1 The applicant or Charter participant shall be required to submit documentary evidence that the root cause for all non-conformances/observations raised has been established and that corrective action has resolved the issue within 28 days. Any observations shall also be subject to root cause analysis and closure within 28 days.

8.3.2 If the closure of non-conformances/observations is successfully demonstrated, the Charter participant shall, within 42 days, receive confirmation of continued certification. Where approval is deferred, not granted or withdrawn, the service provider shall state the reasons for this and provide details of their appeals procedure. 

New applicants wishing to be reconsidered for approval after an initial failed audit shall be required to make a new application.

8.3.3 If any non-conformances/observation are not rectified within the permitted time-scale the Charter participant shall receive a final reminder from the service provider. If following receipt of the final reminder, non-conformances are still not rectified the Charter participant shall be suspended.

8.3.4 Subject to the degree of non-conformity, the service provider may decide that a re-audit is necessary to verify that closure of a critical or major non-conformance has been effective. If a re-audit is necessary, an additional audit fee shall be incurred at cost to the Charter participant. 

9.1.1 Certification shall only be granted to Charter applicants and participants who conform to the BMPA Quality Pork Charter rules, procedures and the specific requirements of the pork modules and relevant appendices.

9.1.2 The certification period for the BMPA Quality Pork Charter is 12 months and it runs from the 1 April to 31 March each year (see Appendix 1). 

9.1.3 Surveillance audits shall not be carried over to the following certification period unless there are extenuating circumstances, in which case the BMPA shall be informed of the reasons in writing in a timely manner and as a minimum one month before the end of the certification period. 

9.1.4 Where an application is made after the commencement of the certification period i.e. after 1 April, the audit fees shall be proportionate to the number of months remaining during the certification period. In calculating the audit fee, the service provider shall take into consideration the number of audits that can reasonably be undertaken during the remaining certification period. 

The BMPA Quality Pork Charter certificate of conformity is not transferable and remains the property of the service provider who issued it. 

10.1.1 Participation in the BMPA Quality Pork Charter is renewed annually. Charter participants shall receive a renewal notice from the service provider 6-8 weeks prior to the 1^st of April each year. 

10.1.2 The Charter participant shall inform the service provider if any products have been delisted from the previous certification period and these shall be removed from BMPA Quality Pork Charter certificate at the time of renewal. New products may be added to the scope during the certification period either through system of prior approval or following approval at the time of the surveillance audit. All requests shall be made to the service provider to amend the certificate accordingly.

10.2.1 Audit fees shall be paid before the due date of the next certification period and cannot be refunded. 

An exception to this could be that, due to commercial reasons, a Charter participant decides to voluntarily withdraw from one pork module however, commits to participation in an alternative pork module on the same site and subject to there being more than three months of the certification period remaining, that portion of the remaining audit fees may be transferred to the alternative pork module less the administration costs incurred by the service provider. 

10.2.2 Once the audit fees have been paid for the next period of certification, the service provider shall arrange to forward the BMPA Quality Pork Charter certificate of conformity for the new certification period to the Charter participant and copy of this shall be held by the BMPA. 

10.2.3 Audit fees are agreed between the Charter participant and service provider prior to the commencement of the certification period. The contract between the BMPA and the service providers shall not exceed a term of three years, and audit fees shall remain the same for the duration of that period.

10.2.4 If the service provider does not receive a renewal remittance within 14 days following the due date, a reminder shall be issued. If a renewal remittance is still not received within 28 days of the due date, the Charter participant may be suspended from BMPA Quality Pork Charter. 

If no contact is made with the service provider before the expiry of the certificate of conformity, certification shall be withdrawn, and the Charter participant shall return the Quality Pork Charter certificate of conformity to the service provider without delay and not make any further claims relating to the BMPA Charter and pork modules. 

10.3.1 Charter participants may decide to voluntarily withdraw their certification. This shall be done in writing to the service provider enclosing the BMPA Quality Pork Charter certificate of conformity and confirming the last date that assured product shall be produced. Where a participant decides to voluntarily withdraw their certification during the period of certification, the participant shall not be entitled to any return of audit fees for the remaining part of the period of certification.

10.3.2 Charter participants who voluntarily withdraw from certification shall cease from the date given to the service provider to make any claims whether explicit or implied, that they or their products are certified against the BMPA Quality Pork Charter. 

10.3.3 Where an approved site is scheduled for closure with no prospect of transfer to an alternative site, the Charter participant shall make the service provider and BMPA aware of the closure date. Once the business has ceased at the site address the Charter participant shall return the Quality Pork Charter certificate of conformity within 14 days of the closure date, to the service provider that issued it. 

11.1.1 Charter participants found to be in breach of the BMPA Quality Pork Charter rules, conditions attached to agreed derogations, procedures or where critical or major non-conformance are raised against traceability, food safety, biosecurity, and/or animal welfare that have the potential to compromise the integrity of the Quality Pork Charter may have their BMPA Quality Pork Charter certificate of conformity suspended or withdrawn, with immediate effect, by written notice from the service provider detailing the reasons for this action.

11.1.2 Where certification is suspended or withdrawn, the BMPA shall contact all stakeholders (PTAC, Red Tractor and the BRC service provider (where this is different to the Quality Pork Charter service provider) to discuss potential implications to on-going manufacture of assured product. Each incident shall be dealt with by the BMPA on a case-by-case basis relevant to the circumstances at that time. 

11.1.3 If satisfactory documentary evidence showing that that all non-conformances have been rectified is received by the service provider within 14 days, suspension shall be lifted. Where re-audit to verify non-conformance closure is required, an additional fee shall be charged at cost to the applicant or Charter participant.

11.1.4 If a suspended Charter participant fails to contact the service provider within 14 days of suspension notification, their certification may be withdrawn. A new application shall then be required if the supplier wishes to be re-certified against the BMPA Charter and pork module(s). 

11.1.5 Any Charter participant who is in breach of any provisions of the Charter rules and/or pork modules may have their certification against the BMPA Quality Pork Charter withdrawn with immediate effect by written notice from the service provider. This notice shallinform the Charter participant of the reasons for withdrawal and shall also provide details of the appeals procedure. 

11.1.6 If certification is withdrawn, the Charter participant shall return the BMPA Quality Pork Charter certificate of conformity to the service provider. If a Charter participant wishes to re-join the BMPA Quality Pork Charter, a three-month waiting period shall be required

In the event of an appeal being made, the service provider shall have detailed procedures that shall be followed. The BMPA would expect the following within this appeals process:

12.1.1 If an applicant or Charter participant wishes to appeal against a certification decision, they shall write to the service provider within 14 days of receiving notification of the certification decision giving the reason(s) why they believe the decision is incorrect and provide any additional supporting evidence that is relevant to the appeal.

12.1.2 The service provider shall contact the applicant or Charter participant to discuss and clarify the basis of the appeal as this may resolve the matter.

12.1.3 If after discussion, the matter remains unresolved the service provider’s certification committee shall appoint an appeals panel consisting of 3 individuals who are independent, impartial and competent to set up a meeting within 30 days of appointment to consider the appeal.

12.1.4 The appeals panel decision shall be sent to the applicant or Charter participant within 30 days and the decision is final and binding on the applicant, Charter participant and/or service provider.

12.1.5 Only one appeal shall be permitted for each specific case.

12.1.6 Costs for an appeal shall be set out in the service provider’s correspondence with the applicant or Charter participant. 

12.2.1 Where a complaint is made to the service provider, the complainant shall do so by confirming in writing the nature and circumstances relating to the complaint.

12.2.2 All complaints relating to the certification process shall be fully investigated and where upheld, appropriate action shall be taken by the service provider. 

12.2.3 The service provider shall maintain a record of all complaints made, investigations undertaken, and actions taken when complaints are upheld and report these to the BMPA Technical Policy Manager on a quarterly basis.