8 Non-conformances

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.