Global Quality Pork Charter Rules
7 Surveillance audits and spot checks
Last Updated: 7 Jan 2022.
7.1 Timing and reporting of audits and checks
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.
7.2 Re-scheduling an audit
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.
7.3 Scope of an audit
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 Auditing external cold stores
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.
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.
7.5 Auditing traceability in a supply chain
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.
7.6 Frequency and scope of internal audits
7.6.1 All Charter participants shall carry out an internal audit of their site and process a minimum of once per certification period against each of the specified requirements of the relevant BMPA pork module(s) for which they have been certified to produce. Where internal audits are being undertaken against the BRC GFS, it is recognised that the scope of this internal audit programme will already cover many of the control points stated within the pork module(s) and it is not expected that these common areas of control shall be subjected to separate internal audit programmes.
7.6.2 However, the degree to which the BRC GFS internal audit programme overlaps with the BMPA Quality Pork Charter internal audit requirement will vary from site to site dependent on the format of the internal audit programme, the products being produced, and the pork module(s) against which the site is certified. The Charter therefore requires that Charter participants shall complete:
- A documented gap analysis of the sites internal audit programme to identify which areas of the Pork Module(s) are not captured within the sites BRC GFS internal audit programme.
- The uncontrol points highlighted by the gap analysis shall be subject to separate internal audit once during each certification period.
- Documented evidence of internal audit, root cause analysis and actions taken where non-conformance are identified shall be maintained.
- As an alternative it is permissible for participating sites to carry out a standalone annual internal compliance audit (the pork module check list can be used for this purpose) to meet the requirements of Charter Rule 7.10. However, if this option is taken then all requirements of the relevant pork module(s) must be reviewed and documented.
- Where a derogation has been granted (see Charter Rule section 6.0) then the requirements specified against the derogation shall be reviewed by separate internal audit for the period in which the derogation is active.
7.7 Approving new products prior to a scheduled audit
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.
7.8 Spot checks
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 Liability & how BMPA will review the quality of audit delivery
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.