BRCGS grade downgrade results in re-classification of the site by the auditor, downgrading the certificate holder from the higher grade, for example AA or A, to the lower grade of B or C. This is one of the most misunderstood effects of an audit by the site owner since it is often misinterpreted to mean that the certificate has been revoked. It simply means that the number or severity of non-conformities found during the audit is greater than what the previous grade allows. This article looks at the causes of BRCGS grade downgrade, differences between it and audit failure and certificate revocation, as well as how to restore your initial grade.
Understanding a BRCGS Grade Downgrade
A BRCGS certificate uses the following five-tier grading system — AA, A, B, C, and sometimes D – depending on the quantity and criticality of non-conformities identified by the auditor. A BRCGS grade downgrade occurs when the audit findings of the auditor force the site into a different grade than what was recorded in the previous certification process. The BRCGS certificate may remain valid, but the fact that the site’s food safety and quality standards have been downgraded is an indication to the buyers and retailers that the standards need closer inspection. The minimum grade requirement for being listed as a supplier by most retailers means that a grade downgrade affects business relationships irrespective of whether the certificate is still valid.
The grade is another way by which a manufacturer/exporter certifies the quality of their products to their buyers just like the certificate itself. A site having the AA grade is considered to have developed a mature and documented food safety standard with few findings while the C grade site needs close monitoring although it is still certified. In short, a grade downgrade affects how the site is perceived even without expiry of the BRCGS certificate.
What Causes a BRCGS Grade Downgrade
Downgrades seldom come from just one problem. Rather, they come from a buildup of BRCGS Non-Conformities across various clauses, or one critical or major non-conformity which overshadows the others. Some of the common root causes of such downgrades are:
- The number of minor non-conformities increased when compared with the last audit cycle
- Presence of one or more major non-conformities in food safety management, traceability, or product control
- Critical non-conformity, where in itself, it could lead to an downgrade or suspension despite the other findings
- Repeat finding in the same clause for two successive audit cycles indicating the lack of effectiveness of the corrective action taken from the previous audit
- Difference between documented practices and observations made by the auditor during the site walk
- Lack of management commitment in resolving audit findings within the agreed time frame
- Ineffective internal auditing and/or verification documentation unable to identify issues before external audit
These are never issues that stand alone. A plant that allows a little documentation deficiency to go unsolved through two rounds of audits will most likely see it come back to haunt them as a big non-conformity in their next audit, because the auditor now looks at it as a systematic issue rather than a single slip up. That is precisely why certification bodies consider past BRCGS Corrective Actions when assessing the current audit; having a good history will mitigate the effect of new issues, but a poor one will make it worse.
Why Does a BRCGS Grade Downgrade Get Applied After an Audit
Why is a BRCGS grade reduced following an audit? This is one of the most frequently asked questions from individuals holding the certificate, as they were expecting that they would maintain their existing grade. This has something to do with how the BRCGS grades findings. In the audit process, all the findings that are discovered are graded as either critical, major, or minor findings, and these have their own significance in the overall grade.
BRCGS Non-Conformities That Most Commonly Trigger a Downgrade
Some areas within the clauses are prone to nonconformities more than others. Analyzing previous studies and identifying where they are clustered will help a company concentrate on their BRCGS Corrective Actions on the most audited areas.
Food Safety Management System
- HACCP/food safety plan review incomplete
- No indication of management reviews’ results
- Outdated hazard assessment which doesn’t take into account new products/ processes
Site Standards and Hygiene
- Records of pest control activities which have no resolution
- Bad housekeeping in critical areas
- Maintenance work which destroys hygienic design
Product and Process Control
- Failed traceability tests without proper reconciliation in the specified time period
- Shortcomings in allergen management during changeover and labeling
- Non-availability of calibration information at critical control points
Personnel and Training
- Mismatch between training records and actual employees on the floor
- Procedures not adhered to by visitors or contractors
BRCGS Audit Failure and BRCGS Certificate Suspension : Where Downgrade Fits
The BRCGS grade downgrade may be mistaken for a couple of similar but distinct scenarios, which include BRCGS audit failure and BRCGS certificate suspension. The importance of distinguishing between these three situations is essential, as they need entirely different actions to be taken for resolution.
Grade downgrade is less serious than two other options, as it implies that the site already has a certificate issued, but it just got a new grade. BRCGS Audit Failure is a more severe scenario in which the certification body decided that the food safety management system implemented in the site is not good enough to receive or renew a certificate. Certificate suspension is somewhere between two previous ones in process, but it is activated after the most serious finding, which can cause food safety and/or legal issues.
How to Recover a BRCGS Certificate After a Grade Downgrade
The procedure for restoring a BRCGS certificate in case of downgrading is a step-by-step process that includes several stages. It is required by BRCGS that certificate holders provide proof of correction of each non-conformity, as well as address the cause in order to prevent recurrence of the issue where applicable. The basic process of recovery may be described as follows:
It is important to understand that recovery is not a mere piece of paperwork. The evidence of implementation of the change should be provided in the form of documentation showing that the change has become part of the routine operations rather than an entry in a document that has been written the day before the due date. It is typical that a corrective measure that exists in a document rather than in practice appears again at the next audit as a repeated non-conformity that leads to a major non-conformity.
- Study the audit report carefully and categorize the issues based on clauses and their severity
- Find out the underlying cause behind each non-conformity rather than just its symptoms
- Create an action plan for correction that includes responsible individuals and reasonable deadlines
- Apply the action plan at the location and create documents to support it (photos, revised SOPs, training sessions)
- Provide documentation to the certification body within the period mentioned in the audit report
- Answer any questions from the auditor that come up before the case closure
- Take the learning into the next audit cycle as well
Typical Corrective Action Timelines
Can a Downgraded BRCGS Certificate Be Recovered
The ability to regain the downgraded BRCGS certificate is the question most site owners pose once the audit report comes in. Usually, the answer is yes. In most cases, the downgrading of the BRCGS grade due to major or minor non-conformities can be regained through fixing the problem and proving the same in the next audit cycle. However, in the case where the downgrading was caused by a critical non-conformity or certificate suspension, it usually takes an extra audit to regain the grade. This grade is temporary because it depends on the most recent audit cycle results; therefore, it will need continuous good performance to retain the grade.
It is also important to plan for the next audit process way ahead of time than waiting until the next year when the audit cycle comes around. Doing an internal mock audit on the clauses of non-conformity and ensuring the evidence for correction actions are ready for inspection help minimize the likelihood of finding another non-conformity under the same clause. Sites that include this planning in their regular schedule of quality audits regain the grades within one to two cycles.
Key Takeaways
- The downgrade of BRCGS grade is based on the results of the latest audit, not a final assessment of the facility
- Grade downgrades are often due to a combination of many small findings or one big or critical non-conformance
- Grade downgrade, audit failure, and suspension of certificate are different events that are related but distinct from each other
- The process of restoring grade includes creating a corrective action plan and performing root cause analysis
- It takes about 24-48 hours to recover from critical finding and 28 days from major/minor findings
Frequently Asked Questions
What causes a BRCGS grade downgrade?
The accumulation of several small non-conformances or a big non-conformity in the audit when compared to the previous round.
Why does a BRCGS grade get downgraded after an audit?
Non-conformances are rated based on the level of their severity, and if the balance changes, the grade will fall despite passing the audit.
How to recover a BRCGS certificate after a grade downgrade?
The submission of a corrective action plan which addresses the root cause needs to be provided before the deadline set by the certification body.
Can a downgraded BRCGS certificate be recovered?
Certainly, in most cases, if the correct actions are taken and performance improves in the subsequent audit.
How long does BRCGS Certificate Suspension last?
Until the critical non-conformity is resolved and verified, usually through an additional or extraordinary audit.
What is the difference between a BRCGS audit failure and a grade downgrade?
An audit fail implies that no certificate is issued, but a grade downgrade keeps the certificate valid with a reduced grade.
How many non-conformities cause a BRCGS grade downgrade?
No specific number, but depends on the composition of critical, major and minor non-conformities in the audit.