Transcript The Global Standard – Consumer Products
The European R&TTE Directive
• • • Alan Binks
An Introduction to BRC and The Consumer Product Standard
The BRC
The British Retail Consortium is the leading Trade Association representing the vast majority of UK retailers
BRC Trading
Services to support BRC members & certificated suppliers – Standards – Training – – Events Supply services (e.g. post, legal )
The Content • • • • • Background to the BRC BRC is a trade organization representing members of the UK retailing sector. Limited by Guarantee Company Four Standards – Food Safety, Packaging, Storage and Distribution The Global Standard for Consumer Products The standard was designed to be a common audit standard recognized by all members to reduce the cost of audits to members and suppliers. Ensures Safety, Legality and Quality of products but does not replace Legal obligations.
Consumer Products Only covers General consumer items and manufactured goods Current Status Currently Issue 2A being revised for Issue 3 and linked to RILA
The BRC Global Standards Consumer Products Packaging Food Storage & Distribution
Why BRC Standards?
•
Requested by retailers to
– Reduce number of audits – Cover their needs – Remove competitive element from product safety – Give a baseline measure – Meet the need to demonstrate “due diligence”
Consumer Products Safety & Quality Assurance • • •
Why?
To keep consumers safe & gain their trust To meet legal requirements To protect the brand
WHY?
Magnets
Clause 2.3
Risk assessment 9 million recalled 33 serious injuries – 2 deaths 12 yr old swallowed 28 magnets New technology neodymium magnets – hazard not assessed
Strollers
One million plus recalled Finger tip amputations Clause 2.3
Faulty Design Risk assessment Clause 6 Product conformity
Christmas lights , 30% unsafe (EU report) Poor construction and components Clause 7 Process control Shoes DMF Contaminant 107 recalls 2009 Clause 5 Product control Freckle cream Wrong formulation 4% mercury 88 recalls 2009 Clause 5 Chemical formulation control
Toxic Sofas!
Consumers complained of horrific burns from new leather sofas
• • • • Packed with Dimethyl-Fumarate(DMF) to stop mould The High Street stores have to pay more than £20m in compensation and legal costs Lawyers think 200,000 defective sofas may have been sold and many more claimants may still exist
http://news.bbc.co.uk/1/hi/uk/7968867.stm
The Phantom of Heilbronn • • • • • • German Police hunt Super-Criminal for 16 years!
Woman suspected of six murders! Police suspicions based identical female DNA found at 40 crime scenes in Germany and Austria After finding DNA at the murder of a 22-year old Heilbronn policewoman in 2007, police offer €300,000 reward Now found that cotton swabs used to collect DNA were contaminated accidently by a woman worker at an unidentified factory in Bavaria http://news.bbc.co.uk/1/hi/world/europe/7966641.stm
Other Incidents • • • • • • Contaminated milk scandal in China China suspends US meat imports over illegal growth hormones Budweiser recalls unsafe beer bottles Coca-Cola company has withdrawn all its Belgian produced drinks Sony recalls 440,000 Vaio laptops We can all play our part to help!
The Certification Process Suppliers
Audited by Certification body
The Standard
BRC approves CB’s and auditors
National Accreditation Body
Approves CB using ISO Guide 65
Certification Body
Accredited to perform audits
Organisation of BRC Global Standards
Governance & Strategy Committee
BRC members and international representatives Define policy & oversee progress
Technical Advisory Committees
One for each Standard • Retailers and other stakeholders • Contribute to production & review of Standards • Interpretation issues • Review training materials
BRC Technical team Certification Body Co-operation groups
Liaison between CB’s and BRC on technical issues & progressing implementation All governed by agreed terms of reference
The BRC Global Standards • • • • • • For retailers – by retailers & other stakeholders Work began 1996 - Food published 1998 More than 13,000 certificated companies Truly global – used in 90 countries – first Standard to be benchmarked by GFSI – developing & expanding in N. America A requirement to supply for most UK retailers Not only for BRC members but retailers around the world
Consumer Products Retailers accepting the BRC Global Standard for Consumer Products • • • • • • • • • • • Ahold Asda B&Q Booker The Co-operative Home Retail Group (Argos and Homebase) John Lewis Makro Metro AG J Sainsbury plc Waitrose
The Global Standard – Consumer Products • • • • • Started in response to European safety requirements for Consumer Goods – General Product Safety Directive 2001/95 Issue 1, 2003 limited success – Too complicated and confusing Issue 2 October 2006 – in English, Chinese (2007), Polish (2008), Thai (2007), German (soon to be published) Issue 2A – to globalise and update – no change of audit requirements Issue 3 completed– accepted by RILA (USA) – Launch date October 2010
The Global Standard – Consumer Products • • • • First accreditation by UKAS – January 2008 Now 6 Accredited companies Companies allowed to carry out audits if they are in process of accreditation – necessary to allow start ups
BABT/TUV-SUD (UK) recognized as a Certification Body
ISO 9000v Global Standard Consumer Products (GSCP) • ISO 9000 is for quality management systems. It requires a system to be in place capable of ensuring that products or services can satisfy the customer's quality requirements • The Global Standard – Consumer Products is a product certification scheme. It is about ensuring that the products themselves are legal and safe • Accreditation is different : – ISO 17021 (EN 45012) for quality management – ISO Guide 65 (EN45011) for product certification
BRC Directory • • • Currently searchable by the public Information is available on – Certified companies – Certification bodies – Trainers Soon to be much more (2009) – Secure areas for particular retailer / suppliers – Data management – – – Audit reports Management reports Audit notification
www.brcglobaldirectory.com
Content & Scope of The BRC Global Standard •
Consumer Products
Almost all consumer products
Exclusions • • • • • • • Motor vehicles Bulk fuel Services Pharmaceuticals dispensed by doctors Vitamins & minerals Plants & flowers Live animals / pets • Products covered by other BRC Standards
Content • • • Product Safety, Quality and Legality Risk and hazard based Does not cover – Environmental management systems – Social accountability or fair trade – Occupational Health & Safety – Corporate or perceived risk
Issue 3 • •
Published February 2010
–
German, Chinese and US English versions
Working with RILA
–
Used to more structure
•
Checklists, scoring, guidance
–
Political imperative CPSIA
–
Cautious start – pilots?
Differences between Issue 2 & 3
Issue 3 is a more global, risk based standard with enhanced product conformity and management commitment requirements
•
Three Product Groups
• • • •
The protocol has been improved Introduces 10 fundamental requirements Graded certification based on number and levels of non conformity Revised audit frequency Scored audit ?
Supporting Materials
Assessment Checklist Auditor Guidance document Differences document Training Interpretation Guideline “ Idiots Guide”
Auditor Requirements • • • • •
Background qualifications Auditing expertise Training Experience Categories
–
21 based on EA as requested by CBs
–
Must have enough expertise to understand issues on site
–
CBs still responsible for ensuring expertise
–
In many cases, will not be clear and judgement will be needed
Product Groups •
Product Group defines the detail of the audit and the frequency Group 1
– Products with specific legal and hygiene requirements and/or potential to cause serious injury or death if they fail during normal use •
Group 2
– Products with specific legal requirements and/or potential to cause serious injury or death if they fail during normal use •
Group 3
requirements and which may cause slight injury if they fail in normal use – Products that have some product specific legal •
Group 4
– Very low risk products that have no product specific legal requirements – disappears with Issue 3
The Standard contains a decision tree to aid classification
Product Group – examples
•
COSMETIC WIPES
– Hygiene requirements – Potential contamination – • • Microbiological Chemical Specific Legislation YES YES YES • TV – Hygiene requirements NO – Specific Legislation YES – Potential to cause serious injury YES • GREETING CARDS – Hygiene requirements – Specific Legislation NO NO – Potential to cause serious injury NO
Content 1. Product Risk Management 2. Consumer Product Management System 3. Site Environment Standards 4. Product Control 5. Process Control 6. Personnel
1. Product Risk Management • •
Hazard & risk management process
– Validated and reviewed – Process flow, Control procedures & Corrective actions monitored & reviewed for higher groups
Awareness and access to legal requirements & safety issues in the country of sale
– Also includes Customer Codes of Practice, Technical developments, for higher groups
2. Consumer Product Management System • • • • • • Manual Structure, Responsibility, authority Management commitment Customer focus Management review Internal audit • • • • • • • Supplier approval & performance monitor Document control Specifications Corrective actions Traceability Incidents and Recalls Complaint handling
3. Site Standards • • • • • Location & grounds Site security Layout and Product Flow Material handling Equipment • • • • • • Maintenance Production facilities Housekeeping and hygiene Waste and disposal Pest control Transport
4. Product Control • • • • • Design & development Packaging Product testing Segregation Stock control • • • Physical contaminants / metal detection Product release Control of non conforming products & materials
5. Process Control • • • • • • Operational control Quantity control Reference samples Retained production samples Equipment & process validation Measuring & monitoring equipment
6. Personnel •
Hygiene
– GMP (good manufacturing practice) •
Training
– Including refreshers & updates
Audit Outcomes • • • • •
No grading
– Either certificated or not
Non conformities characterised as
– Critical , major or minor
Non conformities must be cleared before certification
– Within 90 days for new company – Within one month for existing company
Product Groups
– Cannot be audited to lower group – Can be audited to higher but new rules require listing of actual group on the certificate
On going feedback of any reported issues
Certification • • • • Receive certificate Certification body supplies BRC with information Entered onto Directory Eligible for use of the logo Note : Logo cannot be used on products
Status & Experience so far
Status of The Global Standard – Consumer Products • • Over 300 companies already certified In 32 countries
Companies by Product Type Certified Companies by Country
UK China Italy Germany Pakistan Poland France Hungary India Ireland Netherlands Belgium Czech Israel Personal care Non durables Kitchenware Appliances Household textiles Medical Garments / footwear Tools DIY Pharma Horticulture Vehicle accessories/ cycles Pet products Stationery • Standard sales increasing • Many companies in process
Product Group Classification
33%
13%
7%
25%
32%
25%
59% Audits carried out so far
Preparation • • • Many companies are not well prepared Companies need to work on a gap analysis before certification Pre-assessment shown to greatly improve chances of success
Audits
There are common failure points:
• Do not understand responsibility for product risk assessment – Expect customer to do this – Design not controlled • Poor control of raw materials, bought in parts or subcontracted work • Problems with foreign body detection • Training records
Training • • • • • BRC has an approved training scheme and approved trainers Certification Bodies must be accredited Auditors must be trained in the scheme Visit
www.brcdirectory.com
Choose “Training Courses” or “Approved Training Suppliers” for information BABT is approved training supplier
BRC Help • • • • • Encouraging the use of the Standard – Working with retailers internationally (North America, Europe, Australia) – – Supplier briefings Support for CB’s Technical support – advice on any aspect for all stakeholders Complaint investigation and compliance monitoring Updates and support material (with help of TAC) Translations as required
To contact BRC [email protected]
Tel +44 207 854 8938
Alan Binks Technical Director, BABT Tel: +44(0) 1932 251244 [email protected]
www.tuvps.co.uk
www.babt.com