What are the implications of producing a product outside the scope of accreditation?

Hi all. We manufacture and package liquids in containers, alcoholic and non alcoholic beverages. Our BRC scope includes the types of beverages detailed fairly specifically. Management wish to package (and potentially sell) a beverage type not specifically covered by the scope. We didn't foresee this prior to our last audit, otherwise we'd have included it in the scope and audit.

The beverage they wish to produce would be produced with all the usual food and quality standards, and meet regulatory requirements in the domestic market. The question is, what are the implications of producing a product outside the scope of accreditation - I've never had this before. Can we have a minor scope amendment without re audit? Do  we need to re audit?

Thanks Glenn , approaching the cb would be required I feel. However, as a hypothetical question , does an exemption cover other products produced in a plant which is accredited for some products thereby allowing manufacture of non scope product/s to occur? Must all products be in the scope of accreditation ? As I said, I've never come across this situation before.

Hi all . We manufacture and package liquids in containers, alcoholic and non alcoholic beverages. Our BRC scope includes the types of beverages detailed fairly specifically. Management wish to package (and potentially sell) a beverage type not specifically covered by the scope. We didn't foresee this prior to our last audit, otherwise we'd have included it in the scope and audit.

The beverage they wish to produce would be produced with all the usual food and quality standards, and meet regulatory requirements in the domestic market . The question is, what are the implications of producing a product outside the scope of accreditation - I've never had this before. Can we have a minor scope ammendment without re audit? Do  we need to re audit?

Hi BottlingQA,

It likely depends on the specifics of yr audited/certified Scope, eg -

brc-global-standard-for-food-safety-issue8-faqs.pdf   508.54KB   6 downloads

Also see para 5.2 (pg 81) in the BRC8 Standard

Thanks Charles - the exemptions FAQ make the BRC position fairly clear. 

Thanks Glenn , approaching the cb would be required I feel. However, as a hypothetical question , does an exemption cover other products produced in a plant which is accredited for some products thereby allowing manufacture of non scope product/s to occur? Must all products be in the scope of accreditation ? As I said, I've never come across this situation before.

BRC is quite specific on the requirements for exclusions - they've got to be clearly differentiated from products within scope, and produced in a separate area of the factory (see "Exclusions from Scope", starting on page 5 of the current standard). If you're making these products on the same line(s) as your existing certified products then you wouldn't generally be permitted to have them listed as an exclusion.

As per Glenn's suggestion, pick up with your CB to talk it through. It may well be that the products are sufficiently similar (e.g. process, HACCP etc) that they can be added to your scope without a further audit.

Might also be worth looking at the wording of your scope at your next audit - never had a problem making these fairly broad (e.g. having "carbonated soft drinks" rather than "cola" and then needing to add lemonade/orangeade if you introduce other varieties), as long as the auditor can reasonably cover the selection you're going with, and they all fit within your BRC categories.