The British Retail Consortium (BRC) has issued a draft position statement on the treatment of seasonal sites within its Global Food Standard and the industry has until August 14 to suggest amendments.
The BRC produced the statement in recognition of the difficulties that seasonal sites have in complying with the certification timescales.
The draft statement reads: “A seasonal site is defined as one that is only in production for a limited and short period of the year, and not one that produces different products at different times.
“For these sites therefore certification needs to be based on a season rather than exactly 12 months, to allow for the practical problems of early or late starts to seasons due to availability of product.
“For sites manufacturing seasonal products it is equally important that they work in close accordance with the requirements of the Standard, thereby minimising any likelihood of non-conformity being identified during an evaluation, as there is little time for these to be rectified due to the shortness of the season.
“The evaluation must be planned at the beginning of the season to allow time to close out any non-conformity.
“Where non-conformity is identified during an evaluation visit, then for critical and/or major non-conformance against non-fundamental clauses the site must always take immediate steps to ensure corrective action and fully rectify all of the issues identified within the period of time that the product is being manufactured.
“This will usually be less than 28 days due to the timing of the end of season but documentary evidence of corrective action will be required. Where non-conformity is identified during an evaluation visit, for critical and/or major non-conformance against fundamental clauses the site will remain uncertificated.
“Where minor non-conformances are identified the site should also aim to take and implement corrective action to rectify the non-conformances identified.
“However, it is recognised for on-going evaluations, that it is possible that the season may be coming to an end and it is not feasible or practical for corrective action to be taken in the normal timescales and therefore implementation of the corrective actions can be delayed until a date prior to the next season when the site is being prepared for production.
“In all these cases if there is a clear corrective action plan with defined timescales, this will be sufficient provided that the site does fully rectify the non-conformance prior to the next season.
“It should be noted that if the same non-conformities are identified at the site next season thereby indicating that the corrective action was not taken in accordance with the action plan, then full evidence will need to be provided and these will be raised as a major non-conformity at the time of the evaluation visit.”
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