The European R&TTE Directive Alan Binks Technical Director, BABT [email protected] An Introduction to BRC and The Consumer Product Standard Presented.

The European R&TTE Directive

• Alan Binks• Technical Director, BABT• [email protected]

An Introduction to BRC andThe Consumer Product StandardPresented by Alan BinksTechnical Director, BABT

Services to support BRC members & certificated suppliers

– Standards– Training– Events– Supply services (e.g. post, legal )

The British Retail Consortium is the leading Trade Association representing the vast majority of UK retailers

BRC Trading

The BRC

• 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 ProductsThe 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 ProductsOnly covers General consumer items and manufactured goods

• Current StatusCurrently Issue 2A being revised for Issue 3 and linked to RILA

The Content

Food

Packaging

Storage & Distribution

Consumer Products

The BRC Global 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”

Why BRC Standards?

Why?• To keep consumers safe & gain their trust• To meet legal requirements• To protect the brand

Consumer Products Safety & Quality Assurance

WHY?

Clause 2.3Risk assessment

9 million recalled

33 serious injuries – 2 deaths

12 yr old swallowed 28

magnets

New technology

neodymium magnets – hazard not assessed

Magnets

One million plus recalled

Finger tip amputations

Faulty DesignClause 2.3

Risk assessmentClause 6

Product conformity

Strollers

Christmas lights , 30% unsafe (EU report)

Poor construction and components

Shoes

DMF Contaminant

107 recalls 2009

Freckle cream

Wrong formulation

4% mercury

88 recalls 2009

Clause 5Product control

Clause 5Chemical formulation

control

Clause 7Process control

Consumers complained ofhorrific burns fromnew 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

Toxic Sofas!

• 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

The Phantom of Heilbronn

• 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!

Other Incidents

National Accreditation Body

Certification Body

Suppliers

The Standard

Accredited to perform audits

Approves CB using ISO Guide 65

Audited by Certification body

BRC approves CB’s and auditors

The Certification Process

All governed by agreed terms of reference

Governance & Strategy CommitteeBRC 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

Certification Body Co-operation groupsLiaison between CB’s and BRC on technical issues & progressing implementation

BRC Technical team

Organisation of 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

The BRC Global Standards

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

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

The Global Standard – Consumer Products

• 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

ISO 9000v Global Standard Consumer Products (GSCP)

• 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

BRC Directory

Consumer Products• Almost all consumer products

Content & Scope of The BRC Global Standard

• Motor vehicles• Bulk fuel• Services• Pharmaceuticals dispensed by doctors• Vitamins & minerals• Plants & flowers• Live animals / pets

• Products covered by other BRC Standards

Exclusions

• 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

Content

• 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?

Issue 3

Issue 3 is a more global, risk based standard with enhanced product conformity and management

commitment requirements

•Three Product GroupsThe protocol has been improved•Introduces 10 fundamental requirements•Graded certification based on number and levels of non conformity•Revised audit frequency•Scored audit ?

Differences between Issue 2 & 3

“Idiots Guide”

Differences

document

Assessment

Checklist

Auditor Guidance

document

Training

Interpretation

Guideline

Supporting Materials

• 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

Auditor Requirements

• 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 – Products that have some product specific legal requirements and which may cause slight injury if they fail in normal use

• 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 defines the detail of the audit and the frequency

Product Groups

Product Group – examples

• COSMETIC WIPES– Hygiene requirements YES– Potential contamination YES

• Microbiological• Chemical

– Specific Legislation YES

• TV– Hygiene requirements NO– Specific Legislation YES– Potential to cause serious injury YES

• GREETING CARDS– Hygiene requirements NO– Specific Legislation NO– Potential to cause serious injury NO

1. Product Risk Management2. Consumer Product Management System3. Site Environment Standards4. Product Control5. Process Control6. Personnel

Content

• 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

1. Product Risk Management

• 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

2. Consumer Product Management System

• Location & grounds• Site security• Layout and Product Flow• Material handling• Equipment • Maintenance

• Production facilities• Housekeeping and hygiene• Waste and disposal• Pest control• Transport

3. Site Standards

• Design & development• Packaging• Product testing• Segregation• Stock control • Physical contaminants / metal

detection• Product release• Control of non conforming

products & materials

4. Product Control

• Operational control• Quantity control• Reference samples• Retained production samples• Equipment & process validation• Measuring & monitoring equipment

5. Process Control

• Hygiene– GMP (good manufacturing practice)

• Training– Including refreshers & updates

6. Personnel

• 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

Audit Outcomes

• Receive certificate• Certification body supplies

BRC with information• Entered onto Directory• Eligible for use of the logo

Note : Logo cannot be used on products

Certification

Status & Experience so far

• Over 300 companies already certified

• In 32 countries

Certified Companies by CountryUK

China

Italy

Germany

Pakistan

Poland

France

Hungary

India

Ireland

Netherlands

Belgium

Czech

Israel

Companies by Product Type Personal care

Non durables

Kitchenware

Appliances

Householdtextiles

Medical

Garments /footwear

Tools

DIY

Pharma

Horticulture

Vehicleaccessories/cyclesPet products

Stationery

• Standard sales increasing• Many companies in process

Status of The Global Standard – Consumer Products

13%

25%

25%

32%

7%

33%

59%

Audits carried out so far

Product Group Classification

• 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

Preparation

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

Audits

• 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

Training

• 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

BRC Help

To contact BRC [email protected] +44 207 854 8938

Alan BinksTechnical Director, BABT

Tel: +44(0) 1932 [email protected] www.babt.com