The European R&TTE Directive An Introduction to BRC and • Alan Binks The Consumer Product Standard • Technical Director, BABT Presented by Alan Binks • alan.binks@babt.com Technical Director, BABT
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 Packaging Food Storage & Distribution Consumer Products
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 New technology 12 yr old neodymium magnets – swallowed 28 hazard not assessed magnets
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) Clause 7 Process control Poor construction and components Shoes Clause 5 DMF Contaminant Product control 107 recalls 2009 Freckle cream Clause 5 Wrong formulation Chemical formulation 4% mercury control 88 recalls 2009
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 The Standard BRC approves CB’s and auditors National Accreditation Body Suppliers Approves CB using Audited by ISO Guide 65 Certification body 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 BRC Technical team • Retailers and other stakeholders • Contribute to production & review of Standards • Interpretation issues • Review training materials 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 Interpretation Differences Guideline document “Idiots Guide” Training
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 – 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 – 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
Content 1. Product Risk Management 2. Consumer Product Management System 3. Site Environment Standards 4. Product Control 5. Process Control 6. Personnel
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