The European R&TTE Directive An Introduction to BRC and Alan - - PowerPoint PPT Presentation
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
Presented by Alan Binks Technical 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
The BRC
BRC is a trade organization representing members of the UK retailing sector. Limited by Guarantee Company
– Food Safety, Packaging, Storage and Distribution
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.
Only covers General consumer items and manufactured goods
Currently Issue 2A being revised for Issue 3 and linked to RILA
The Content
Food Packaging Storage & Distribution Consumer Products
The BRC Global Standards
– 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?
Consumer Products Safety & Quality Assurance
WHY?
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
Magnets
One million plus recalled Finger tip amputations Faulty Design
Clause 2.3 Risk assessment Clause 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 5 Product control Clause 5 Chemical formulation control Clause 7 Process control
Consumers complained of horrific burns from new leather sofas
legal costs
claimants may still exist
Toxic Sofas!
at 40 crime scenes in Germany and Austria
Heilbronn policewoman in 2007, police offer €300,000 reward
were contaminated accidently by a woman worker at an unidentified factory in Bavaria
The Phantom of Heilbronn
hormones
produced drinks
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 Committee BRC members and international representatives Define policy & oversee progress Technical Advisory Committees One for each Standard
Certification Body Co-operation groups Liaison between CB’s and BRC on technical issues & progressing implementation BRC Technical team
Organisation of BRC Global Standards
– used in 90 countries – first Standard to be benchmarked by GFSI – developing & expanding in N. America
The BRC Global Standards
Consumer Products
requirements for Consumer Goods
– General Product Safety Directive 2001/95
– Too complicated and confusing
– in English, Chinese (2007), Polish (2008), Thai (2007), German (soon to be published)
– to globalise and update – no change of audit requirements
Launch date October 2010
The Global Standard – Consumer Products
The Global Standard – Consumer Products
system to be in place capable of ensuring that products or services can satisfy the customer's quality requirements
certification scheme. It is about ensuring that the products themselves are legal and safe
– ISO 17021 (EN 45012) for quality management – ISO Guide 65 (EN45011) for product certification ISO 9000v Global Standard Consumer Products (GSCP)
– Certified companies – Certification bodies – Trainers
– Secure areas for particular retailer / suppliers – Data management – Audit reports – Management reports – Audit notification www.brcglobaldirectory.com
BRC Directory
Content & Scope of The BRC Global Standard
Exclusions
– Environmental management systems – Social accountability or fair trade – Occupational Health & Safety – Corporate or perceived risk
Content
– German, Chinese and US English versions
– Used to more structure
– 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
The protocol has been improved
non conformity
Differences between Issue 2 & 3
“Idiots Guide” Differences document Assessment Checklist Auditor Guidance document Training Interpretation Guideline
Supporting Materials
– 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
and/or potential to cause serious injury or death if they fail during normal use
to cause serious injury or death if they fail during normal use
requirements and which may cause slight injury if they fail in normal use
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
– Hygiene requirements YES – Potential contamination YES
– Specific Legislation YES
– Hygiene requirements NO – Specific Legislation YES – Potential to cause serious injury YES
– Hygiene requirements NO – Specific Legislation NO – Potential to cause serious injury NO
1. Product Risk Management 2. Consumer Product Management System 3. Site Environment Standards 4. Product Control 5. Process Control 6. Personnel
Content
– Validated and reviewed – Process flow, Control procedures & Corrective actions monitored & reviewed for higher groups
safety issues in the country of sale
– Also includes Customer Codes of Practice, Technical developments, for higher groups
Responsibility, authority
commitment
performance monitor
detection
products & materials
– GMP (good manufacturing practice)
– Including refreshers & updates
– Either certificated or not
– Critical , major or minor
– Within 90 days for new company – Within one month for existing company
– Cannot be audited to lower group – Can be audited to higher but new rules require listing of actual group on the certificate
Audit Outcomes
Note : Logo cannot be used on products
Certification
already certified
Certified Companies by Country
UK China Italy Germany Pakistan Poland France Hungary India Ireland Netherlands Belgium Czech
Companies by Product Type
Personal care Non durables Kitchenware Appliances Household textiles Medical
Status of The Global Standard – Consumer Products
13% 25% 25% 32% 7% 33% 59%
Audits carried out so far
Product Group Classification
Preparation
There are common failure points:
– Expect customer to do this – Design not controlled
subcontracted work
Audits
Choose “Training Courses” or “Approved Training Suppliers” for information
Training
– Working with retailers internationally (North America, Europe, Australia) – Supplier briefings – Support for CB’s
– advice on any aspect for all stakeholders
BRC Help
Alan Alan Binks Binks
Technical Director, BABT Tel: +44(0) 1932 251244 alan.binks@babt.com www.tuvps.co.uk www.babt.com