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
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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
12 yr old
swallowed 28
magnets
New technology
neodymium magnets –
hazard not assessed
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)
Poor construction and
components
Clause 7
Process control
Shoes
DMF Contaminant
Clause 5
Product control
107 recalls 2009
Freckle cream
Wrong formulation
4% mercury
88 recalls 2009
Clause 5
Chemical formulation
control
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 Belgianproduced 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
Suppliers
National Accreditation Body
Approves CB using
ISO Guide 65
Audited by
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
• Retailers and other stakeholders
• Contribute to production & review of Standards
• Interpretation issues
• Review training materials
BRC Technical team
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
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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
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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
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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
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Background qualifications
Auditing expertise
Training
Experience
Categories
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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
– Potential contamination
• Microbiological
• Chemical
– Specific Legislation
• TV
– Hygiene requirements
YES
YES
YES
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.
2.
3.
4.
5.
6.
Product Risk Management
Consumer Product Management System
Site Environment Standards
Product Control
Process Control
Personnel
1. Product Risk Management
• 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
2. Consumer Product Management System
• 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
3. Site Standards
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Location & grounds
Site security
Layout and Product Flow
Material handling
Equipment
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Maintenance
Production facilities
Housekeeping and hygiene
Waste and disposal
Pest control
Transport
4. Product Control
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Design & development
Packaging
Product testing
Segregation
• Physical contaminants / metal
Stock control
detection
• Product release
• Control of non conforming
products & materials
5. Process Control
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Operational control
Quantity control
Reference samples
Retained production samples
Equipment & process validation
Measuring & monitoring equipment
6. Personnel
• Hygiene
– GMP (good manufacturing practice)
• Training
– Including refreshers & updates
Audit Outcomes
• 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
Certification
• Receive certificate
• Certification body supplies
BRC with information
• Entered onto Directory
• Eligible for use of the logo
Note : Logo cannot be used on products
Status &
Experience so far
Status of The Global Standard – Consumer Products
• Over 300 companies
already certified
• In 32 countries
Certified Companies by Country
UK
China
Italy
Germany
Pakistan
Poland
France
Hungary
India
Ireland
Netherlands
Belgium
Czech
Israel
Companies by Product Type
Personal care
Non durables
Kitchenware
Appliances
Household
textiles
Medical
Garments /
footwear
Tools
DIY
• Standard sales increasing
• Many companies in process
Product Group Classification
13%
7%
25%32%
33%
25%
59%
Audits carried out so far
Preparation
• 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
Audits
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
Training
• 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
BRC Help
• 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
To contact BRC
brcglobalstandards@brc.org.uk
Tel +44 207 854 8938
Alan Binks
Technical Director, BABT
Tel: +44(0) 1932 251244
alan.binks@babt.com
www.tuvps.co.uk www.babt.com