The European R&TTE Directive

1. The European R&TTE Directive Alan Binks Technical Director, BABT alan.binks@babt.com An Introduction to BRC and The Consumer Product Standard Presented by Alan Binks Technical Director, BABT

2. 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 )

3. 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

4. The BRC Global Standards Packaging Food Storage & Distribution Consumer Products

5. 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”

6. Consumer Products Safety & Quality Assurance Why? • To keep consumers safe & gain their trust • To meet legal requirements • To protect the brand

7. WHY?

8. 9 million recalled 33 serious injuries – 2 deaths 12 yr old swallowed 28 magnets New technology neodymium magnets – hazard not assessed Magnets Clause 2.3 Risk assessment

9. One million plus recalled Finger tip amputations Faulty Design Strollers Clause 2.3 Risk assessment Clause 6 Product conformity

10. 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 7 Process control Clause 5 Product control Clause 5 Chemical formulation control

11. 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

12. 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

13. 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!

14. The Certification Process The Standard BRC approves CB’s and auditors National Accreditation Body Suppliers Approves CB using ISO Guide 65 Audited by Certification body Certification Body Accredited to perform audits

15. 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

16. 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

17. Retailers accepting the BRC Global Standard for Consumer Products 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

18. 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

19. 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

20. 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

21. BRC Directory www.brcglobaldirectory.com • 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

22. Content & Scope of The BRC Global Standard Consumer Products Almost all consumer products

23. Exclusions Motor vehicles Bulk fuel Services Pharmaceuticals dispensed by doctors Vitamins & minerals Plants & flowers Live animals / pets Products covered by other BRC Standards

24. 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

25. 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

26. 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 ? Differences between Issue 2 & 3

27. “Idiots Guide” Assessment Checklist Auditor Guidance document Training Interpretation Guideline Differences document Supporting Materials

28. 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

29. 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

30. Product Group – examples • 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 • COSMETIC WIPES • Hygiene requirements YES • Potential contamination YES • Microbiological • Chemical • Specific Legislation YES

31. Content • Product Risk Management • Consumer Product Management System • Site Environment Standards • Product Control • Process Control • Personnel

32. 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

33. 2. Consumer Product Management System • Supplier approval & performance monitor • Document control • Specifications • Corrective actions • Traceability • Incidents and Recalls • Complaint handling • Manual • Structure, Responsibility, authority • Management commitment • Customer focus • Management review • Internal audit

34. 3. Site Standards • Maintenance • Production facilities • Housekeeping and hygiene • Waste and disposal • Pest control • Transport • Location & grounds • Site security • Layout and Product Flow • Material handling • Equipment

35. 4. Product Control • Physical contaminants / metal detection • Product release • Control of non conforming products & materials • Design & development • Packaging • Product testing • Segregation • Stock control

36. 5. Process Control • Operational control • Quantity control • Reference samples • Retained production samples • Equipment & process validation • Measuring & monitoring equipment

37. 6. Personnel • Hygiene • GMP (good manufacturing practice) • Training • Including refreshers & updates

38. 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 actualgroup on the certificate • On going feedback of any reported issues

39. Certification Note : Logo cannot be used on products Receive certificate Certification body supplies BRC with information Entered onto Directory Eligible for use of the logo

40. Status & Experience so far

41. Status of The Global Standard – Consumer Products • Over 300 companies already certified • In 32 countries • Standard sales increasing • Many companies in process

42. Product Group Classification 13% 7% 25% 32% 33% 25% 59% Audits carried out so far

43. 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

44. 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

45. 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

46. 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

47. To contact BRC brcglobalstandards@brc.org.ukTel +44 207 854 8938

48. Alan Binks Technical Director, BABT Tel: +44(0) 1932 251244 alan.binks@babt.com www.tuvps.co.ukwww.babt.com