Summary of the CPP Audit Scheme

SUMMARY OF THE CPP AUDIT SCHEME OF APPROVED PRODUCTS AND FUTURE DEVELOPMENTS.

1. Purpose

The factors behind the decision to undertake an audit of approved products included -

1. A failure incident relating to one approved product
2. Some of the approved products had been approved under the previous voluntary scheme, with some approved with either only limited or no testing being undertaken
3. The anticipated inclusion of a regular (probably once a year) audit requirement in the European Acceptance Scheme (EAS)

The main objectives of the audit scheme were:

• to ensure that approved products were manufactured in accordance with the information notified to the CPP, particularly with regard to the chemical composition and source and identity of raw materials or components; and
• to carry out limited re-testing to monitor for changes in product leaching behaviour.

Notes:

a. product re-testing was not undertaken on chemicals such as flocculants, adsorbents, cleaning and disinfecting products.
b. full details of the original audit basis and requirements are given in Regulation 25 letter 06/2001

2. The Audit Scheme

2.1 Factory inspections

The audit process usually included an announced factory inspection of product manufacture (based on the CPP Audit Manual ) including:

• walk through of the production facility;
• verification of formulations and production processes, including inspection of batch sheets;
• inspection of ingredient/component inventory and validation of suppliers;
• inspection of shipping receipts, validation of suppliers and amounts of ingredients used;
• collection of samples for re-testing; and
• review of quality system and documentation, including ingredient/component specifications, and quality control, identification and traceability of finished products.

2.2 Product re-testing

Leaching tests were carried out to current Regulation 31 Enquiries requirements but the testing was less stringent than the tests required for initial product approval:

• only final leachate samples were analysed for TOC and GCMS identification of organic substances.
• odour and flavour testing was carried out to BS6920, usually in both chlorinated and non-chlorinated test water, on three batches of the product.

2.3 Post-audit assessment

Post-audit assessment reports were prepared for the CPP Secretariat based on the factory audit report and the audit re-testing results, identifying any discrepancies or concerns raised by the factory inspection and summarising the results of re-testing.

Action was taken by the CPP Secretariat if there was a change of components or suppliers without prior agreement, with referral to the CPP if there were matters that could be of concern, but not sufficiently major to require immediate revocation.