packaging_differences_issue_2_v_3.pdf

8/17/2019 Packaging_differences_Issue_2_v_3.pdf

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KLH Page 1 of 8 Issue 2 20.2.08

Detail of Enhancements

Global Standard for Packaging and Packaging Materials

Issue 2 and 3

The BRC Global Standard for Packaging and Packaging Materials Issue 3 was published on 4th

January 2008. The publication follows an extensive benchmarking and consultation process.

The following details the enhancements from Issue 2.

Scope

The scope of the Standard has been extended to encompass packaging for food and non food

use. Three categories of packaging with regard to the standards of hygiene under which

packaging is produced, have been identified. A decision tree has been produced to aid in

identifying the packaging category (see Appendix 1) and specific examples are also given (see

Appendix 2). The final decision on the level applicable to a manufacturing site will be made by

a hazard and risk analysis based on the hygiene requirements of the final product, used in

conjunction with the decision tree and may be determined by the manufacturer in association

with customers.

Name

The Standard’s name has been revised to reflect its international appeal and increased scope. It

does not contain ‘BRC or IOP’ in the title and is now the Global Standard for Packaging and

Packaging Materials.

The Standard is written from the perspective of a company undergoing audit and includes thefollowing:

• Introduction to BRC Global Standards Directory

• Qualifications, Training and Experience Requirements for Auditors

• Certificate Template

Audit frequency

The audit frequency has been reviewed and now all audits will be carried out at 12 month

frequencies unless three or more major non-conformities are found, where the next audit shallbe due in six months.

Report Format

The report format has been updated to provide enhanced presentation of information to the user

and report owner.

Auditor Qualifications

Details on the requirements for auditors is now included within the Standard to ensure

transparency and allow companies to verify auditor qualifications.


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Audit Protocol

Clarification of some further audit protocol points include:

Auditor selection – as guidance the same auditor should not carry out more than 5

consecutive visits to a site.

Action to be taken by company and certification body detailed when extension to scope

is required.

Details requirement for BRC administration fee (currently £75).

Clarification of non conformity against fundamental = non conformity against

statement of intent.

Corrective action time now clearly stated as 28 calendar days.

Justifiable circumstances for certificate expiry defined.

Definition and actions required for certification of seasonal products.

The previous year’s audit report shall be made available for the auditor.

Further visits may be made by the certification body

Feedback and complaints to the BRC are encouraged. Details on how to do this are

included. The company has the right to appeal to the certification body within 7

calendar days of a certification decision.

Glossary of terms updated.

Requirements Clauses

The format of the Requirements has been updated to be consistent with other BRC Global

Standards and therefore does not include Best Practice Guidelines. The Requirements have

been reviewed and expanded and several new sections have been incorporated in light of

industry requirements. The number of clauses now total a maximum of 242 (from 178) and

include more detailed guidance and clarity to facilitate interpretation for certification bodies

and companies. The following changes are summarised although requirements may not beapplicable to all 3 packaging categories and provided as a guide to changes only.

1. Management Commitment and Continual Improvement (14 clauses from 6)

Emphasis on continual improvement. Additional requirements:

• provision of resources

• clear communication channels

• review specified annually

• detailed requirement for topics to be included in review

• system for being kept up to date with legislation required

•

products must comply with legislationAdditional requirements specific to audit process:

• current issue of Standard required


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• closing of non-conformities from previous audit2. Hazard and Risk Management (15 clauses from 8)

Split into 3 sub sections:

2.1 Hazard and Risk Management Team

• requires multidisciplinary team

• training

2.2 Hazard and Risk Analysis

• requires documentation and verification of packaging category

• include description and intended use of product

• corrective action to be specified

• best practice guideline of annual review incorporated

2.3 Hazard and Risk Management Prerequisites

• proposed exemptions need to be documented and reviewed

3.1 Technical Management Policy (4 clauses from 4)No change

3.2 Quality Manual (2 clauses from 2)

Minimal change

3.3 Customer Focus and Contract Review (New Section 3 clauses)

• identify and review customer requirements

• identify individuals for communication with customers

3.4 Internal Audits (5 clauses from 5)

•

requires records of conformity as well as non-conformity

3.5 Supplier Monitoring (4 clauses from 3)

Minimal change

3.6 Subcontracting of production (3 clauses from 3)

• assessment of subcontractors by competent person deleted

3.7 Documentation Control (6 clauses from 6)

No change

3.8 Specifications (6 clauses from 6)

Minimal change

3.9 Record Keeping (2 clauses from 2)

Minimal change

3.10 Traceability (5 clauses from 3)

• traceability system to comply with legislation in country of intended use where known

is required

• best practice guideline for system tested on annual basis incorporated

3.11 Complaint Handling (4 clauses from 3)

Minimal change


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3.12 Management of Incidents and Product Recalls (5 clauses from 4)

Section split out into Management of Incidents and Non-conforming Product (clause 5.6)

• detailed requirements for product recall procedure specified

• best practice guideline for annual product recall test incorporated

4 Site Standards

4.1 Perimeter and Grounds (10 clauses from 10)

Minimal change

4.2 Security (New section 4 clauses)

• controlled access

• secure storage

4.3 Layout and Product Flow (6 clauses from 4)

Minimal change – adoption of best practices to requirements

4.4 Building Fabric (8 clauses from 8)

Minimal change

4.5 Maintenance of Plant and Equipment (11 clauses from 10)

• a planned preventive maintenance programme to be in place

• control of compressed air

• documented hygiene clearance following maintenance required

4.6 Staff Facilities (New – pulled from sections 7.2, 7.3 & 7.4 - 13 clauses from 18)

•

best practice guideline incorporated specifying lockers of sufficient size

4.7 Housekeeping and Hygiene (11 clauses from 12)

• best practice guideline incorporated – requirement for adequate gap

• specification for details on cleaning procedures incorporated from best practice

guideline

• best practice guideline incorporated – strongly scented chemicals not to be used

4.8 Waste and Waste Disposal (6 clauses from 5)

• requirement for containers to be suitably labelled or marked

4.9 Pest Control (10 clauses from 7)

• best practice guideline incorporated – frequency of visits determined by hazard analysis

• requirement for flying insect catch tray analysis at appropriate intervals (category 1

only)

• recommendations need to be implemented

• records must be kept

4.10 Transport, Storage and Distribution (8 clauses from 11)

Minimal change


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5 PRODUCT AND PROCESS CONTROL

5.1 Product Design and Development (New section 5 clauses)

• customer design requirements shall be defined and agreed

• development of procedures and specifications including retention of reference samples

5.2 Process Control (7 clauses from 8)

• recycled material to be controlled

• best practice guideline incorporated – requirement to revalidate process followingchanges

5.3 Product Inspection and Analysis (7 clauses from 6)

• best practice guideline incorporated specifying frequency of checks

5.4 In-line Testing Equipment (New section 5 clauses)

•

need for equipment based on hazard and risk analysis• procedures to be documented

• product flow divert required

5.5 Calibration (New section – pulled from 4.8 - 7 clauses from 1)

• equipment needed to be listed and labelled

• documented procedure required and records kept

• equipment to be adjusted at predetermined frequency

5.6 Control of Non-conforming Product (New section – pulled from 4.6 - 3 clauses from 4)

Minimal change

5.7 Foreign Body Control (16 clauses from 11)

• based on risk analysis glass shall be protected

• best practice guideline incorporated – notices on equipment shall be cleanable & secure

5.8 Chemical and Biological Control (3 clauses from 3)

Minimal change

6 Personnel

6.1 Training (5 clauses from 5)

• routine review of staff competency required

6.2 Access and Movement of Personnel (4 clauses from 6)

• clause regarding security moved to 4.2 (site security)

6.3 Personal Hygiene (11 clauses from 9 – section 7.3 & 7.6)

• plain wedding ring, a wedding wristband and sleeper earrings (continuous loop)

allowed to be worn.

• best practice guideline incorporated – personal items not to be taken into production

areas

• best practice guideline incorporated - gloves to be controlled


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6.4 Medical Screening (4 clauses from 4)

Minimal change

6.5 Protective Clothing (10 clauses from 6)

• best practice guideline incorporated – sufficient sets of clothing required

•

policy to be documented

• specification detailed for self care procedures


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Appendix 1

Decision Tree – Packaging Category Determination

STEP 1 – Conduct Risk Analysis

Is the packaging

intended for a high

risk product - For

example food or

cosmetic products?

Is the packaging

intended for

direct contact

with a high risk

product?

Yes

Does the

packaging ha

the potential

contaminate t

product?

Is it intended that the

packaging will enter

an environment where

there are unprotected

or open high risk

products?

Does the high

risk product have

an adequate

natural barrier?

Yes

Yes

Yes

No

No

No

Is the product

already in

impermeable

packaging?

No

Yes


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Appendix 2

Packaging Category Examples

Cross reference shall be made against the decision tree.

It must be stressed that this is not an exhaustive list and only provides examples. The final

packaging category determination should be agreed between the company and their customer

and discussed with the certification body.

PACKAGING CATEGORY 1

Direct contact with products that are consumed, applied to the skin or intended for infants’Plastic film laminate for cooked / uncooked meats

Plastic film for bread

Plastic laminate for toothpaste tube

Lipstick case mechanism

Caps for bottles of mouthwashPackaging for infants’ toys

Packaging for facial wet wipes

Tube for eye liner

Tub for baby ointment

Caps for bottles of shampoo

Packaging for sanitary products or baby nappies/diapers

Skin care product containers


Packaging that is in direct contact with a high risk product that has a natural barrier.Corrugated case used for packing bananas or avocados

Moulded pulp/expanded polystyrene box for eggs

Packaging that enters the same area as unprotected high risk productCartons used to protect food stuffs that have been film over-wrapped where the cartoning and

over-wrapping machines are in the same area.

Label for foodstuff where the label is applied on the same machine on which the food is packed

Closure for bag of cotton wool pads


Packaging that will be used for certain high risk product that is already in an impermeable

packLabels used for any product in plastic/glass jars or metal cans

Corrugated case for film over wrapped biscuits where the case is filled in different area to

biscuit wrapping

Packaging for products with reduced hygiene requirementClothing (coat-hangers or shirt bags)

Textiles (sheets, oven gloves or curtains)

Homeware (pots/pans, cutlery or crockery)Household products (kettles, toasters or china ornaments)

DIY products (chisels, screws, curtain rails or mastic)

Automotive products

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