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BRC Global Standard - Packaging
Issue 2 of the BRC Global Standard - Food Packaging
and Other Packaging Materials was published on 31 August 2004. SaferPak
have reviewed Issue 2 of the Standard and developed a free guide to the
revisions: Download
Review Guide (pdf 147kb). Copies of
the revised Standard can be purchased from the TSO
Bookstore.
Overview
of the standard
The BRC Global Standard - Packaging was published on 17 October 2001 following
two years of development by The
British Retail Consortium and The
Institute of Packaging in consultation with a wide variety of retailers,
food producers, trade associations and packaging companies. Many of the
large UK's retailers such as Marks & Spencer, Sainsbury's, Safeway,
Co-op, Tesco and Waitrose have stated that suppliers of retailer branded
packaging must achieve certification to the BRC Global Standard - Packaging.
The Standard has been welcomed by the majority of the packaging industry
and significant numbers of packaging businesses both in the UK and overseas
have already achieved certification or are working towards it.
The need
for a standard
Reports of deaths and illnesses caused by poor food safety have grown in
frequency over the last 20 years or so and in order to protect the consumer,
The
Food Safety Act 1990 was established and later The
Food Safety (General Food Hygiene) Regulations 1995 (EU Food Safety
Directive 93/43/EEC).
Under the terms of the Food Safety Act, retailers have an obligation to
take all reasonable precautions and exercise all due diligence in the avoidance
of failure, whether in the development, manufacture, distribution, advertising
or sale of food products to the consumer. To aid due diligence the BRC Global
Standard - Food was launched in 1998 and it was inevitable that a common
auditing standard for packaging companies would soon follow.
The standard has become the benchmark by which audits
are undertaken and has superseded previous hygiene certification schemes.
| Requirements
of the standard |
| • |
The adoption of a formal Hazard
Analysis System |
| • |
A documented Technical Management System |
| • |
The control of factory standards, products, processes
and personnel |
| Benefits
of certification |
| • |
Supported by most of the major UK Retailers |
| • |
A single standard and protocol, evaluations will be carried out
by a third party certification bodies accredited to European standard
EN45011 |
| • |
Single verification will allow manufacturers and suppliers to report
on their status to food retailers and other organisations |
| • |
The standard addresses part of the 'due diligence' requirements
of the packaging manufacturer/supplier, packer/filler and retailer |
| • |
Facilitates continuous improvement of quality, hygiene and product
safety through surveillance non-conformities and corrective action |
| • |
Should significantly reduce the number of customer audits and their
associated management costs |
| • |
Packaging manufacturers can use the standard to ensure their suppliers
are following good hygiene practices and complete the 'due diligence'
chain |
Do
I need it?
If you are a manufacturer or supplier of packaging and your products are
used with retailer branded food products the answer is most probably -
YES! The requirements of the standard differ depending on the risk your
products present to the food. In the standard there is a simple 'decision
tree' that will help you determine whether you are a category 'B' supplier
and must meet the higher level requirements of the standard, or a category
'A' supplier for whom the requirements are a little less rigorous.
The standard is flexible and allows suppliers to operate both category
A and B standards in separate 'risk areas' of the factory. In addition
suppliers may apply for exemptions to certain clauses of the standard
if they can be identified and confirmed through the hazard
analysis
Content
of the standard
The standard consists of eight sections plus an associated protocol. Each
section sets out a statement of intent and all packaging suppliers will
need to comply with this statement in order to gain certification.
1. Scope
General overview of the standard, who the standard applies to and what
the requirements of the standard are.
2. Organisation
Covers the requirements for the organisation in terms of management responsibility,
organisational structure and management review.
3. Hazard and risk management system
Covers the requirements for a formal hazard analysis of the production
process considering foreign object, chemical and microbiological contamination
as well as packaging defects that compromise consumer safety.
4. Technical management system
Covers the quality and hygiene policy, hygiene system documentation and
control, specifications, management of incidents and product recall, traceability
system, internal audits, complaints, supplier monitoring, subcontracting
and product analysis.
5. Factory standards
Covers the requirements for the building infrastructure, facilities and
fabric, product flow, maintenance of equipment, housekeeping, cleaning
and waste management.
6. Contamination control
Covers the requirements for foreign object training, glass control, blade
control, chemical and biological control, pest
control and transport, storage and distribution.
7. Personnel
Covers the access and movement of personnel, staff facilities, toilets
and hand washing, eating, drinking and smoking, illness and injury, jewellery
and personal items, protective clothing and hygiene
training.
8. Risk category determination
In this section the supplier uses the decision tree to determine whether
they are a category A or B risk supplier.
Certification
bodies
It is a requirement that the certification
bodies evaluating against the standard are formally accredited to the
European standard EN45011 (General requirements for bodies operating product
certification systems). Formal accreditation of a certification body can
only be granted by a National accreditation body; in Great Britain this
Body is the United Kingdom
Accreditation Service (UKAS).
In other countries this includes National accreditation bodies which
are members or associate members of EA (European Co-operation for Accreditation)
or subject to bi-lateral or multilateral agreements. Accreditation is
awarded after a detailed assessment has found that the certification body
complies with all of the criteria of EN45011.
Over 30 Certification Bodies have been accredited by a national Accreditation
Body to EN45011. An up to date list containing full contact details for
these organisations can be found at the following page: BRC
Global Standard - Packaging | Accredited Certification Bodies.
Implementation
guide
Achieving the The BRC Global Standard -
Packaging can be relatively easy or very difficult; this depends to a
large extent on how mature and well developed your current technical/hygiene
management system is. If you are an established supplier of packaging
to the UK or European food industry it should be a case of evolution rather
than revolution.
To ensure a smooth transition to the BRC Global Standard - Packaging it
is essential to have a good action plan. The following plan is provided
as a guide and assumes that you have already recognised (or your customers
have) that you must achieve the standard.
If you feel that you need external
help developing your system we offer a range of services to help you:
1. Research the subject
Buy a copy of the standard and carry out the decision tree analysis
to determine whether your company is a category A or B risk supplier.
2. Carry out a gap analysis
Carry out a gap analysis of your current technical/hygiene management
system against the requirements of the BRC Global Standard - Packaging.
Determine the procedures you need to write or amend, any building or facility
upgrades that may be necessary, as well as additional services and/or
equipment that may need to be purchased. Get quotes for everything and
draft a project proposal including cost, time and human resource needs.
3.Take the proposal to senior management
Show senior management requests received from customers requiring you
to achieve the standard, this should help to secure commitment. Explain
the scope and requirements of the standard, what you need to do to achieve
it, and how much it is going to cost them. Be prepared to compromise,
but not too much (you have the standard on your side). Try to sell them
some benefits (a significant reduction in the number of customer audits
is a good one). Work with senior management to draft the policy and define
management responsibility.
4. Run a workshop with all Managers/Supervisors
Explain why the standard is required and the benefits it can bring (less
customer audits, consistency of message, increased productivity). Inform
them what changes will be required and how this will affect them. Build
your Hazard Analysis team from this group. Helping identify the hazards
within their process will facilitate greater understanding and they will
be more likely to take ownership of solutions, controls and procedures,
and this is vital.
5. Carry out the Hazard Analysis with your team
HACCP is not a requirement of the BRC Global Standard
- Packaging, however, it is the universal method for conducting
a food safety hazard analysis and the methodology does provide a useful
framework for conducting a hazard analysis in a food packaging context.
Covered in detail in the HACCP resource.
6. Brief all remaining employees
To ensure wide commitment to and effectiveness of the
technical/hygiene management system, it is critical that all employees
understand, at the very least, the basics requirements of the standard
and what their responsibilities will be. After all it is the front line
staff who will be expected to put the procedures and controls into practice
and they can make or break the system.
7. Develop the systems
Develop the procedures and purchase essential equipment, roll
out the procedures as they are developed. (one small sentence but a lot
of hard work!).
8. Audit and refine the procedures
Procedures may look great in a manual, but often they do not
reflect what is happening in practice. Audit new procedures frequently
until they become standard practice. Once a procedure is standard practice
the audit frequency may be reduced.
9. Get your system evaluated
A list of accredited organisations who are fully
authorised to issue certificates of compliance against the BRC Global
Standard - Packaging is available in the Buyers
Guide. The certification process consists of an intensive initial
evaluation (usually one or two days depending on the size and complexity
of your operation).
If you comply with all of the requirements of the standard (at the first
attempt) you will gain certification and you should give yourself a mighty
pat on the back! However, in most cases some non-conformities will be
identified and these will need to be addressed before Certification can
be achieved.
Following certification evaluations are every 6 months
although the frequency may be reduced to 12 months for continued demonstration
of compliance to the requirements of the standard.
| Jargon
Review |
| EN45011 |
The standard for the European Accreditation of bodies who are involved
in certification. |
| BRC |
The British Retail Consortium. |
| Certification body |
Companies who have gained accreditation to EN
45011 for the scope of the BRC Global Standard - Packaging. |
| Consumer |
The end user of an item, commodity
or service. |
| Contamination |
The action of making impure or hazardous, usually
caused by foreign object, chemical or microbiological means. |
| Evaluation |
A systematic examination to measure compliance
of practices with a pre-determined system, whether the system is implemented
effectively and is suitable to achieve objectives, carried out by
certified bodies. |
| Decision tree |
A diagrammatical tool to aid in making the decision
whether category 'A' or category 'B' risk supplier. |
| Due diligence |
Demonstration that all reasonable
precautions have been taken to prevent a food
product causing harm to the consumer. (a legal defence). |
| HACCP |
Hazard Analysis Critical Control Point. |
| IOP |
The Institute of Packaging. |
| Retailer branded products |
Products bearing a Retailer's logo, copyright,
address, or are products that are legally regarded as the responsibility
of the retailer. |
| Risk |
The likelihood of occurrence of harm from a hazard. |
| Traceability |
The ability to trace back to all components and
records of a manufactured product. |
| UKAS |
The United Kingdom Accreditation Service. Recognised
by the British Government as the sole national body responsible for
assessing and accrediting the competence of organisations in the fields
of measurement, testing, inspection and certification of systems,
products and personnel. |
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