April 15, 2019|
In less than four months, a new issue of the BRC Packaging and Packaging Materials standard is expected to be released. It is still on track for publication on August 1, 2019. DQS Inc. was fortunate to have two members of our leadership team – Mike Pearsall, Director of Food Safety Business Development, and Ron Bergamasco, Food Safety Program Manager – able to participate in the development process. After the estimated publication in August, there is a transition period of six months. The use of Issue 6 is compulsory for all certification audits taking place from February 2020 onwards. Prior to that date, it is not possible to be certified according to the new version.
As a reminder on the changes, we have an article from our colleagues at DQS CFS on the changes below.
The new BRC Global Standard for Packaging – Issue 6 includes six major changes: two key changes concerning the protocol and four key changes regarding the requirements of the former Packaging and Packaging materials – Issue 5 certification.
While reading please keep in mind that the requirements and protocol are still subject to change.
Changes to the Protocol
- Removing the second hygiene category – In Issue 5 there were two categories of requirements, depending on the intended use of the packaging material – high hygiene and basic hygiene. Removing the two-category system simplifies the use of the new standard. The differing hygiene levels will be replaced by a risk-based approach, based on only one set of requirements. Some requirements will have a higher or differing level of hygiene that applies to “food contact materials”.
- Removing second/split unannounced audit option – Version 5 of the BRC Global Standard for Packaging offered three audit options: Full announced audit, full unannounced audit, and split unannounced audit. The last one divided the audit requirements into two separate audits, the first one unannounced and the second one announced. Reflecting that the full unannounced audit option is generally preferred because it gives extra confidence to specifiers, Issue 6 will be in line with Issue 8 of the Food Standard by removing the split unannounced audit option. Unannounced audits remain optional.
Changes to the Requirements
- Corrective and preventive action: fundamental clause – The new version of the standard integrates specific requirements on corrective and preventive action (CAPA) related to root cause analysis into a structured continuous improvement approach. This way the root cause analysis is assembled in one paragraph, in line with Issue 8 of the Food Standard, emphasizing the importance of addressing issues with the intent to remove the risk of re-occurrence and supporting continuous improvement. This is a fundamental clause, which means that sites that have not implemented this clause cannot be certified. The fundamental clauses are marked with “FUNDAMENTAL”.
- Emphasis on product quality – BRC Global Standard for Packaging is not just a hygiene standard – its scope covers both product safety as well as product quality. Issue 6 places even more emphasis on product quality and clearly distinguishes between safety and quality. In the hazard and risk analysis (HARA), Issue 6 separates hazards into product safety and quality defects to improve control measures necessary to prevent, eliminate or reduce each product quality hazard to acceptable levels (2.2.6).
- Product safety and quality culture – Issue 6 emphasizes the importance of the culture at a site. It does so by introducing a new clause (1.1.2). The clause requires sites to set up, execute and review an action plan to improve product safety and quality culture. This does not imply that the auditor will assess the culture of the organization, but rather that (s)he examines the efforts made to document the status of the organizational culture and the steps that are put in place to improve it.
- Pellet, flake and powder control in the plastic industry – Section 8 of the BRC Global Standard for Packaging – Issue 6 acknowledges the importance of raw material management in the packaging industry with the intention to remove new plastic contamination from food supply chain. This regards the removal of risks of cumulative chemical contamination of the human food chain and removing the risk of starvation of fish and marine mammals. Section 8 is applicable to the conversion of polymer from pellet, the use of flake or powder and the use of hot melt glues, particle raw materials etc.