BRCGS Packaging Issue 6: Key changes

Richard Leathers, Food Safety Management System Lead

BRC Global Standards has recently launched a new packaging standard (BRC Global Standard for Packaging and Packaging Materials Issue 6) with changes that bring it in line with Global Food Safety Initiative (GFSI) requirements, industry best practice and the BRC Global Standard for Food Safety Issue 8. In this video, Richard covers the changes that you may need to be aware of and how they may affect you.

About Richard Leathers

Richard Leathers joined Campden BRI in September 2011, and has worked in the food industry for 4 decades.

Richard started working with Dairy Crest and subsequently worked for both Heinz, Unilever, Best Foods and Kanes Foods. Working in the areas of HACCP and Quality Management Systems, Richard also has experience within the fresh produce sector, as well as analysis systems in the milling / baking areas, and is a BRCGS qualified lead auditor.

Richard has contributed to several publications and guidelines, including those for TACCP, VACCP and HACCP / Risk Evaluation and is also trained at advanced level by EHEDG (European Hygienic Engineering Design Group).

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We're here today to talk about Issue 6 of the BRCGS Packaging Standard. A lot of the changes that have happened to this standard bring it in-line with GFSI requirements, but also bring it in-line with some of the changes have happened in Issue 8 of the food standard. What the process for changing standards and updating the standards is we get a lot of packaging manufacturers but also retailers and independent experts that come together to update the standards.

One of the first big changes is to introduce culture into the standard clause 1.1.2. This is a read across from the both the GFSI and the food standard one important thing to note here for packaging manufacturers is that this clause is being deferred a year to allow packaging manufacturers to get used to it, so this will not be audited until the 1st of February 2021, whereas the rest of the standard is being audited from the 1st of February 2020.

One of the other new areas is in environmental monitoring. Now it's important to say here that this environmental monitoring clause is based on risk, and this may not be applicable to all packaging manufacturers. There is a BRCGS positioning statement on this number p558 so it's important to reference that or if companies want to get in touch with us, we can give them guidance and advice. It may not be applicable because if you're producing packaging that is not in contact with the product, then there's less risk than if there is. It also may be important to look at not necessarily pathogens but yeasts and molds.

Another area to be aware of is product defence - in the food standard this is food defence. Product defence is clause 4.4 and we have seen this is the 15th most populous non-conformance in the food standard so it is something to be aware of in in packaging as well. There's a number of changes in section two but one of the big focuses there is to move to the terminology of hazard and risk analysis (away from previous definitions). This allows a separation from quality and product safety in packaging so that they're both covered slightly differently. Linking into the product defence and product security that we spoke about is there's some new clauses again that read across from the food standard on digital protection and cyber security so in the packaging standard its Clause 3.2.2 and there's also other areas that need to be aware of within that.

One of the big areas of non-conformity in both the food standard and the packaging standard is within internal audits - this is section 5.2. Now there's a number of updates within this section so it's important for packaging manufacturers to look at those updates and make changes accordingly.

Some of the smaller but still significant changes within the packaging standard Issue 6 include updating overhead walkways where there is a risk so Clause 4.2.6. This is important to say where there is a risk so where there's open and exposed packaging there may need to be covers and controls. Some of the other areas here are on things like ‘whistle blowing’, glass controls and sharp controls as well.

One of the big new areas and sections is on corrective and preventive actions - section 3.6. This is not only new but it's also a new fundamental clause within the packaging standard. A new a fundamental clause is quite key because if a packaging site gains a major non-conformance against a fundamental clause, that has serious repercussions. Finally, within the packaging standard Issue 6, there are two new voluntary modules: the first one is on traded goods which again ties in with the food standard but the second one is a voluntary module based on plastics and it's for pellet flake and powder control again it's a voluntary module.

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