13 replies to this topic

[Simon]

Version 4 of the BRC/IOP Global Standard for Packaging is due early next year. There are a number of proposed changes detailed below. Please note these are not finalised and the list may be incomplete, but they should give users and idea of what to expect and perhaps to make some preparations.

2.2 Hazard and Risk Analysis

2.2.4. The hazard and risk analysis shall include microbiological, foreign objects and chemical (e.g. taint, odour, allergen, component transfer from inks, varnishes & glues) contamination, any problems arising from the use of recycled materials, legality and defects critical to consumer safety as well as those hazards that may have an impact on the functional integrity and performance of the final product taking into account the customer requirements.

2.3 Hazard and Risk Management Prerequisites

Hazard and Risk Management Systems - New sub-section

2.4 Prevention of Malicious Interventions

A formal system with senior management support shall be in place to minimise the risk of malicious intervention to premises, materials or processes

2.4.1 A team, with senior management support, shall be tasked with responsibility for this area

2.4.2 A regular review shall be undertaken at appropriate planned intervals, as a minimum annually, to minimise the risk of malicious interventions. Records etc of reviews shall be documented and retained as per item 1.9 above. Areas to be reviewed include:

• Site security (including IT systems to ensure they are adequately controlled and backed up)
• Personal records (for example addresses, background checks, criminal record checks) as appropriate for employees, contractors, customers, visitors and others entering the site
• Materials, deliveries and supplies – see item 3.5 below
• Storage and shipment of finished goods – see 4.10

2.4.3 An action plan action plan shall be produced to address issues arising from 2.4.2 above. Such a plan shall include timescales and those responsible for each action.

2.4.4 A team shall exist to manage any incident of malicious intervention. Such a team shall be headed by a senior manager and have both human and other resources necessary to carry out its responsibilities

3.5 Supplier Monitoring

Clause Requirements Category 1
3.5.1 The company shall have a documented supplier approval procedure and continual assessment programme in place, based upon hazard and risk analysis. “This shall include the risk of malicious intervention”

5.1 Product Design and Development

Print Control

Requirement

1. A clear documented procedure for the control of printing must be in place. Print controls must:

• Eusure that any print containing allergen/safety/legal information is correctly printed
• importance of preventing mixing of any print containing allergen/safety/legal information
• action to be taken in the event of non-conformaties

2. All printing plates must be clearly identified and traceable to the customers (approved) origination material.

• Generic plates shall be clearly identified.

• Traceability for printing plates must include a signed record on the production documentation to ensure the correct printing plates are issued for a job

3. Verification of the design shall be carried out and documented before the approval to run the product is given.

4. A line clearance procedures must be in place to ensure that at start up, the line is clear of all previous work and that previous production documents have been removed.

5. Samples of print must be kept from the start and end of each print run and quality checks made at appropriate intervals during the run.
A system must be in place to detect and flag any print errors.

6. All unused printed packaging must be accounted for and disposed of.

7. Records of printing must be maintained with printed samples retained

8. All personnel carrying out printing checks must be appropriatly trained and adequately supervised

[GMO]

Interesting the focus on malicious contamination (I would say more rigorous than the "normal" BRC standard). I can understand the focus on allergen information printing due to the number of FSA alerts (but I still maintain this is mainly due to mixing up different packaging types at the printers and in factories not due to misprinting).

[Simon]

Interesting the focus on malicious contamination (I would say more rigorous than the "normal" BRC standard). I can understand the focus on allergen information printing due to the number of FSA alerts (but I still maintain this is mainly due to mixing up different packaging types at the printers and in factories not due to misprinting).

I agree GMO, mixed packaging is not usually due to printing incorrectly, it can happen where line clearance and segregation are poor or when generic plates are used across designs as there is much more chance of putting a plate in the wrong job bag. In theory generic plates save money, but they often end up costing as they have to be replaced more often and can get mixed.

Like you I see the hot topics as malicious contamination (food security), but also Printing Quality Control / Assurance which addresses the issues of allergens and mixed packaging as well as addressing the requirement to prevent ink transfer to the food contact side of packaging:

Commission Regulation (EC) No. 2023/2006 on good manufacturing practice for materials and articles intended to come into contact with food

Overall I think these are reasonable additions.

[GMO]

But why the particular focus on malicious contamination, particularly in packaging? Obviously it's important but I'm not aware of any recent packaging examples and it would be more damaging if it occurred in a food company? (Or at least requires more imagination to make it damaging for the packaging company.)

[Simon]

But why the particular focus on malicious contamination, particularly in packaging? Obviously it's important but I'm not aware of any recent packaging examples and it would be more damaging if it occurred in a food company? (Or at least requires more imagination to make it damaging for the packaging company.)

Food defence and security is a ‘high profile’ topic (especially in the US) and I think maybe the powers that be thought that food packaging should consider this area being a critical input supplier to food businesses. Whether or not there is a real risk I suppose it wouldn’t do any harm to assess the risk and I’m sure food businesses would expect their packaging suppliers to do so. The other aspect is BRC are probably trying to promote the BRC Packaging Standard in the USA.

I think the new requirements on print control are far more important and will add a lot of value.

Regards,
Simon

[Charles Chew]

Food defence and security is a ‘high profile’ topic (especially in the US) and I think maybe the powers that be thought that food packaging should consider this area being a critical input supplier to food businesses. Whether or not there is a real risk I suppose it wouldn’t do any harm to assess the risk and I’m sure food businesses would expect their packaging suppliers to do so. The other aspect is BRC are probably trying to promote the BRC Packaging Standard in the USA.

I think the new requirements on print control are far more important and will add a lot of value.

Regards,
Simon

2.4 Prevention of Malicious Interventions

I can understand the concern and also believe there are possibilities of intentional malicious damage than ever before if interventions are not in place. No problem with the standard upgrade. I can live with it.

[Charles.C]

Dear All,

Don't remember much about content of last version but I deduce that the "risk" section has now become considerably more prescriptive. Surprise, Surprise !

I presume 2.4.2 effectively defines the minimum criteria for the risk analysis, nice touch, not generally mirrored in BRC (Food).

Are there any published statistics comparing global take-up of (ISO 22000 / clones [if any]) with BRC Packaging ?. Just curious, didn't see anything in forum index.

@Simon

(especially in the US)

Perhaps that should read only in the US ? (or possibly US / Canada?). I get the impression that the rest of the World is simply oblivious.

Rgds / Charles.C

[rosie]

Thanks for the information Simon

Rosie

[Simon]

@Simon Perhaps that should read only in the US ? (or possibly US / Canada?). I get the impression that the rest of the World is simply oblivious.

Until something happens.

Thanks for the information Simon

Rosie

No problem.

[kaz]

Hi all
not sure how many of you got the email from BRC with link to drafts for the 4th Issue of the Global Standard for Packaging and Packaging Materials.
Kaz

[Simon]

Hi all
not sure how many of you got the email from BRC with link to drafts for the 4th Issue of the Global Standard for Packaging and Packaging Materials.
Kaz

Kaz and all members, I had to remove the documents at the requets of the BRC. If anyone would like a consultation draft please see below.

Our consultation net is planned to be as wide as possible and we are quite happy for you to put a note in the forum stating that anyone who would like to see a copy can do so by contacting me.

Joanna Griffiths
Technical Packaging Manager
BRC Global Standards
T: 020 7854 8947
E: Joanna.Griffiths@brc.org.uk

[JoGriffiths]

Happy New Year all!

As you're all probably now aware, Issue 4 of the Global Standard for Packaging and Packaging Materials will be published on 25th February. See the summary at http://www.brcglobal...ging-materials/

Pre-order copies here:
In print - http://www.tsoshop.c...35945&DI=628588
In pdf - http://www.tsoshop.c...35945&DI=628593

Training will be available soon, contact the BRC Training team for more details.

[Sylvester]

Thank you for the update Jo.

Happy New Year!

[kaz]

I have attached Version 3 verses version 4 index. Hope this helps some of you  Issue 3 versus issue 4 indexes live.xls   28KB   44 downloads