What is a Code of Practice as per the BRC/IOP Standard?

what is code of practice for BRC/IOP..

I am guessing that you are referring to clauses 1.2.4 and 2.2.2 of the Standard.

These refer to having knowledge of any industry sector specific codes of practice.

For instance the European can making industry has a Code of Practice (EMPAC) and the paper and board industry has a couple as well (eg CEPI)

These give background and guidance on various technical aspects of those sectors which may be relevant to your operation and hazard analysis.

then how can ı find my code of practice. is there a list of practices for all pacakaging firms?



For instance

I am guessing that you are referring to clauses 1.2.4 and 2.2.2 of the Standard.

These refer to having knowledge of any industry sector specific codes of practice.

For instance the European can making industry has a Code of Practice (EMPAC) and the paper and board industry has a couple as well (eg CEPI)

These give background and guidance on various technical aspects of those sectors which may be relevant to your operation and hazard analysis.

There is not a list of Codes of Practices.

What is the sector that you work in?

we produce metal closures for beverages and jars

This is the European Metal Packaging Association Code of Practice. There may be a similar one for Turkey.

Are you working towards BRC/IoP Certification or was this a non conformance in an audit?

I have audited quite a few metal closures operations for BRC/IoP, so if you have any other queries, post them and I may be able to help.

Thanks for your helping documents. I am working towards BRC/IoP Certification. Issue 4 is really confusing for me. I would like to revise hazard and risk management system.mine was according to ISO 22000. how could the new system be.

Preparing a hazard analysis is a big subject and not one that can easily be organised over a forum like this, excellent though it is.

I will lay out a few points that I feel may help.

The analytical tools that you use for ISO22000 are likely to be valid for BRC/IoP.

However, one area which 22000 often doesn't seem to understand is the types of hazard which are relevant to your products.

For food products, generally the types of hazard will be chemical, physical and microbiological. For your products they will be different. The types of hazard that the BRC/IoP wants you to evaluate in addition to those 3 are functionality and legality hazards.

Microbiological hazards are likely to be very unlikely for your products. Your process will include a compound bake oven and your customers will mostly have a heat treatment process.

Chemical hazards can occur, and this will include any migration from the compund.

Physical hazards can occur almost anywhere.

The concept of functionality hazards is difficult to understand when you first go into it.

Packaging is designed to protect and inform and to enable the contents to be used safely. Therefore the functionality hazards should include aspects of how this can be achieved.

The hazards to consider in your process (and there are others)

Correct choice of materials - different compounds are used for sterilisation and pasturisation, low/high pH, oily foods etc. They must be legal eg BPA is banned in some countries.

Dimensional attributes - making sure that the closure fits and any tamper evident systems work

Correct temperature/time profile in the bake oven to cure the compound.

Mixed product controls, cameras, line clearances etc.

Ability to read any important text - eg allergen statements

Whether any of these is called a CCP will depend upon the risk analysis model you have chosen.

I am sure that you will already have controls in place for these, but it is important that they are included in the hazard analysis.

do you think that integrity and critical packaging defects for customer safety means functionality?

Yes, if you read the clause (2.2.5) the phrase is '...functional integrity and peformance of the final product in use' This could be the operation of a tamper evident system.

Defects critical to consumer safe can include many things but possibly the most serious is mixed designs where the result can literally cause death. (eg mixing sugar free product with full sugar products affecting diabetics)

Dear foodeng,

I realise the specific packaging application is different to yourself however you may find the general info. in thread below useful, and the attachments in post #7

http://www.ifsqn.com...dpost__p__39717

(from memory there are some other useful attachments around also but cannot remember the location at moment, you could try a little IOP forum browsing but I know is quite big now )

Rgds / Charles.C

as explained 3,7 the spesification must include declarations. how can ı make formal agreement with customers and how can ı show it within the spesification?

There are a few separate points here, all of which you need to cover.

1. You need to create a finished product specification. This needs to include all of the important properties of the individual product - materials, dimensions, artwork, applications and packing formats (ie boxes, pallets, palletwrap) amongst others. You will have engineering drawings or similar which can form part of this. The specification will normally have a general statement about compliance with legislation. (eg EU 1935/2004 or Turkish food contact legislation)

2. You need to agree the specification with customers or at least be able to demonstrate that you have taken steps to reach agreements. Probably in your business, this will not be too much of a problem. I would guess that most of your products are designed for a individual customers. You may have some generic designs which possibly you sell through distribution agents. Sending the specification to the customer or agent is the first step and then pushing them to sign agreement.

3. There is a requirement to create a Declaration of Compliance. This is more than a simple specification and is part of EU law, which the BRC has adopted as a requirement. Its purpose (at least one of them) is to identify how you are able to justify that the product is safe for contact with the food. I will attcah some guidance on this. The Declaration should be sent out ideally with every delivery, but certainly once a year or if there is any change to the materials that you use. It is a big subject, and heavy going I am afraid.

Don't forget about raw material and other specifications as well

3. There is a requirement to create a Declaration of Compliance. This is more than a simple specification and is part of EU law, which the BRC has adopted as a requirement. Its purpose (at least one of them) is to identify how you are able to justify that the product is safe for contact with the food. I will attcah some guidance on this. The Declaration should be sent out ideally with every delivery, but certainly once a year or if there is any change to the materials that you use. It is a big subject, and heavy going I am afraid.

I'm reading this thread with interest, thank's foodworker.

One point to add to the above is that packaging materials are not always globally suitable for all foods and all processing and usage parameters of the food producer and therefore must be proved by migration testing and shelf life trials etc.

For example imagine you intend to supply your packaging to a food producer customer that has a high fat product, that is hot filled at 95C and then frozen with a shelf life of 2 years. The legal suitability of your packaging for this product must be proven. So as a supplier either you or your raw material supplier will conduct migration tests with various simulants, which will prove whether or not the packaging material is legally suitable for use with high fat products and other food groups, but still it may not prove to 95C and 2 years shelf life.

As a packaging supplier you can recommend packaging specifications to your customer based on the tests you have conducted, but if their product and processing combination falls outside of your test data they must carry out there own tests. You must establish how they intend to use the packaging and make any limitations (untested parameters) clear to them during the contract review, sampling, trialling etc.

To be honest it's an absolute minefield.
I just wanted to make that clear, hope it makes sense.

Regards,
Simon