Determining risk category using the decision tree in BRC/IOP

High hygenie risk category offers the primary food contact material production. Low hygenie risk category gives requirements for secondary packaging (there is a notification for the low hygenie category, it says '' some forms of primary packaging may fall into this category, most notably labels for use with packaging materials that do offer an absolete barrier, such as glass and metals''. Our company manufactures jar metal closures. what is your opinion about which category ı fall into?

Sounds like direct food contact thus High Risk.

Metal closures for jars will certainly be High Hygiene Risk.

Just to muddy the waters, the BRC have recently decided that only metal and glass will now be considered as providing an absolute barrier when using the Decision Tree.

This has got some far reaching consequences.

For instance, labels applied to the outside of polybags or PET bottles will now be High Hygiene Risk.

I must confess that the logic and relation to hygiene escapes me somewhat.

Metal closures for jars will certainly be High Hygiene Risk.

Just to muddy the waters, the BRC have recently decided that only metal and glass will now be considered as providing an absolute barrier when using the Decision Tree.

This has got some far reaching consequences.

For instance, labels applied to the outside of polybags or PET bottles will now be High Hygiene Risk.

I must confess that the logic and relation to hygiene escapes me somewhat.

Hi Foodworker and Happy New Year. I cannot imagine this change is related to foreign body or micro issues and more likely chemical migration risk assessment / prevention. Do you see any 'high risk' requirements that would be totally unnecessary or could be excluded for labels?

Regards,
Simon

And A Happy New Year to you too.

Migration is pretty much the only risk that I can come up with although I am not aware of any recent scares or information to suggest that there is any significant risk from inks or adhesives passing right through plastics and into food. In fact the last FSA benzophenone survey concluded that there was "little evidence" of this type of migration.

With respect to exclusions, the devil unfortunately is in the detail.

It would be fairly easy to justify exclusions for most of the additional personal hygiene requirements, but there are more sublte differences between the two categories to watch out for.

eg

Under maintenance, High Risk requires that there are post maintenance cleaning records (4.7.4) whereas the Low Risk only requires that the equipment is checked (4.7.2) It seems a small difference, but in my experience difficult to build into a system, particularly where maintenance plans etc are computerised.

The detail required for cleaning schedules and records is much higher.

Glass/plastic audits now become a requirement

EFK catch tray analysis is also required.
etc.

Remember also that exclusions can only apply to Sections 4-6. There are differences between the categories in 1-3 which cannot be excluded.

Companies which are currently under the Low category are going to have to go through the Standard with a fine toothed comb to pick up the differencies otherwise they are going to pick up a lot of NCs, and there is no transition period.

Yes certainly a shock to the system for those affected and a lot of work. Was this part of Issue 4 or some sort of technical committee decision. Either way seems very ill thought out. I suppose we can expect an influx of secondary packaging members looking for answers soon enough.

Cheers,
Simon

As I understand it, the decision was made by a technical committee, although not the full one, to clarify and make the use of the decision tree more consistent.

Interesting point about secondary packaging. The BRC has a unique definition of secondary.

- "Packaging that is used to collate and transport sales units to the retail environment eg corrugated cases" (p99 in the Glossary)

Most people would consider it to be packaging that is separated from the product by another packaging layer. What if you don't sell to a retailer?

Again, this muddies the waters about the risk category.

They have said that secondary packaging will be Low Hygiene (which it should be in my opinion), but if there is a risk because of 'contaminants' from labels migrating through plastics, is there not also a risk of phenols, taints etc migrating from lower grade boards used to 'collate and transport' through plastics. The BRC seem to be saying no which, is inconsistent.

An example of this is a case of vacuum packed bacon. The label on the pack is High Risk, but the case, which is also in contact, is Low Risk.

I can't grasp the logic.

I think they should have left it as it was and let the migration / chemical risks be determined by hazard and risk analysis for all types of packaging. Surely the chances of chemicals from a label adhesive migrating through a plastic container are minute and as you say all of the other requirements are just burdensome and not necessary. I know that some 'secondary' cardboard box manufacturers ensure mineral oils are removed from raw materials and also conduct their own finished product migration testing. Unless there was some other reason for the change that we are unaware of.

Regards,
Simon

Some days ago I asked a Certifiyng Organism which risk category should be assigned to pulp paper trays used in contact with fruits like melons, apples, peaches, etc. and used also for whole eggs. The answer was that they could be considered as low risk packaging. I do not feel very comfortable with this answer, since apples and some other fruits are often eaten without peeling and because there has been a recent big outbreak with many fatalities related to Listeria monocytogenes in Cantaloup melons. I have to say that I do not have a copy of the 4th edition of BRC-IoP Standard, to check the decission tree by mayself, but I would appreciate to have some other opinions.
Many thanks in advance
Enric Riera

From your description, High risk, no question.