BRC Risk Assessment - Issue 4

Pls clarify following clauses.

2.2.5

hazards considered shall include, where relevant:

• potential problems arising from the use of recycled materials
• legality
• defects critical to consumer safety
• hazards that may have an impact on the functional integrity and performance of the final product in use. 

Thanks.

I am assuming your product is meant for direct food contact, if so.  

• Potential problems arising from the use of recycled materials

If there is an element of recycled material in your packaging product you have to be 100% sure (and have evidence) that it is not going to cause any chemical contamination / migration into the foodstuff.  Often a problem with using recycled materials can be variance and unknown "other" materials (perhaps undesirable) mixed during the recycling process.  If you use virgin materials for your packaging products then this can be marked in your system as an exclusion.

• Legality

Your packing product must comply with the relevant legislation in the countries where your product will be sold (especially relating to food contact packaging), so you need to understand this legislation and ensure relevant tests e.g. migration are undertaken.  You of course need records demonstrating your understanding and compliance.

• Defects critical to consumer safety

Maybe holes in the packaging, print defects with maybe important ingredients (nuts) missing or out of register / unreadable.

• Hazards that may have an impact on the functional integrity and performance of the final product in use 

The packaging does not work to specification, maybe it is meant to seal onto the top of the container and falls off, or leaks.

In short:

1. You need to fully understand all of the "ingredients" that make up your packaging product

2. Ensure their combination and the final product meets relevant regulations in the place it will be sold

3. Ensure the packaging works as required and is as per the agreed specification with the customer

Of course if your product is not direct food contact the above would be considered in a different way.

Hope this helps, if you have further questions let me know.

Dear chinthaka,

You may also get some ideas regarding interpretation of the standard (Low/high risk)  by looking around the IT.  There are a number of  examples of actual audits here and there.

Not to forget the various existing queries on this forum of course. :smile:

Rgds / Charles.C

Thanx for your Reply.  Yes, We are manufacturing food containers.

• Potential problems arising from the use of recycled materials

We are not using recycled materials for our products. Do we have to do risk analysis on above clause?
 
And pls go though with attached Hazard Identification and Analysis sample formats.
 
 
 
 
 
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