Preparation for BRC Packaging and Packaging Materials Issue 5

Hello!o

Our sister company is preparing for the certification, the product for now is cartons and labels intended for canned tuna.

Any advice or tips on the preparation?

The management decided for the high hygiene category (there is a plan to produce packaging with direct contact to food in the future)

Thank you,

Chastine

Hello!o

 

Our sister company is preparing for the certification, the product for now is cartons and labels intended for canned tuna.

 

Any advice or tips on the preparation?

 

The management decided for the high hygiene category (there is a plan to produce packaging with direct contact to food in the future)

 

Thank you,

Chastine

Hi Merry Chastine,

I don't quite understand how you can be audited for the high hygiene category if no relevant production exists ?.

Hi Charles,

I forgot to mention the product, it's pouches, cake boxes, and grease proof papers (for hamburgers)

Thanks,

Chastine

Hi Merry Chastine,

Assuming BRCPackaging  is similar to BRCFood, my tip is to make sure you invest in a "preliminary" audit.

Hi Charles,

Thank you.  We are planning to conduct a gap assessment (preliminary audit)

I have additional query, the facility will be under both the high hygiene category and basic hygiene category, the management decided for high hygiene category

What do you think?

Thanks,

Chastine

Hi Charles,

There is a risk assessment/analysis required in BRC Packaging Issue 5.  Can you assist me on this one.  Is there an example Risk Assessment for Packaging?

Thanks,

Chastine

Hi Charles,

 

There is a risk assessment/analysis required in BRC Packaging Issue 5.  Can you assist me on this one.  Is there an example Risk Assessment for Packaging?

 

Thanks,

Chastine

Sorry but I'm only directly familiar with Food.

I think there are other threads on yr query here already though, which clause No. do you refer ?

We are BRC 5. High hygiene, We do not have any direct contact but are audited to this standard so that we could attract more customers/products and do direct contact if we had the request from the customer. 

There are several risk assessment in this BRC. Obviously the HACCP one but then several others about wearing PPE, when, where. We used the standard matrix often used in Health & Safety. i.e. likelihood and severity. see example attached.

Gap analysis is ideal. They go through the standard clause by clause so have evidence for it all.

Hi Sharon,

Good Day!

Thank you for the information.  Yes, gap analysis is ideal, we are about to start the gap analysis this month.  Can you send again the example, I can't see the attachment.  For sure this will really help us and give us idea on how to start with the risk assessment

Regards,

Chastine

I never knew packaging and packaging materials supplier can have high hygiene category. following this thread. :spoton:

oops. Sorry, Here is am example attached.

Hi Sharon!!!

Thank you very much!! I will study and get back to you if I have some clarifications

Again, thank you very much

Regards,

Chastine

We are BRC 5. High hygiene, We do not have any direct contact but are audited to this standard so that we could attract more customers/products and do direct contact if we had the request from the customer. 

There are several risk assessment in this BRC. Obviously the HACCP one but then several others about wearing PPE, when, where. We used the standard matrix often used in Health & Safety. i.e. likelihood and severity. see example attached.

Gap analysis is ideal. They go through the standard clause by clause so have evidence for it all.

Hi Sharon,

I am intrigued by yr (2nd sentence) comment re auditing. (Also see Post2 above).

Such a factor would IMEX be a "scope-breaker" for Food, eg could not be certified for RTE Production if only do raw items. Do auditors for BRC Packaging really not care ?

Hi Charles,

  Of course they care. Perhaps you misunderstood.

What we are doing is overkill.

We do more than we need to do for our low risk product. We are audited to the scope for a high risk product. Do you see what I mean? 

The basic hygiene is for none direct contact (food to pack) and is a little less stringent than the high hygiene.

 We do more that the basic requires but our scope is for High hygiene to we maintain standards for that. .

We make secondary packaging but our procedures are stringent enough for primary contact /direct contact . We maintain this level to allow us to do contact packaging if we are asked for it. I believe we have had 1 job for direct contact in the last 12 months. Yes we are over kill for most of our products but this is our Snr Managements decision. 

Hope this clears it up for you.

Hi Sharon,

Thks for yr Post. I have attempted to spell out my interpretations below.

I assume the BRC Certification references the specific item(s) whose manufacturing "process" was audited (= HACCP Scope).

I also assume (not my area) that all individual species ("items") within "cartons"/"bags"/'labels" etc are not necessarily created equal, ie some are ("quality") restricted to non-direct contact, others are bi-functional.

The (implicit/explicit) differences between the Standards for Basic/High categories appear to be more than just "Hygienic", eg both hazard analyses (as per usual) require a nomination of "intended use". I assume this input should correlate with the chosen category/BRC Packaging Decision Tree. i aslo assume the choice may have implications regarding the details of the submitted Product Specification (?).

i can envisage (at least) 3 options/scenarios for a specific packaging "species"/item (packaging is not my product area so pls correct me if unrealistic) -

(a) If an item is usable (and may be required) for both direct and non-direct contact i can understand the reason to select the intended use  which matches "high".

(b) If an item is intrinsically usable only for non-direct contact, it would seem IMO "illogical" (and to an auditor?) to select an intended use to match "high".

(c) If an item is usable for direct/non-direct but only ever intended to use for latter, I get it that some Companies may like to "overkill" for some grandiose reason and go for high (probably over-riding the QA Mngr).

Regarding OP, I get the impression that the product under present discussion falls into (b) ?. But perhaps not.

I hope the above makes sense.

Hi Sharon!!!

Good Day!

May I know what's your product?  What kind of packaging?

Our sister company is opting also for high hygiene, even for now they are producing cartons and labels for canned tuna.  They are also producing cupcake boxes and fries boxes (in minimum quantity only), it's one of the main reason going for high hygiene aside for the future product which is the plastic pouches. 

Thank you,

Chastine

Hi Sharon!!!

 

Good Day!

 

May I know what's your product?  What kind of packaging?

 

Our sister company is opting also for high hygiene, even for now they are producing cartons and labels for canned tuna.  They are also producing cupcake boxes and fries boxes (in minimum quantity only), it's one of the main reason going for high hygiene aside for the future product which is the plastic pouches. 

 

Thank you,

Chastine

Hi Merry Chastine,

Please respond to the final query in Post 15.

addendum to post 15

i can also envisage a 4th scenario (d) where the "product" is a generic "group", eg direct-contact "boxes" and some kind of validatable, generic, Product specification is used. This presumably only works if the manuf. processes for different members of the "group" are similar, eg identical CCPs. Similar approach to that used in Foodservice Industry. Perhaps this is what was meant in Post 14.

Hi All,

Afaik, a manufacturing facility audit can only obtain a certification for a nominated product  based on activities encountered at the time of the audit although there may be some generic auditorial flexibility, eg satisfactory evaluation of a breaded shrimp line might enable certification to a "Category" of “breaded seafood products”.  However IM(food)EX, at least one production activity commensurate with a generic “category” must be available for evaluation/certification to such Category.

In other words it seems to me not possible to be certified for a given Category without exhibiting for audit an associated Process/Product Specification/HACCP Plan/Records.

I infer that Basic Hygiene (BH) and High Hygiene (HH) would correspond to two Categories in the context of above text.

As a corollary, it seems to me that an audited packaging facility which desires to have a current product certified as usable for direct-contact, ie to the BRC HH Standard/Category, must be able to validate, inter alia the complete HH Standard’s Clauses, that the input items used in the product fabrication are compliant with the requirements for a direct-contact application (presumably defined by the Product Specification).

Consequently, my basic query is whether the inputs for a product which is currently intended only for non-direct food contact are usually the same as if for direct-contact (I anticipate not) ?.  If yes I can appreciate that a certification for HH should be feasible, and if otherwise, IMO, presumably not (for the specific item under discussion) ?.

Is the above a correct interpretation/not (for say cartons/labels) ? Or is some kind of  “middle path” available ?

Thanks for any thoughts.

PS - 2 older threads partially overlap this query but don't really answer the same question -

http://www.ifsqn.com...ugated-cartons/

http://www.ifsqn.com...food-packaging/

Hi Chastine & Charles ,

Sorry for the late reply. I work on 2 sites and do not access the forum when I am on the other site as I tend to spend most of the time in production.

In answer to Chastine, we make folding box board sleeves for food in the main. The kind of printed sleeve you find on a ready meal.

In answer to Charles I would say we fall into (A) above. As I said previously we have had 1 job in the last 12 month which was direct contact but we do hope to gain more of this business. The main difference is the migration levels from the boards, glues & printing inks. We use low migration materials.

Hi both again,

The cake boxes & fries boxes mentioned by Chasitine are likely to be direct contact. If these boxes are printed the migration of inks needs to be considers too. But the cartons for fish are not direct contact . Similar to ours situation. We decided not to switch between the procedures for BH & HH and decided it would be easier and safer to maintain the procedures of HH all the time. Its prevent confusion of the production staff. 

Hi Sharon,

Thks yr comments.

Based on Post 19, I infer that characteristics such as those mentioned in yr Post 20, eg low migration, if not duplicated in  the OP's fish cartons, would/could prevent a request for Certification to HH Standard.

I anticipate that if a product complies with requirements for HH, it will automatically comply with BH so no reason to switch backwards and forwards.

Hi Charles,

Yes that's right, if you go for HH you can stay that way, but if you go for BH then you end up in a switch if decide to do any direct contact. So as I said previously we are overkill for most of our products and the auditors are quite happy with that. 

Hi Charles,

Yes that's right, if you go for HH you can stay that way, but if you go for BH then you end up in a switch if decide to do any direct contact. So as I said previously we are overkill for most of our products and the auditors are quite happy with that. 

hi Sharon,

Since you are maximising FS, the auditors should be happy.  Hopefully customer loyalty may also be optimised.

Hi Sharon,

Thank you very much for your reply. 

Hoping to coordinate with you in the future, we just finished our pre assessment.