Hi all, and Happy New Year.
Yes, just like the term "high risk" BRC has put their own unique definition to a fairly common industry term - "primary packaging". Arguably a more unique term could have been used. The BRC definition, applied only to those facilities intending to undergo BRC certification, is in the standard, relatively clearly. That being said, I always encourage sites to look at the intended outcome, before worrying too much about the definition debate. In previous versions, there is the generic term "packaging" - then you look at a specific requirement and the endless debate about which pieces of packaging us that clause relevant to... one of the most debated was traceability. This gives much clearer direction, which I do appreciated.
If you go through the 8th issue of the Standard, here is where the term "primary packaging" comes into play - and which clauses you can now see apply (to things like food contact packaging) and which don;t apply (typically things like shrink wrap on the outside of a pallet, or a pallet license plate).
What applies to "primary packaging"?
3.5 having an effective supplier approval program
188.8.131.52 perform a risk assessment on it as a raw material
184.108.40.206 create an effective supplier approval mechanism based on the risk assessment
220.127.116.11 do the same if you purchase the materials from a broker
18.104.22.168 ensure the supplier has a traceability program
3.5.2 have an effective, risk based receiving and acceptance program
3.6 have specifications for it
3.9 the site being certified needs to have some form of traceability on the materials
4.7.5 maintenance materials coming into contact with the materials should be approproate
5.5.1 potential product / package interactions or needs should be identified
Looking at the list, which is really just basic supplier management, you can see how using the definition gets the right material into a proper management system.