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Allergen & radiological declarations for food contact materials?

BRC Food contact materials

Best Answer pHruit, 10 December 2019 - 09:13 AM

The legal side of things is, at face value, a fairly simple case of being obliged to make sure that what you're using is suitable for purpose. I'm not aware of a specific regulation that says "you must have declarations", but without these one would have to wonder how you'd prove the point. Nonetheless I expect it is enforced in proportion to the scale and nature of the business - I'm pretty sure that a lot of smaller food companies and caterers wouldn't have these on file, but I don't recall ever seeing any of them challenged on it.

BRC is a bit more forthright about what it expects, but whether you'll be picked up on it depends on the auditor - there isn't time for them to check everything during each audit, but certainly over the years we've had to provide these for various direct and incidental food-contact materials such as gaskets, seals etc.

If the belts etc are direct food contact, or potentially food contact, then I'd agree with your supervisor that it's sensible to get the statements together for them.

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#1 RSantos

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Posted 03 December 2019 - 08:10 AM

Hello,

 

I am currently doing an internship in a red meat company and i am currently managing material technical data sheets and compliance declarations. Our company demands that Plastic suppliers send an "allergen declaration" and a " radiological hazards declaration". I would like to know what specific clause of BRC demands this two declarations.

 

Further, our knives supplier states that for this specific material it is not required to send this two declarations but as it is a food contact material (clause 4.7.5), at least the "allergen declaration" should be needed, am i right?

 

Thanks in advance,

 



#2 pHruit

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Posted 03 December 2019 - 01:38 PM

BRC generally doesn't have a "thou shalt" approach* to this type of thing - really it is up to the business to determine how they want to meet the aims of the standard.

4.7.5 is more focussed on the stuff you're using to maintain your site, rather than the equipment itself - this sites more in 4.6.

Is the plastic part of your equipment or a packaging material? The latter is fairly simple as this falls under 3.5.1.

Equipment is more ambiguous as the standard necessarily has to cover the entire spectrum of materials and equipment used in the food industry, so rather than giving an enormous checklist where 90+% will be inapplicable to any given business, they've instead gone with more generic requirements like "constructed of appropriate materials" and "suitable for food contact and meet legal requirements where applicable".

Your business (i.e. probably your boss, given that you're an intern) would need to determine what those requirements are.

 

 

 

*It is very "thou shalt" about doing risk assessments, though ;)



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#3 RSantos

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Posted 09 December 2019 - 05:48 PM

First thank you for your answer, really helpfull. But i still have some doubts, cause we are a meat plant we work a lot with plastic conveyor belts, knifes. We do posess a list of all packaging materials so we collect the Technical datasheets and Conformity  Declarations and BRC certificates and so on.

But when discussing with my supervisor, she suggested that we make an assessment of ALL materials that come in contact with the food (basically all FCM's) and that we collect the technical datasheets and conformity declarations. My question to her was what was our legal or standard obligation to have those documents (specifically talking about this FCM's like conveyor belts, not packaging materials).

 

Do you know something regarding this specific point?

 

 

BRC generally doesn't have a "thou shalt" approach* to this type of thing - really it is up to the business to determine how they want to meet the aims of the standard.

4.7.5 is more focussed on the stuff you're using to maintain your site, rather than the equipment itself - this sites more in 4.6.

Is the plastic part of your equipment or a packaging material? The latter is fairly simple as this falls under 3.5.1.

Equipment is more ambiguous as the standard necessarily has to cover the entire spectrum of materials and equipment used in the food industry, so rather than giving an enormous checklist where 90+% will be inapplicable to any given business, they've instead gone with more generic requirements like "constructed of appropriate materials" and "suitable for food contact and meet legal requirements where applicable".

Your business (i.e. probably your boss, given that you're an intern) would need to determine what those requirements are.

 

 

 

*It is very "thou shalt" about doing risk assessments, though ;)



#4 pHruit

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Posted 10 December 2019 - 09:13 AM   Best Answer

The legal side of things is, at face value, a fairly simple case of being obliged to make sure that what you're using is suitable for purpose. I'm not aware of a specific regulation that says "you must have declarations", but without these one would have to wonder how you'd prove the point. Nonetheless I expect it is enforced in proportion to the scale and nature of the business - I'm pretty sure that a lot of smaller food companies and caterers wouldn't have these on file, but I don't recall ever seeing any of them challenged on it.

BRC is a bit more forthright about what it expects, but whether you'll be picked up on it depends on the auditor - there isn't time for them to check everything during each audit, but certainly over the years we've had to provide these for various direct and incidental food-contact materials such as gaskets, seals etc.

If the belts etc are direct food contact, or potentially food contact, then I'd agree with your supervisor that it's sensible to get the statements together for them.



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#5 RSantos

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Posted 13 December 2019 - 05:13 PM

Thank you so much! We recently had an internal audit about BRC and IFS and the auditor did put to mind that as it is not the first time we have an audit for BRC that we start to think about the little details and this came to my mind.

 

The legal side of things is, at face value, a fairly simple case of being obliged to make sure that what you're using is suitable for purpose. I'm not aware of a specific regulation that says "you must have declarations", but without these one would have to wonder how you'd prove the point. Nonetheless I expect it is enforced in proportion to the scale and nature of the business - I'm pretty sure that a lot of smaller food companies and caterers wouldn't have these on file, but I don't recall ever seeing any of them challenged on it.

BRC is a bit more forthright about what it expects, but whether you'll be picked up on it depends on the auditor - there isn't time for them to check everything during each audit, but certainly over the years we've had to provide these for various direct and incidental food-contact materials such as gaskets, seals etc.

If the belts etc are direct food contact, or potentially food contact, then I'd agree with your supervisor that it's sensible to get the statements together for them.







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