This thread is scrambled from diverse inputs/different related clauses, ie 4.8.5 (environmental related), 4.3.2 (non-environmental related), x.x (unknown)
Few Comments -
Post 5 - air can be tested. various threads here detail such.
Post 6 - BRC Packaging Standard's scope includes Cosmetics et alia
Post 8 - Change yr intended auditor if they cannot accept BRC's own publications. Previous threads here validate the quotation's auditorial applicability for Food Packaging.
Post 9 - IIRC, an earlier thread here demonstrated that the effective survival time for Covid-19 on specified packaging was very short.
To recap p558 -
Most packaging materials are unsuitable for the survival and growth of pathogens and therefore will not require an environmental monitoring programme to be in place.
Regrettably, afaik, BRC did not elaborate on "most" however previous reported experiences here suggest that for specified Food Packaging a program based on Enterobacteriaceae / Y&M may be acceptable to BRC if a "low risk" scenario can be presented/justified.