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Direct vs Indirect food contact packaging


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bradkephart

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Posted 17 February 2021 - 10:20 PM

Last certification audit we changed our scope from direct and in-direct food contact packaging as we have never had any direct food contact business. Our current scope only includes in-direct food contact packaging (certified to Issue 6 of BRCGS Packaging Materials). We have a potential customer that wants direct food contact - would we be able to produce the order under our current certification? Or would we need to complete another certification audit and change our scope prior to running the order?



beautiophile

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Posted 18 February 2021 - 01:38 AM

Our customers accepted our products before we got the first BRC audit. A certification makes the approval easier but it's not vital.

I think you can invite them to a site tour and introduce your hygiene & safety control system which is already suitable. And don't forget to tell them your plan to re-upgrade to the food-direct category in the following certification renewal. That'd have them feel more confident.



SQFconsultant

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Posted 18 February 2021 - 02:19 AM

Contact your CB, change or modify the scope and make needed changes to docs, you do not need a brand new certification.


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Foodworker

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Posted 18 February 2021 - 10:34 AM

You can certainly produce the order if your customer is prepared to accept it, but if your scope is for non direct contact, the direct contact products will not be covered by the certificate.

 

If it is likely to be more than a one off piece of business, you will need to have the scope modified as there are rules about what can or can't be excluded from a BRC scope.

 

This will have to be through your CB who may insist on another partial extension to scope audit, depending upon what they looked at in the last audit. For instance on the simplest level, would your staff have been following hygiene rules applicable to direct contact during the audit? Also would your hazard analysis have looked at direct contact at the time of the last audit.

 

Chopping and changing scopes on a regular basis is generally frowned upon as it doesn't demonstrate clear commitment to the principles of the BRC Standard

 

CBs are commercial organisations and would be very likely to want a re-audit so that they can charge you for the privilege.






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