BRCGS 4.9.1.2 - Control of detectable pens
Good afternoon,
In our company we use detectable pens. Is it necessary to include them in the control of plastics according to point 4.9.1.2. of the BRC packaging&packaging regulation?
We have been doing it until now but we consider that it would not be necessary since in case of breakage or loss it would be detected if problems.
Thank you for your comments
Greetings Ana,
Mentioning them in the list with breakable items is necessary, since they are a possible danger no matter that they are detectable. Having them checked is the fail-safe for the possibility of detection error. Such error though low can occur and examples are malfunction of the X-ray (if you have one) or the material of the pen in terms of detectability.
What you can do is maybe lower the frequency of the checks since you have other measures also in place (maybe once before the start of the shift and once at the "middle" or middle and end if the products are shipped on the same day of the production).
Regards!
We have never included the metal detectable pens in our registry (we're SQF, I don't know the specific wording of BRC 4.9.1.2).
We do validate any new pen design/supplier detectability by breaking samples down and running them through detectors, and require them to be tethered. None of our auditors or inspectors has challenged this approach.
We tether ours as well, along with knives. Inspectors have never questioned it, no registry.
Took me awhile to remember what I did about pens last time it came up for me. We ended up labeling a number of metal clipboards and using those bank style pens with sticky bases and chains to keep them attached to clipboards. Clipboards were checked at end of shift, operators had to report if a chain broke or any part of the pen was chipped. The pens weren't sold as "metal detectable", so I did a test on my own that the pens indeed would trip every detector in our plant. This appeased a couple years' worth of SQF auditors while I was at that plant.
I don't know about including them on a register, since that seems like you'd have to have a controlled number of them at any given time and maybe even uniquely identified (Pen 1, Pen 2, etc).
Good afternoon,
In our company we use detectable pens. Is it necessary to include them in the control of plastics according to point 4.9.1.2. of the BRC packaging&packaging regulation?
We have been doing it until now but we consider that it would not be necessary since in case of breakage or loss it would be detected if problems.
Thank you for your comments
Hi Ana_B,
Your detectable pens should not be brittle plastic and hence no need to go on a register. Staff should be trained to report breakages or loss but to be honest it was very very difficult to accidentally break the detectable pens that I have bought previously. See example below.
Detectable HD Retractable Pens - Standard Ink (Pack of 50)
Made from Detectamet’s unique detectable polymer, the rugged construction makes it resilient, so it won’t break under stress, whilst the ergonomic grip allows a firm hold in a wide range of environments.
Kind regards,
Tony