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

MDaleDDF:

What/how did you tether the pens

Metal leashes, like they have at the bank or whatever.    They're stuck to our clipboards, also all metal.

We actually stopped doing it though and just took pens out of the production room since they rarely used them anyway...  Knives are still leashed up tho.

We never included it in the plastic checks.  Some which have a plastic "clip" are breakable but due to the plastic being detectable (and us validating that) we risk assessed it was unnecessary.

I always find it fascinating that it's dictated when so many other things which are loose items aren't.  And the BRCGS auditors who let teams get away with any old crap in tool boxes (they shouldn't but I've never seen an auditor push this anywhere near as much as I have.)

Just be aware that metal detectable doesn't always mean x-ray visible.  That sometimes catches people out.  

Hi Everyone,

You might find it interesting that BRCGS Global Standard for Packaging Materials Issue 7 does not refer to pens, detectable or not. Pens have not been referred to in the standard for a long, long time.

Anyway, as an example clause 4.9.5.4 of Issue 7 states:

Site issued portable handheld equipment, e.g., mobile phones, tablets, measuring equipment and similar portable items, shall be controlled by the site to minimise the risk of physical contamination.

Whereas the BRCGS Global Standard for Food Safety Issue 9 clause 4.9.6.2 states:

Portable handheld equipment, e.g. stationery items (pens, pencils etc.), mobile phones, tablets and similar portable items used in open product areas, shall be controlled by the site to minimise the risk of physical contamination.

It also gives examples of control measures including: pens are designed without small external parts and are detectable by foreign-body detection equipment

Also note it is not compulsory for Food Manufacturers to have detectable pens provided you can demonstrate control - BRCGS Global Standard for Food Safety Issue 9 clause 4.9.6.2 guidance states:

The Standard is not prescriptive in the control mechanisms used. For example, it is common for pens used in production areas to be metal detectable; however, other controls may be more suitable in certain circumstances. Therefore metal detection is provided as an example of a common control. Nor does the Standard require pens to be of a specific design, or state that most pens available on the market are not compliant. The Standard does not require the site to test every batch of pens through its metal detector. It does, however, require sites to consider the design of pens and portable items being used, to ensure that potential food safety hazards have been considered and are managed appropriately.

Personally, I have always used detectable pens that are robust and not brittle like the example I posted previously and that is how I think most people control the risk of product contamination. As they aren’t brittle, they don’t need to be on a register for brittle materials as per the question in the OP.

From experience, one of the main reason pens are chained up is because they tend to go walkabout on a regular basis but obviously it also makes it more difficult for them to end up in a product.

Kind regards,

Tony