Is Primary Packaging Storage an Enclosed Product Area Under BRCGS Issue 9?
Can we consider, the primary packaging storage area as a enclosed product area, according to BRCGS issue 9 ?
Thank you in advance
Can we consider, the primary packaging storage area as a enclosed product area, according to BRCGS issue 9 ?
Thank you in advance
Is this storage of the packaging before it is filled, or sealed finished goods?
Is this storage of the packaging before it is filled, or sealed finished goods?
This storage is for primary packing materials only, not finished goods. BRC Issue 9 states that raw material storage should also be considered an enclosed product area. Since the primary packing material directly contacts the food, I consider this as important as raw material.
Am I right?
Hi NipunRRSL,
Warehouses are generally regarded as Enclosed Product Areas and the expectation is that there is a dedicated packaging store or a dedicated area of a raw material store.
I wouldn’t get to hung up on this if your packaging is adequately protected in storage. Zoning is predominantly in consideration of risk to product not packaging. Requirements for packaging storage are prescribed in BRCGS Global Standard for Food Safety Issue 9 Clause 4.15.2 which covers storage of packaging:
Where appropriate, packaging shall be stored away from other raw materials and finished product. Any part-used packaging materials suitable for use shall be effectively protected from contamination and clearly identified to maintain traceability before being returned to an appropriate storage area.
Production Risk Zones are laid out in details in BRCGS Global Standard for Food Safety Issue 9 Appendix 2 but the focus of this appendix is to identify product and non-product zones as per the quoted sections below:
The Standard identifies a number of different production risk zones within the processing and storage facilities which require corresponding levels of hygiene and segregation to reduce the potential for product contamination with pathogenic micro-organisms.
These production risk zones or areas are classified as:
Open product areas, consisting of:
• high risk (chilled and frozen)
• high care (chilled and frozen)
• ambient high care
• low risk
Enclosed product areas (e.g. warehouses and storerooms)
Non-product areas (e.g. canteens, laundries and offices).
Note that BRCGS focuses on product, not packaging, when defining Enclosed product areas:
An enclosed product area is defined as an area of the factory where all of the products are fully enclosed and therefore not vulnerable to environmental contamination (e.g. foreign bodies or micro-organisms). This includes areas where:
• the product is fully enclosed within packaging (e.g. raw material and finished product storage and dispatch areas)
• the product is fully enclosed within equipment shielding the product from physical or microbiological contamination from the production equipment during production – this may include enclosure within transfer pipework and fully enclosed equipment, and also where the equipment maintains its own environment to protect the product (e.g. aseptic filling equipment).
Kind regards,
Tony