What does BRCGS consider as sharps and metals?

Hi, I am working on implementing a proper blade control and monitoring system. We make food contact plastic packaging, and knives are used in production, warehouse, and maintenance areas for various tasks. I am prepared to control and monitor them, but what else?

My main question is this: What is considered a sharp implement? Scissors? Plyers? Saws? We have a maintenance room full of various tools. Will I need to go and dig through them all, confiscate all of the ones that could cut someone, assign them each an ID, and have them signed out each day? Is a screwdriver a sharp? The standard called it "sharps and metal control" but does it really just means sharp metals?

I guess I am wondering how far I really need to go with this. 

I don't have access to BRCGS standard since it is copyrighted and behind a paywall, so I can't review it with you or cite sources.

In my (different) audit standard, sharps and metals are aimed at preventing contamination of the product.

So, a knife used to cut rolls of plastic film would need to be controlled, just like you said.

This knife touches packaging and has a chance to introduce foreign material (blade chips, handle fragments, etc.)

These will need to be checked at a higher frequency since they're used every day. Maybe make it a part of daily GMP checks.

I imagine they use "sharps and metals" to describe knives and utensils that are used often and in direct contact with packaging.

However, a screwdriver or tool used inside a maintenance room away from production is much lower risk.

I think the easiest way to cover all your bases would be completing a separate checklist at a defined frequency. (monthly?)

You could fill it with all the utensils that aren't used often.

Then if you're ever asked, you will have records EVERYTHING is being checked and potential issues will be corrected.

Example:

Clean, in good repair, no missing/chipped pieces, proper storage?

Knives:                             YES, all knives checked, no issues found

Maintenance Tools:         YES, all tools checked, no issues found

Scrapers:                          YES, all scrapers checked, no issues found

Box Cutters:                     YES, all box cutters checked, no issues found

Were any damaged, soiled, or improperly stored metals/sharps found during inspection?

NO, all metals and sharps were clean, undamaged, and properly stored.

Corrective Action

No corrective actions required.

Date:                                   1.08.2025

Employee:                           AltonBrownFanClub

Packaging facilities get away with a bit more than I'm used to, but my attitude would be that any cutting tools used by your production employees need to be registered and checked in/out with each shift.  The check in/out should detail inspections prior to use with a cleaning and inspection documented when it is returned.  The GFSI codes are really looking to actively control tools that are used during production and pose a hazard.

Where maintenance has additional tools that can cut, their tools should NOT be permitted for use in your production activities.  You can write into your procedures that maintenance's tools are only to be used by maintenance personnel and are prohibited for use in production to cover your bases there.  There should be SOP on how often maintenance guys wash and sanitize their tools before coming out to perform tasks, and clear instructions about how maintenance activities require recleaning of your equipment, but I think it's defendable that maintenance tools are accounted for by the tech during their activities and are separate from production cutting implements.

Hi WorkingFromWork,

Sharps include knives, blades, needles and wires.

I am working on updating the IFSQN BRCGS Packaging Safety and Quality Management System - Issue 6 Implementation Package to Issue 7 and I have some bad news for you.

Requirements for sharps and metal control previously focussed on production/manufacturing but have been extended and Issue 7 specifically includes issue and control in engineering workshops and laboratories

BRCGS Global Standard for Packaging Materials Issue 7 Clause 4.9.2.1 Changes:

There shall be a documented policy procedure for the controlled use and storage of sharp implements, including knives, blades, needles and wires, to prevent product contamination.

The policy shall include control of these items into and out of the site.

The procedure shall include:

• issue and control of sharp implements in the manufacturing, storage and ancillary areas, such as engineering workshops and laboratories

• record of replacement or breakage.

Snap-off blade knives shall not be used. (Moved from clause 4.9.2.3 to 4.9.2.1)

I’m of the view that the focus should still be production/manufacturing areas but there needs to be some level of control in workshops, for example training of staff, logs of sharp implements, reporting of breakage/loss and confirmation of any sharp implements that must stay in the workshop.

Note that certification against Issue 7 will commence from 28 April 2025

Kind regards,

Tony

I think there has to be a level of pragmatism in it all.  So as ever with BRCGS, personally and in the behaviour of auditors I've seen, if you do something sensible, it's generally accepted.

So I'd definitely have an issuing process for those used in your main production area.  But also what I'd do is write a risk assessment on all of your sharps and metal potential risks then how you control them.  What you'll probably already find is that some are only used in the workshop and that workshop probably has restricted access (or should anyway).  So that could be recorded (make sure it's also in a procedure somewhere which is trained out too even if it is already your custom and practice).  For other engineer items, you may have some which are taken into production areas.  But when doing so they are in tool boxes which are locked when the engineer is not using them. (Again, procedure all the way.)

So if you have all that, then you don't really have a risk, you don't have to number and issue saws and engineers tools in the same way as you would for the production knives as long as you comply.  Might be worth explaining that to the engineers though that you're trying to make their lives easier by doing that as you train out any procedures.

Hi WorkingFromWork,

 

Sharps include knives, blades, needles and wires.

 

I am working on updating the IFSQN BRCGS Packaging Safety and Quality Management System - Issue 6 Implementation Package to Issue 7 and I have some bad news for you.

 

Requirements for sharps and metal control previously focussed on production/manufacturing but have been extended and Issue 7 specifically includes issue and control in engineering workshops and laboratories

 

BRCGS Global Standard for Packaging Materials Issue 7 Clause 4.9.2.1 Changes:

There shall be a documented policy procedure for the controlled use and storage of sharp implements, including knives, blades, needles and wires, to prevent product contamination.

The policy shall include control of these items into and out of the site.

The procedure shall include:

• issue and control of sharp implements in the manufacturing, storage and ancillary areas, such as engineering workshops and laboratories

• record of replacement or breakage.

Snap-off blade knives shall not be used. (Moved from clause 4.9.2.3 to 4.9.2.1)

 

I’m of the view that the focus should still be production/manufacturing areas but there needs to be some level of control in workshops, for example training of staff, logs of sharp implements, reporting of breakage/loss and confirmation of any sharp implements that must stay in the workshop.

 

Note that certification against Issue 7 will commence from 28 April 2025

 

Kind regards,

 

Tony

Hi Tony,

If all of the metal implements in the maintenance area are locked up when not in use, and the ones that are used in production are controlled with monitoring, does that work? 

For example, we lock the toolbox with all the various metal tools in the maintenance room. The worker has a cart with specific tools that he takes into production to work on a machine. Those tools on the cart are the only ones allowed to be brought out, and they are kept clean and checked for damage daily. Would this work?

Thanks

Hi Tony,

 

If all of the metal implements in the maintenance area are locked up when not in use, and the ones that are used in production are controlled with monitoring, does that work? 

 

For example, we lock the toolbox with all the various metal tools in the maintenance room. The worker has a cart with specific tools that he takes into production to work on a machine. Those tools on the cart are the only ones allowed to be brought out, and they are kept clean and checked for damage daily. Would this work?

 

Thanks

Hi WorkingFromWork,

I think that is workable as long as you have it documented and trained in your procedures.

I would like to see a log of the locked up maintenance items and that they are checked on a regular basis such as weekly. 

Also that the tools taken into production on the cart are controlled (logged and checked) and the cart is locked when not attended by your maintenance guy.

GMO has also mentioned a risk assessment which isn’t a bad idea as BRCGS just love risk assessments  ;)

Kind regards,

Tony