Deodorant Aerosol Valves - high or low risk?

Hi everybody

New to BRC so I need some advice. I run a new production line making aerosol valves for deodorant aerosols. I had a first audit 2 months ago biased on low risk as my sister company had passed BRC at this level 1 year ago. This is a state of the art production facility and has been running for 4 months. On the audit introductions the auditor stated that we were high risk. I tried to put my point over to the auditor that how could I be high risk when our sister company was low risk. We make the valve that is fitted to the top on the can and sprays the deodorant to peoples under arms so no contact with the skin, This valve sits in alcohol so any bacteria is killed off. I have decided to set the risk assessments as high risk and risk assess back down to low risk. I have completed a bioburden  test on raw material and finished valve and had very low readings. My  question is how can my process be "HIGH RISK"?

What standard is this...BRC Packaging or Consumer Products?

Hi Simon

Its BRC Packaging

In the BRC/IOP standard there is a decision tree on page 11 for determining if you are low or high risk.

Under high risk it states “packaging that comes into direct contact with food products or other designated hygiene-sensitive products*

*Those products intended for human consumption or which come into contact with the body, such as application to the skin.

Based on this your product “aerosol valves” comes into contact with a hygiene-sensitive product “deodorant” that is applied to the skin.  Therefore you are high risk.

For me personally a deodorant aerosol valve would be low risk, however,  according to the BRC/IOP decision tree it is high risk.

If your customers are happy with low level hygiene requirements and certification you can appeal directly to the BRC for a final decision.