Published for the first time in 2001, the British Retail Consortium (BRC) brought together industry experts from The Institute of Packaging, certification bodies and retailers to develop a standard that encapsulated the due diligence approach to hygiene and technical controls in the manufacture of food packaging. Subsequent issues have refined and built upon the original standard and widened the scope to include quality and non-food packaging. This latest, Issue 4, provided the opportunity to look again at the relevance of the Standard to emerging issues and provide a greater emphasis on packaging quality control and functional properties, which are of particular concern to buyers.
Each revision of the standard begins with the objective to produce a dynamic document able to facilitate improvements in hygiene and consistency while ensuring customers retain confidence in standards of product safety, quality and legality. The risk based approach of the standard ensures that it is applicable to large scale production and smaller firms, and can be applied in the different packaging sectors.
Retailers and manufacturers are well used to the benefits that a single, testing, broad-based, annual audit can bring. Instead of multiple audits carried out by individual customers, access to the BRC audit report can satisfy several parties and verify that the ongoing surveillance requirements facilitate the packaging supplier’s continual improvement.
Auditors have to meet exacting requirements for training and must demonstrate expertise in any packaging fields in which they may audit, to ensure that the audit and reports are relevant.
It is the use of industry experts that ensures the standard is as relevant to the unique challenges of packaging as possible. The multi-stakeholder technical advisory committee includes people from The Packaging Society, audit bodies, manufacturers, retailers and trade bodies in a lively and open discussion forum. Consultation, particularly for Issue 4, has recognised the increasing global interest and the consultation process has engaged ideas from growth regions of the world to formulate the standard.
Issue 4 will revert back from three to two different product categories, each with their own set of requirements reflecting the hygiene risks associated with the particular packaging usage. The categories broadly divide between packaging for food use and packaging for non-food use.
The standard’s requirements have been critically reviewed to ensure that new and emerging issues are effectively addressed, and this has included:
¦ Greater emphasis on managing the functional quality of packaging materials and meeting customer specifications;
¦ Packaging print control – to reduce the risk of mistakes in printing or mixing of print jobs creating issues for users;
¦ Mitigating the risks of chemical migration from packaging materials into food products – covering raw material origin and composition and guidance on intended use; and
¦ Requirements where recycled materials are used.
Systems that are crucial to the establishment and operation of an effective packaging manufacturing operation have been elevated to ‘fundamental’ clauses, in line with the Food Safety and Consumer Products Standards. Failure to meet these fundamental clauses will lead to noncertification and the need for a further audit. Fundamental requirements should be substantially in place and demonstrably working at the time of the audit visit, and cannot be corrected afterwards without the need for a complete re-audit. At the heart of the Fundamental clauses is the necessity of ‘senior management commitment’, first emphasised in Issue 3, along with systems requirements for hazard and risk analysis and internal auditing, and systems such as cleaning and process control.
A grading system is also to be incorporated into the Packaging Standard to bring this in line with other BRC standards. The new grading system is to indicate to the user of the report the commitment of the company to continual compliance and will dictate the future audit frequency. Sites with fewer than 20 minor non-conformities or a single major non-conformity will remain on a 12-month cycle, whereas those with a greater number will see audits increase to a six-monthly cycle. For the first time, those sites with either a critical non-conformity or higher levels of major and minor non-conformities, will not be awarded certification and will also require a re-audit to remain in the scheme. Benefits to packaging buyers and retailers of the scheme are clear: a single, broad-based audit, implemented globally in every sector of the packaging industry and rooted in food and non-food sectors.
Joanna Griffiths Joanna Griffiths
