Sixth sense: a time to act

The recent update to the BRCGS Global Standard for Packaging and Packaging Materials has put the safety and quality of packaging materials – and the process of manufacturing them – firmly back on the agenda. Joy Franks, food market director at testing, inspection and certification specialist Bureau Veritas, examines what has changed and what it means for the industry

AMONGST the myriad of legislation and safety standards affecting food processing and production, it is vital not to ignore the safety and quality of packaging production. The manufacture, printing and production of raw materials for packaging often involves potential harmful materials and processes, from inks and coatings which have the potential to ‘migrate’ onto food, to the handling of process waste including pellets, powder and flakes. Standards for packaging and its manufacture are set out in the BRCGS Global Standard for Packaging and Packaging Materials, which focuses on all aspects of safety and quality, covering a wide range of issues including hazard control, factory environment, process control and quality management system.

The Global Standard for Packaging and Packaging Materials covers everything from food to consumer products, but as the first packaging standard in the world to be recognised by the Global Food Safety Initiative (GSFI) benchmarking committee, it is widely accepted as a benchmark for compliance in the UK food industry. In fact, many UK retailers require certification as a pre-requisite from their suppliers, whilst it is also recognised by brand owners, foodservice companies and manufacturers around the world when assessing the capabilities of their suppliers. It now provides a robust framework for all types of packaging manufacturers to assist them in the production of safe packaging materials and to manage product quality to meet customers’ requirements, whilst maintaining legal compliance.

Understanding Issue 6

More than 3,500 companies in over 80 countries are certified to the Global Standard for Packaging and Packaging Materials, which like all similar standards is regularly updated in line with developments to maintain safety, quality and operational criteria. In August 2019, Issue 6 was published, marking the first major update in four years and a further evolution in requirements of certified organisations. Recognising the importance of quality management systems and consistent audits, the new Issue 6 places greater emphasis on senior management commitment and reinforces the importance of a hazard analysis and risk assessment-based product safety programme. Its objective, to quote the BRCGS itself, is to ‘direct the focus of the audit towards the implementation of good manufacturing practices within a product safety and quality culture of continual improvement, while recognising the diversity and breadth of the packaging industry, and the skills required to audit it.’ With this in mind, let’s examine the specific areas of change since Issue 5. 

Enhancing the processes used by quality management systems in printed packaging controls and through a hazard and risk analysis approach

Issue 6 reinforces the need for a Hazard and Risk Analysis (HARA) – including through an accompanying checklist – but for the first time, it separates hazards into product safety and quality defects. This provides greater clarity and will help to improve control measures necessary to prevent, eliminate or reduce each product quality hazard to acceptable levels. 

Ensuring consistency of the audit process across the world

The role of accredited certification bodies and audit training providers such as Bureau Veritas remains critical as supplier approval is required via a benchmarked audit or site audit by a 2nd or 1st party audit. Low risk suppliers could still be approved by a questionnaire, as long as supplier traceability systems are tested initially and then every three years.

Importance of a product safety and quality culture in the drive to improve transparency and coherence across the food supply chain

In another new clause introduced in Issue 6 (1.1.2), organisations are reminded of the importance of driving a culture of safety and quality. This clause requires sites to set up, execute and review an action plan to improve product safety and quality culture. Auditors are not required to specifically assess the culture of the given organisation, but he/she must examine the efforts made to document the status of the organisational culture and the steps that are put in place to improve it.

Simplifying the hygiene requirements based solely on risk

Issue 5 used a two-tiered approach to hygiene – high hygiene and basic hygiene – but after consultation with the industry this has now been simplified and replaced by one, risk-based approach. This simplification will also help to ensure clauses are applied appropriately in former basic hygiene sites. 

Introducing a new fundamental clause, corrective and preventive actions, to address issues and minimise the risk of their occurring

Fundamental clauses are those which must be implemented otherwise the site cannot be certified. A new fundamental clause in Issue 6 requires the integration of root cause analysis with a structured continuous improvement approach to minimise the risk of issues reoccurring – Corrective and Preventive Action (CAPA). This is in line with Issue 8 of the BRCGS Food Safety Standard.

Based on risk, putting a microbiological environmental monitoring programme in place

Another change in line with the latest update to the Food Safety Standard and to incorporate BRC Packaging issue 5 position statement P558, the new environmental monitoring clause (4.8.5) applies to all production areas. It is designed to make sure that the production environment is fit for production and doesn’t pose a risk of contamination to the product. 

A risk assessment must first determine what testing is required, before the necessary control limits are applied with pre-defined corrective actions. Inevitably, ongoing monitoring and review is necessary. 

Simplifying the unannounced audit programme

Issue 5 of global standard offered three audit options; a full announced audit, full unannounced audit, and split unannounced audit. The latter of these options divided the audit requirements into two separate audits, the first one unannounced and the second one announced. In reality, the full unannounced audit option is generally the preferred because it gives extra confidence to specifiers and so Issue 6 has removed the split unannounced audit option (in line with Issue 8 of the Food Safety Standard). Unannounced audits remain optional.

Time to act

Issue 6 has now been published and it is a welcome step forward in the evolution of safety, quality and operational criteria throughout the packaging production chain. However, these new auditing requirements will of course require some changes. Audits and certification to Issue 6 will start in February 2020 so organisations must act now to make sure they are fully prepared.