BRC/IoP Packaging

British Retail Consortium Global Standard for Food Packaging

Food Safety

Contents

  1. Introduction
  2. Overview
  3. Global adoption
  4. Benefits
  5. Auditing
  6. Choosing a registrar
  7. Route to registration
  8. Costs
  9. Contributing editor

Introduction

The BRC/IOP Global Standard for Packaging & Packaging Materials Issue 4 is the latest in a series of standards published to conform to not only the necessity for consumer safety, but also the importance that packaging of a product plays over and above the traditional features of contain, preserve, protect and inform. The British Retail Consortium in conjunction with the Institute of Packaging published the first Standard in 2001. The objective of that Standard was, for the first time, to provide a common basis for the certification of companies providing packaging for own-branded food products.

Since then the BRC/IOP Standard has evolved from being food-only orientated to now encompassing the much wider area of packaging for consumer products. At each new issue the Standard has attempted to reflect changes in technology, manufacturing practice and consumer needs with the latest edition becoming active on 1 August 2011.

This version of the BRC/IOP Standard has undergone considerable review and a number of the changes introduced reflect the already operational requirements of the Global Standard for Food Safety Issue 5. It is not unreasonable therefore, that the safety parameters for consumer packaging of which the greatest single area is food packaging, reflect the objectives applicable to food safety where tradition has demanded the highest levels of safety and quality be met by those supplying the retail sector.

Internationally recognised and available in many languages this new edition of the BRC/IOP Standard has after much consultation been designed to reflect increased focus on the quality and functional properties  of packaging materials to operate in parallel with the traditional hygienic requirements.

Overview

The British Retail Consortium is the primary trade association representing the interests of United Kingdom retailers.  A natural business interest will be that all products sold by the membership fully comply with current legislation irrespective of where the product was manufactured.

The BRC/IOP Standard applies not only to materials utilised in food packaging and filling operations, materials which are in direct contact with food products even although those very products already have a natural barrier such as boxes to contain eggs or bananas and to other products such as toiletries. The Standard is also intended to apply to consumer-disposable goods which may come into contact with food such as paper plates, disposable cutlery and cling-film, however these latter products and other similarly used products may still be audited against the BRC’s sister standard, the BRC Global Standard for Consumer Products.

Importantly the BRC/IOP Standard also applies to other key areas in the packaging industry such as those involved in the production of packaging materials for conversion or printing, those business supplying packaging materials from stock where additional processing or simply repackaging may have taken place  and the supply of essential materials used in packaging such as coatings and adhesives etc.

The new issue of the BRC/IOP Standard recognises two categories of operation:

High Hygiene Risk: ‘Packaging that comes into direct contact with food products (or other designated hygiene-sensitive products. Primary packaging used for food or other hygiene-sensitive products where there is no absolute barrier in place’.

Low Hygiene Risk: ‘Packaging for consumer products and the secondary and tertiary packaging for all uses’.

The BRC/IOP Standard has six primary operational sections covering:

  1. Senior Management Commitment and Continual Improvement
  2. Hazard and Risk Management Systems
  3. Product Safety and Quality Management Systems
  4. Site Standards
  5. Product and Process Control
  6. Personnel

New to this issue of the BRC/IOP Standard are:

  • A grading system reflecting the number and the severity of non conformances identified during the certification audit process.
  • The introduction of ‘Fundamental’ Clauses to reflect the importance of operations crucial to an effective and safe packaging operation.
  • Any major non-conformance raised against a statement of intent of a Fundamental Clause would not permit certification to take place.

Fundamental Clauses include:

  • Clause 1.2 Senior Management Commitment
  • Clause 2.2 Hazard and Risk Analysis
  • Clause 3.3 Internal Audits
  • Clause 3.9 Traceability
  • Clause 4.9  Housekeeping and Cleaning
  • Clause 5.3 Process Control
  • Clause 6.1 Training and Competency

Is the BRC/IOP Global Standard for Packaging & Packaging Materials Standard relevant to your organization?

As with all BRC operated standards, certification to the Global Packaging Standard brings with it a recognition that the certificated company recognises to its business success, the importance of maintaining sustained high levels of product safety, legality and quality. Formal acceptance of the BRC/IOP Standard through the certification process acknowledges at the most senior level in a company, adoption of the aforementioned commitments.

Global adoption

According to the BRC Global Directory, on 2 May 2011 there were 2,063 companies certificated worldwide to Issue 3 of the Global Standard for Packaging and Packaging Materials. These comprise 20 in glass, 739 in paper, 174 in metal, 1,109 in plastics and 21 in wood and other.

Benefits

  • Existing implementation a Quality Management System such as IS0 9001:2008 may mean that many of the requirements of the Standard are already met.
  • Cost savings can be made through improved efficiency and productivity.
  • Improvements can be developed, resulting in less waste, inappropriate or rejected work and fewer complaints.
  • Certification to the standard provides credibility.
  • Assists Companies choose approved suppliers with confidence.
  • Provides assurance that suppliers are following good manufacturing practice and are meeting their legal requirements.
  • Provision of a single recognised third party audit report saves time money and inconvenience.
  • Provides marketing opportunities through the BRC Global Standards Directory website and use of the BRC logo.

Auditing

A Company will only receive a valid certification to this Standard after it has undergone a satisfactory audit by a certification body of its choice, conditional on that body having been approved by BRC. As the audit process is viewed as a critical process to this scheme, BRC have specified very strict criteria to be met by both the certification body and the auditor. As a minimum the certification body must be accredited to ISO Guide 65/EN45011 by a national accreditation body which is wholly affiliated to the International Accreditation Forum.

Auditors are required to be registered with the BRC and this approval system recognises the auditor’s areas of competency and expertise. Detailed guidance has been given on matters affecting auditor competency including education, training, qualifications and work experience.

Clearly to have credibility, any scheme must have consistency in its application. BRC recognise this need is fundamental to the confidence of users of the Standard and has introduced several monitoring devices such as key performance indicators of approved certification bodies, audit report reviews and audits of both certification bodies and witnessed audits of the actual auditors.

Choosing a registrar

There are over 1,000 certification bodies globally. It is important to select an approved certification body and to ensure they comply with the following criteria:

  • Ensure the company is approved by the BRC
  • Receive quotations from several certification bodies
  • Do not select the cheapest as their auditing or service may not meet expectations
  • Ensure the certification body is recognised by your customers and possesses the relevant sector experience for your industry

Route to registration

There are various phases to certification:

  1. Obtain a copy of the Standard
    • Study the requirements
      This is best done by putting together a team of staff members of the varying disciplines whose activities are covered in the Standard. A team leader with authority should be appointed.

      With your designated team the initial step must be to understand the content of the standard and to obtain an appreciation of the interpretation of the clauses.

    • Identify the appropriate category for certification
      Using the decision tree contained within the standard, determine the applicable packaging category.
    • Determine current level of compliance
      Having gained an appreciation of what will be required to obtain certification it is then possible to assess which requirements may already be fully met as a consequence of other certifications which may be held, or from good manufacturing procedures and documented requirements already in place. This is best done by putting together a team of staff members of the varying disciplines whose activities are covered in the standard. A team leader with authority should be appointed.
    • Identify areas where improvement or new requirements need to be met
      This step will enable concentration to be focused on those areas where the business or its operations do not meet the requirements necessary for certification. A plan can now be developed as to how the gaps can be filled, who is to be responsible, and for the creation of a timescale to complete the necessary work. Effective communication is vital at this stage.
    • Create a history
      Through internal audits against the standard, establish confidence that the business is now in a position to proceed to formal certification.
  2. Initial Assessment conducted
    Some businesses find it helpful to have a pre-assessment audit conducted by a recognised and approved certification body or consultant to assist them identify any areas which may have been overlooked or where the requirements of a clause have not been fully understood. This may be done in the early stages of consideration for certification or at the time when the business is confident that it now meets the necessary requirements.
  3. Choose a certification body
    Having established confidence that the business is capable of meeting the BRC requirements, formally choose a certification body
  4. Initial Audit
    • Fix mutually agreeable dates for the audit
    • Ensure senior management are available
    • Ensure all persons likely to be involved in the audit process have been advised and are comfortable with what may be expected of them
    • Conduct audit
    • Audit findings are presented by the Certification Body in the specified audit format
    • If required, carry out any remedial actions required
    • Certification is approved and entered into the BRC Global Directory
    • The absolute minimum time expected on site, exclusive of report preparation, will be 1.5 days but in many instances, dependant upon factors such as site size, staff, numbers, complexity of operation, number of product lines and translation issues, to name but a few, additional time will be required
  5. Reassessment
    Ongoing certification is conditional on reassessment of the site. Normally, reassessment is provided on an annual basis but if a C-Grade award is given, a six month re-audit period will apply. However, in addition, a second visit will be required to the site within 28 days to confirm that all non-conformances have been fully and satisfactorily resolved.

    In the event of a D-Grade being awarded certification will not be granted and a full re-audit will be required.

Costs

The answer depends on a number of factors. There are costs to both implement and to maintain your certification.

Implementation Costs

In terms of costs to implement, if you choose a full do-it-yourself approach, the only real costs will be the time for resources dedicated to the implementation process and in time spent writing documents and training your staff. There are many advantages to the do-it-yourself approach in that the system is fully owned by those writing it and should be fully reflective of site operations. If you have little experience with the standard or have limited internal resources, you might choose to get some outside professional help through a consultant who is familiar with the requirements of the standard. There are also advantages to be gained by the use of a consultant who can often take on the role of facilitator and driver, to ensure projected timescales are met.

Certification Costs

Costs of registration are dependent on the size of your organization. Most registrars charge a certain rate per day to be on-site at your facility. This day rate will vary depending on your country. Typically, two days in the United Kingdom will cost circa £2,000 to £2,500. As with all commercial operations this price may be slightly less or greater depending upon the pricing structure of the chosen certification body and for any additional days required for the reasons outlined above. The certification body fee normally includes the annual fee payable to the BRC.

Other fees will include travel and accommodation expenses for the auditor, if travelling a fair distance to the site.

To maintain your certification, the Registrar must return annually to audit a portion of your system. These costs will be less than the original visit, since the time spent on it will be shorter. Once every three years, the Registrar returns to audit your entire system.

Contributing editor

John Hutchison

John Hutchison obtained a degree in Environmental Health from the University of Strathclyde in 1976 before commencing his career in local government, the latter years being spent as a specialist food safety officer.

John then joined the public sector where he was employed for another thirteen years with a major international pest control company. His brief was to provide environmental pest control services and technical support to the food industry, as demands for safer pest control were being made by the major food retailers and their suppliers.  Leaving a senior management position, he broke away to setup his own company, Hutchison Associates, in the food safety industry.

Hutchison Associates specialise in the provision of high quality food safety training, inspection and consultancy operations to the food sector and have worked internationally. As a British Retail Consortium approved evaluator, John regularly inspects food manufacturing and packaging manufacturers.

On the educational front John held the position as Honorary Senior Lecturer at University Strathclyde and has lectured at the University of Edinburgh and Glasgow College of Food Technology. He has had several articles on HACCP related subjects published in the journal ‘Food Hygiene International’.

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