BRC Packaging Issue 5: An Overview of the Main Changes

On July 1st 2015, the British Retail Consortium published the latest issue of its Global Standard for Packaging and Packaging Materials. The standard, which has been updated to reflect the changing requirements and expectations of the various stakeholders, will be valid from January 1st, 2016 onwards. To help you prepare for certification, we have compiled an overview of the main changes in Issue 5.

• Structure & Fundamentals

Like before, the BRC Packaging Standard distinguishes two main categories, with separate requirements. Whether a product falls in one category or the other depends on the intended use of the product. To reflect the fact that the intended use rather than the level of risk is the determining factor, the names of these categories have been changed: “high hygiene risk” is now called “high hygiene”, “low hygiene risk” becomes the category “basic hygiene”. High Hygiene relates to those items that are intended to come into direct contact with food or other hygiene sensitive product, while Basic Hygiene is intended for all other items, such as labels applied to other packaging materials through to the manufacture of tertiary (transit) packaging.

Except for changes in the numbering, the eight so called Fundamentals remain unchanged.

• Changes per Chapter

1. Senior management commitment and continuous improvement: There are few changes in this section, except for some minor clarifications and changes to the order of appearance.
2. Hazard and risk management system: Here too the changes are minor. In clause 2.2 the concept of quality has been added. This means that quality is a factor to consider during risk and hazard analysis and that it is acceptable to manage quality hazards through prerequisite programmes.
   Another addition is the inclusion of the risk of migration as a potential hazard in the manufacture and storage of packaging materials, as well as potential for malicious intervention, reflecting more current potential issues in the manufacture and use of packaging materials.
3. Product safety and quality management system: The order of the clauses has been changed to reflect the logical order of the processes. In addition, a new clause has been added to manage suppliers of services. Management of subcontracting of production (3.5) was always part of Issue 4, but this addition ensures that both aspects of supply into the site are adequately controlled.
4. Site Standards: A couple of clauses have been added relating to pest control. Sites that manage their own pest control program need to have appropriate measures in place to ensure its effectiveness. All pest control equipment is required to be function. All employees should be able to recognize and report any signs of pest activity.
   Here too there have been minor changes to the order of the clauses. Staff facilities have been incorporated into section 6 (6.3) as it relates to personnel, and housekeeping and cleaning has moved from 4.9 to 4.8. Meanwhile, product contamination control (glass and brittle plastics, sharps and chemical and biological controls) are now in 4.9.
5. Product and Process Control: Two new clauses catch the eye here: 5.2 Graphic design and artwork control, and 5.8 Incoming Goods.
   Graphic design has been added so that sites conducting any pre-print artwork-related activities are responsible for the artwork and have systems in place to maintain the integrity of the images. This is in addition to packaging print controls which are concerned with the printing process.
   Incoming goods is a small clause but partly formed by an existing close from Issue 4’s Transport, Storage and Distribution section, which has been extensively reviewed and amended for Issue 5.
   Storage of all materials and intermediate and finished products (now 5.9) and dispatch and transport (now 5.10) replace Issue 4’s transport storage and distribution to give adequate emphasis to the roles those two functions plays in maintaining product integrity. There is no overlap with the Storage and Distribution Standard as the requirements relate only to what occurs on the site.
   The requirements for in-line testing and measuring equipment have been moved and now form part of product inspection, testing and measuring; 5.6; and control of the equipment used for this is under the revised calibration and control of measuring and monitoring devices, 5.5.
6. Personnel: As indicated above, the clause on Staff facilities has moved from chapter 4, and access and movement of personnel has joined with layout and product flow in section 4 (now 4.5).

• Evaluation System

An excellence level has been introduced to foster continuous improvement. The new classification “AA” is geared towards sites that have already reached the Grade A. Sites with less than 5 minor non-conformities can achieve the excellence level. The maximum possible number of minors of the previous category A remains unchanged.

• Unannounced Audits & Additional Modules

The audit protocol now provides the opportunity to conduct unannounced audits. This is entirely optional. There is also the option to include additional modules in the audit. At the moment, there are two optional modules available: Traded Goods (also known as factored goods) and the Environmental Awareness Module (EAM).

• Time Plan

After the publication of the new BRC Packaging Standard on July 1st, 2015, there is a transition period of six months. The use of Issue 5 is compulsory for all certification audits taking place from January 1st, 2016 onwards. Prior to that date, it is not possible to be certified according to the new version.