AWARENESS TRAINING PROGRAMME

Technical Standard for Companies Manufacturing and Supplying Food Packaging Materials for Retailer Branded Products
presented by

David Burns
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INTRODUCTION
BRC / IOP Technical Standard for Companies Manufacturing and Supplying Food Packaging Materials for Retailer Branded Products

Development of the Standard

This standard hails as a first for the packaging industry It provides common ground on auditing It underpins due diligence to users. It brings quality and hygiene standards, and many manufacturers to new heights. It means a single audit for packaging manufacturers

Development of the Standard

The BRC / IOP Technical Standard was bench-marked to several existing standards during writing It covers all packaging industry types, not just one, as are many codes of practices that are issued by trade associations The BRC/IOP Standard encompasses all problem areas within packaging production.
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Development of the Standard

It is hoped that the Standard will cascade through the packaging industry Retailers will require their packer fillers to ensure all of their packaging manufacturers are accredited The Standard requires them to ensure their suppliers are up to an adequate standard The best way to achieve this is by accredited certification
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Development of the Standard

The cascade effect will ensure all packaging manufacturers, converters and suppliers have the same standard. Transparency of auditing will ensure companies will not be commercially disadvantaged by non compliant companies.

Development of the Standard

The new Standard is designed to be dynamic Regular Standard updates will be carried out A Standard review body will sit every six months and look at problems that have arisen

Background Information

Following the Food Hygiene Standard, it was agreed that the Packaging Standard had to be credible It should be backed by the EN45011 standard All standard audit bodies must be accredited under the EN 45011 standard requirements Each evaluator will have to prove competence by examination in both hygiene and packaging.
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UKAS Accreditation

Standard Integrity

Only bodies that are accredited to the EN45011 standard will be allowed to carry out audits Audit bodies will not be allowed to carry out both consultations and audits Individual Inspectors will need to have specific qualifications based on packaging, hygiene and audit management

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Why have a common Standard ?

Provides a level playing field Being able to demonstrate Due Diligence A single audit, one certificate that will be acceptable by all interested parties Reduction in cost, speed up of auditing

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What are the objectives ?

To ensure all food packaging manufacturers are satisfactory in both hygiene and technical matters To ensure all packaging users are able to trust their packaging materials to be hygienic and consistent

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What are the objectives ?

The Standard is based on both pre-requisites and risk assessment The Standard is prescriptive in many areas Control of hygiene in every aspect of a production unit Ensures consistent adherence to a specification Covers high and low risk areas Defines high and low risk

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Who Were Involved ?

Institutions
United Kingdom Accreditation Service (UKAS) The Institute of Packaging (IOP) The British Retail Consortium (BRC)

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Who Were Involved ?

Others
The Standard has not been written by the retailers and then imposed on the packaging industry. The committee was made up from the following: Audit bodies, Institute of Packaging, Academia, Manufacturing Trade Bodies, Packaging Manufacturers, Food Manufacturers (Packer Fillers) and Retailers

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Benefits of the Standard

Accepted Standard based on best practise Certification bodies accredited to EN45011 to achieve maximum consistency in application and interpretation Open and transparent Encourages continuous improvement Cost effective, removes need for multiple customer inspections
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Benefits of the Standard

Removes burden of routine visits Broad based standard, including; quality, hygiene, and safety The standard addresses due diligence Requirement for on-going surveillance Focusing on process improvement

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Benefits of the Standard

The Standard covers issues that are also covered within an ISO9000 standard. Provided your ISO9000 certification can be shown to be acceptable to the assessor much of the Packaging Technical Standard may be covered.

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What does the Standard cover ?

Management Responsibilities Risk Assessment Documentation Requirements Factory Standards

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What does the Standard cover ?

Quality Assurance/ Process Control Contamination Control Personal Hygiene Glossary of Terms
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What does the Standard protocol cover ?

Audit Body Requirements Frequency of Evaluation and follow up. Evaluation Reporting. Certification. Competency of Inspectors. Standard and Protocol development. The Auditors Report

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BRC - STANDARD CONTENTS

1. Scope 2. Organisation 3. Hazard and Risk Management System 4. Technical Management System 5. Factory Standards 6. Contamination Control 7. Personnel 8. Risk Category Determination
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BRC - TECHNICAL STANDARD

The BRC Standard is divided into two levels, in consideration of the product supplied

Category A Non Food Contact Packaging Category B Food Contact Packaging

The priority categories associated with your companys requirements will be explained, as follows:
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THE STANDARD REQUIREMENTS

1. SCOPE 2. Organisation

Responsibilities for implementation and maintenance of standard Designated Manager (within structure)
Qualified Suitably senior Acknowledged deputy

Management review system

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THE STANDARD REQUIREMENTS

3. Hazard And Risk Management

Contamination risks Packaging defects Customer specific Senior Management commitment Documented management system Internal Audits

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THE STANDARD REQUIREMENTS

3. Hazard And Risk Management

3.1 Hazard analysis: Conduct hazard analysis Determine hazards Establish critical limits programme Monitor against programme Verification and validation records Procedures and methods for execution

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THE STANDARD REQUIREMENTS

3. Hazard And Risk Management

3.2 Hazard analysis: Establish process flows Identify and record hazards Assess the risk Decide the action required Procedures appropriate to the risk Process controls Regular review / audits of the risk areas
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THE STANDARD REQUIREMENTS

3. Hazard And Risk Management

3.3 Following the completion of the analysis (as above), measure to monitor critical process steps shall be implemented, maintained and reviewed

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THE STANDARD REQUIREMENTS

3. Hazard And Risk Management

3.4 Hazard analysis and procedures shall have Top Management approval and commitment 3.4 Procedures and methods of control implemented through the companys documented management system 3.5 Related procedures shall be included with audit programme (refer to section 4.7)

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THE STANDARD REQUIREMENTS

4. Technical Management System
4.1 Technical Management Policy

Quality and Hygiene Policy Statement Published and issued statement by the Senior Management: Legal compliance Commitment to consumer protection Documented system implementation Training and resource management Review of system effectiveness
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THE STANDARD REQUIREMENTS

4.2 Document Control

Demonstrate compliance with the standard Documented management system (procedures / methods) shall be authorised (at all levels) Formally issued and controlled Obsolete documentation removed from use Complete records controlled at all appropriate levels

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THE STANDARD REQUIREMENTS

4.2 Document Control (Required Records)
Training Cleaning Schedules Foreign Body Incidents Customer Complaints and Product Recall Internal Audits Pest Control (internal and external) Maintenance / Engineering Glass and Brittle Plastic Policies Blades and Sharps Control Non Conforming Products Traceability
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THE STANDARD REQUIREMENTS

4.3 Specifications

Raw Materials Finished Goods Suitable for food contact use Adequate, accurate and legally compliant Agreed with relevant parties Trademark agreement Review procedure
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THE STANDARD REQUIREMENTS

4.4 Management Of Incidents And Product Recall

Documented incident reporting procedure Customer notification Documented recall procedure Product re-call at all stages of production Control of non conforming products Corrective and preventive actions Verification of recall systems
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THE STANDARD REQUIREMENTS

4.5 Traceability

Raw materials Work in progress Finished goods Product identifiable at all stages of production

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THE STANDARD REQUIREMENTS

4.6 Process Control

Hazard Analysis Sufficient and appropriate controls Segregation of raw materials, work in progress and finished goods Process and equipment verification Legal compliance and customer satisfaction Equipment calibrated and traceable to National Standard Control of raw material supply
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THE STANDARD REQUIREMENTS

4.7 Internal Audits

Programme of audits in consideration of risk Trained and independent auditors Documented results of audit Review of audit results Corrective and preventive actions

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THE STANDARD REQUIREMENTS

4.8 Complaint Procedure

Documented system for complaints Effective management review Implementation of corrective and preventive actions Complete records of action taken Approval of actions

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THE STANDARD REQUIREMENTS

4.9 Supplier Monitoring

Evaluation and selection of suppliers Selection criteria against procedures Assess ability to supply conforming product Maintain an approved supplier list Measurement of supplier performance Verification of supplier claims / approvals

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THE STANDARD REQUIREMENTS

4.10 Sub Contracting Of Production

Effective control of sub-contracting Include hazard analysis Identify responsibility Verification of Subcontractor Technical Systems

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THE STANDARD REQUIREMENTS

4.11 Product Analysis

Hazard Analysis Reliability of Test Results Qualified Personnel Accredited Sub Contracted Laboratories (or other body) Agreed and Documented Test Methods Compliance with Specifications

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THE STANDARD REQUIREMENTS 5. Factory Standards

As indicated within earlier slides, the Standard is divided into two categories: Category A, (indicated in orange) and; Category B (indicated in green) The priority categories associated with your companys requirements will be explained, as follows:

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THE STANDARD REQUIREMENTS 5. Factory Standards

5.1 Perimeter And Grounds

Unobstructed Access and Debris Free Defined External Eating Area Access Points Proofed Protected Appropriate Drainage Systems Traffic Routes Surfaced Protected External Storage Designated Refuse Collection Areas

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THE STANDARD REQUIREMENTS

5.2 Layout And Product Flow

Prevention of cross contamination Control of work in progress Product handling areas Designated personnel routes

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THE STANDARD REQUIREMENTS

5.3 Building Fabric

Sound construction Suspended ceilings accessible Adequate lighting Cleaning schedules for internal surfaces Walls capable of being cleaned Drainage protection Sufficient ventilation Proofing of ventilation openings Proofed against pest ingress
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THE STANDARD REQUIREMENTS

5.4 Maintenance Of Equipment

Well maintained Cleaning schedules Wooden equipment Minimised use Good condition Properly sealed Notice-boards
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THE STANDARD REQUIREMENTS

Maintenance Of Equipment
Planned maintenance programmes Control of compressed air Use of tape engineering Operate to hygiene, health and safety requirements Control of contractors Post maintenance checks Documented post maintenance checks

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THE STANDARD REQUIREMENTS

5.4 Housekeeping And Cleaning Clean as you go policy Cleaning schedules

Item to be cleaned Frequency Method Cleaning materials Responsibility Cleaning record checks

Use of approved cleaning detergents Monitoring of effectiveness

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THE STANDARD REQUIREMENTS

5.4 Housekeeping And Cleaning

Storage of cleaning equipment Toilet cleaning products segregated Control of tools and maintenance equipment Control of workstations to prevent product contamination Suitable storage facilities for workstations

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THE STANDARD REQUIREMENTS

5.6 Waste And Waste Disposal

Minimise accumulation of waste in production Use of appropriate containers Disposal of putrescible waste (lined and lidded) Disposal of Trademarked waste Use of licensed waste contractors Collection of recycling waste

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THE STANDARD REQUIREMENTS

6. Contamination Control
6.1 Foreign Body Control

Staff training Written policy for glass and brittle plastic Glass and brittle plastic register Written policy for sharps control Issue and control of sharps Snap off knife blades

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THE STANDARD REQUIREMENTS

6.2 Chemical And Biological Control

Chemicals, cleaning materials, lubricants and adhesives controlled to prevent product contamination Aseptic control systems

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THE STANDARD REQUIREMENTS

6.3 Pest Control

Formalised preventative programme Use of approved contractors for pest control Records and location of pest control baits Correctly sited EFKs Follow up actions

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THE STANDARD REQUIREMENTS

6.4 Transport, Storage And Distribution

Finished product protected Product movements between premises Checking of wooden pallets Control of contract haulage Written contract with hauliers Integrity checks of raw materials Documented checks of raw materials
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THE STANDARD REQUIREMENTS

6.4 Transport, Storage And Distribution

Non conforming products Vehicle drivers Clean and suitable transport Cleaning programme for vehicles Pre loading checks of vehicles Control of off site storage

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THE STANDARD REQUIREMENTS

7. Personnel
7.1 Access And Movement Of Personnel

Designated entrances Site security Designated walkways Logical movements

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THE STANDARD REQUIREMENTS

7.2 Locker Rooms

Provision of lockers Access to locker rooms and overall/protective clothing segregation Control of eating, smoking and drinking Food control Visitors and contractor facilities

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THE STANDARD REQUIREMENTS

7.3 Toilets And Hand Washing

Hand wash facilities Advisory signs Hand wash disciplines Hand-wash disciplines entering production areas Hand-wash facilities at entrances to production areas

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THE STANDARD REQUIREMENTS

7.4 Facilities For Eating, Drinking And Use Of Tobacco Products

Prohibited within direct production areas Provision of facilities Facilities for smoking internal or external

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THE STANDARD REQUIREMENTS

7.5 Personal Health

Illness notification/return to work Medical questionnaire for visitors/contractors Covering of cuts with appropriate dressings

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THE STANDARD REQUIREMENTS

7.6 Jewellery And Personal Items

Jewellery policy plain band rings, sleeper earrings and wristwatches Jewellery policy plain band rings and sleeper earrings only False nails and nail varnish

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THE STANDARD REQUIREMENTS

7.7 Protective Clothing

Appropriate clothing Appropriate clothing (spares) Hair covered to prevent contamination Self care of protective clothing Approved laundry services (contractors) Segregation of clean and dirty clothing

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THE STANDARD REQUIREMENTS

7.8 Hygiene Training

Induction training Formal basic hygiene training Refresher hygiene training Training records Contractor and visitor hygiene procedures

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PROTOCAL

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PROTOCAL

Certification Bodies
Only Accredited Certification bodies to EN45011* with the appropriate scope, shall carry out evaluations against the BRC Standard, and issue certificates, or; Until 31st May 2003, to include those Certification Bodies actively seeking accreditation to EN45011

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PROTOCAL

Before the initial evaluation The Supplier is required to review the BRC Standard Make any necessary amendments or improvements to its operation and systems Provide background information on the site concerned, by completion of a pre-evaluation questionnaire or pro-forma information sheet.

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PROTOCAL

The scope of the evaluation shall be defined between the Supplier and the Certification Body The scope shall be identified in the evaluation report and any certificate of inspection. The Supplier may contract the Certification Body to evaluate matters beyond the scope of the BRC Standard, but no relevant elements of the BRC Standard shall be omitted.

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PROTOCAL

Any additions to evaluation scope may or may not fall within the scope of the Certification Bodies accreditation A supplier may be advised to check with either the Certification Body or UKAS before contracting such additional work

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PROTOCAL

Evaluation Procedures Duration of evaluations will be dependant upon a number of factors but due regard must be given to; size of the site the types of processes to produce and store product number of product lines,

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PROTOCAL

Evaluation Procedures (continued) the number of employees related to food (food safety) size of random sampling the number of non conformances as recorded in previous evaluation

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PROTOCAL

At all evaluations there are four elements, which shall be carried out;
opening meeting review of quality systems and procedures site inspection closing meeting

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PROTOCAL

Major
There is substantial failure to meet the requirements of a statement of intent and any mandatory clause of the Standard. Depending upon the level of certification sought (Foundation or Higher), the mandatory clauses will differ. The mandatory clauses for Foundation Level are all those listed in the Foundation Level column. The mandatory clauses for Higher Level are as for Foundation Level, and in addition, all the clauses in the Higher Level column.
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PROTOCAL

Minor
This is where absolute compliance to the statement of intent and a mandatory clause has not been demonstrated, but on the basis of objective evidence the conformity of the products safety and legality is not in doubt

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PROTOCAL

Recommendation
There is a failure to meet a recommendation of good practice.

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PROTOCAL

The report contains the following sections:

evaluation details evaluation summary- overview of performance details of non-conformance and corrective action plan detailed evaluation report

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BRC / IOP Technical Standard for Companies Manufacturing and Supplying Food Packaging Materials for Retailer Branded Products

YOUR QUESTIONS

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THE STANDARD REQUIREMENTS

What to do next:
Make sure your factories are up to the requirements of the Standard Become accredited under the Packaging Technical Standard Ensure your suppliers are as good as you require by insisting they become accredited

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