Detail of Enhancements

Global Standard for Packaging and Packaging Materials

Issue 2 and 3
The BRC Global Standard for Packaging and Packaging Materials Issue 3 was published on 4th
January 2008. The publication follows an extensive benchmarking and consultation process.
The following details the enhancements from Issue 2.
Scope
The scope of the Standard has been extended to encompass packaging for food and non food
use. Three categories of packaging with regard to the standards of hygiene under which
packaging is produced, have been identified. A decision tree has been produced to aid in
identifying the packaging category (see Appendix 1) and specific examples are also given (see
Appendix 2). The final decision on the level applicable to a manufacturing site will be made by
a hazard and risk analysis based on the hygiene requirements of the final product, used in
conjunction with the decision tree and may be determined by the manufacturer in association
with customers.
Name
The Standards name has been revised to reflect its international appeal and increased scope. It
does not contain BRC or IOP in the title and is now the Global Standard for Packaging and
Packaging Materials.
The Standard is written from the perspective of a company undergoing audit and includes the
following:

Introduction to BRC Global Standards Directory

Qualifications, Training and Experience Requirements for Auditors

Certificate Template

Audit frequency
The audit frequency has been reviewed and now all audits will be carried out at 12 month
frequencies unless three or more major non-conformities are found, where the next audit shall
be due in six months.
Report Format
The report format has been updated to provide enhanced presentation of information to the user
and report owner.
Auditor Qualifications
Details on the requirements for auditors is now included within the Standard to ensure
transparency and allow companies to verify auditor qualifications.

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Audit Protocol
Clarification of some further audit protocol points include:

Auditor selection as guidance the same auditor should not carry out more than 5
consecutive visits to a site.

Action to be taken by company and certification body detailed when extension to scope
is required.

Details requirement for BRC administration fee (currently 75).

Clarification of non conformity against fundamental = non conformity against
statement of intent.

Corrective action time now clearly stated as 28 calendar days.

Justifiable circumstances for certificate expiry defined.

Definition and actions required for certification of seasonal products.

The previous years audit report shall be made available for the auditor.

Further visits may be made by the certification body

Feedback and complaints to the BRC are encouraged. Details on how to do this are
included. The company has the right to appeal to the certification body within 7
calendar days of a certification decision.

Glossary of terms updated.
Requirements Clauses
The format of the Requirements has been updated to be consistent with other BRC Global
Standards and therefore does not include Best Practice Guidelines. The Requirements have
been reviewed and expanded and several new sections have been incorporated in light of
industry requirements. The number of clauses now total a maximum of 242 (from 178) and
include more detailed guidance and clarity to facilitate interpretation for certification bodies
and companies. The following changes are summarised although requirements may not be
applicable to all 3 packaging categories and provided as a guide to changes only.
1. Management Commitment and Continual Improvement (14 clauses from 6)
Emphasis on continual improvement. Additional requirements:

provision of resources

clear communication channels

review specified annually

detailed requirement for topics to be included in review

system for being kept up to date with legislation required

products must comply with legislation

Additional requirements specific to audit process:

current issue of Standard required

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closing of non-conformities from previous audit
2. Hazard and Risk Management (15 clauses from 8)
Split into 3 sub sections:
2.1 Hazard and Risk Management Team

requires multidisciplinary team

training
2.2 Hazard and Risk Analysis

requires documentation and verification of packaging category

include description and intended use of product

corrective action to be specified

best practice guideline of annual review incorporated

2.3 Hazard and Risk Management Prerequisites

proposed exemptions need to be documented and reviewed

3.1 Technical Management Policy (4 clauses from 4)
No change
3.2 Quality Manual (2 clauses from 2)
Minimal change
3.3 Customer Focus and Contract Review (New Section 3 clauses)

identify and review customer requirements

identify individuals for communication with customers

3.4 Internal Audits (5 clauses from 5)

requires records of conformity as well as non-conformity

3.5 Supplier Monitoring (4 clauses from 3)
Minimal change
3.6 Subcontracting of production (3 clauses from 3)

assessment of subcontractors by competent person deleted

3.7 Documentation Control (6 clauses from 6)
No change
3.8 Specifications (6 clauses from 6)
Minimal change
3.9 Record Keeping (2 clauses from 2)
Minimal change
3.10 Traceability (5 clauses from 3)

traceability system to comply with legislation in country of intended use where known
is required

best practice guideline for system tested on annual basis incorporated

3.11 Complaint Handling (4 clauses from 3)
Minimal change
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3.12 Management of Incidents and Product Recalls (5 clauses from 4)

Section split out into Management of Incidents and Non-conforming Product (clause 5.6)

detailed requirements for product recall procedure specified

best practice guideline for annual product recall test incorporated

4 Site Standards
4.1 Perimeter and Grounds (10 clauses from 10)
Minimal change
4.2 Security (New section 4 clauses)

controlled access

secure storage
4.3 Layout and Product Flow (6 clauses from 4)
Minimal change adoption of best practices to requirements
4.4 Building Fabric (8 clauses from 8)
Minimal change
4.5 Maintenance of Plant and Equipment (11 clauses from 10)

a planned preventive maintenance programme to be in place

control of compressed air

documented hygiene clearance following maintenance required

4.6 Staff Facilities (New pulled from sections 7.2, 7.3 & 7.4 - 13 clauses from 18)

best practice guideline incorporated specifying lockers of sufficient size

4.7 Housekeeping and Hygiene (11 clauses from 12)

best practice guideline incorporated requirement for adequate gap

specification for details on cleaning procedures incorporated from best practice

guideline

best practice guideline incorporated strongly scented chemicals not to be used

4.8 Waste and Waste Disposal (6 clauses from 5)

requirement for containers to be suitably labelled or marked

4.9 Pest Control (10 clauses from 7)

best practice guideline incorporated frequency of visits determined by hazard analysis

requirement for flying insect catch tray analysis at appropriate intervals (category 1
only)

recommendations need to be implemented

records must be kept

4.10 Transport, Storage and Distribution (8 clauses from 11)
Minimal change

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5 PRODUCT AND PROCESS CONTROL

5.1 Product Design and Development (New section 5 clauses)

customer design requirements shall be defined and agreed

development of procedures and specifications including retention of reference samples

5.2 Process Control (7 clauses from 8)

recycled material to be controlled

best practice guideline incorporated requirement to revalidate process following

changes
5.3 Product Inspection and Analysis (7 clauses from 6)

best practice guideline incorporated specifying frequency of checks

5.4 In-line Testing Equipment (New section 5 clauses)

need for equipment based on hazard and risk analysis

procedures to be documented

product flow divert required

5.5 Calibration (New section pulled from 4.8 - 7 clauses from 1)

equipment needed to be listed and labelled

documented procedure required and records kept

equipment to be adjusted at predetermined frequency

5.6 Control of Non-conforming Product (New section pulled from 4.6 - 3 clauses from 4)
Minimal change
5.7 Foreign Body Control (16 clauses from 11)

based on risk analysis glass shall be protected

best practice guideline incorporated notices on equipment shall be cleanable & secure
5.8 Chemical and Biological Control (3 clauses from 3)
Minimal change
6 Personnel
6.1 Training (5 clauses from 5)

routine review of staff competency required

6.2 Access and Movement of Personnel (4 clauses from 6)

clause regarding security moved to 4.2 (site security)

6.3 Personal Hygiene (11 clauses from 9 section 7.3 & 7.6)

plain wedding ring, a wedding wristband and sleeper earrings (continuous loop)
allowed to be worn.

best practice guideline incorporated personal items not to be taken into production
areas

best practice guideline incorporated - gloves to be controlled

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6.4 Medical Screening (4 clauses from 4)

Minimal change
6.5 Protective Clothing (10 clauses from 6)

best practice guideline incorporated sufficient sets of clothing required

policy to be documented

specification detailed for self care procedures

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Appendix 1
Decision Tree Packaging Category Determination
STEP 1 Conduct Risk Analysis

Is the packaging
intended for a high
risk product - For
example food or
cosmetic products?

Yes

Is the packaging
intended for
direct contact
with a high risk
product?

Does the high

risk product have
an adequate
natural barrier?

Yes

No

Yes

No

Is it intended that the

packaging will enter
an environment where
there are unprotected
or open high risk
products?

Yes

Does the
packaging have
the potential to
contaminate the
product?

Category 1

Category 2

Yes

Category 1

No
No

Is the product
already in
impermeable
packaging?

No

Category 2

Yes

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Category 3

Appendix 2
Packaging Category Examples
Cross reference shall be made against the decision tree.
It must be stressed that this is not an exhaustive list and only provides examples. The final
packaging category determination should be agreed between the company and their customer
and discussed with the certification body.
PACKAGING CATEGORY 1
Direct contact with products that are consumed, applied to the skin or intended for infants
Plastic film laminate for cooked / uncooked meats
Plastic film for bread
Plastic laminate for toothpaste tube
Lipstick case mechanism
Caps for bottles of mouthwash
Packaging for infants toys
Packaging for facial wet wipes
Tube for eye liner
Tub for baby ointment
Caps for bottles of shampoo
Packaging for sanitary products or baby nappies/diapers
Skin care product containers
PACKAGING CATEGORY 2
Packaging that is in direct contact with a high risk product that has a natural barrier.
Corrugated case used for packing bananas or avocados
Moulded pulp/expanded polystyrene box for eggs
Packaging that enters the same area as unprotected high risk product
Cartons used to protect food stuffs that have been film over-wrapped where the cartoning and
over-wrapping machines are in the same area.
Label for foodstuff where the label is applied on the same machine on which the food is packed
Closure for bag of cotton wool pads
PACKAGING CATEGORY 3
Packaging that will be used for certain high risk product that is already in an impermeable
pack
Labels used for any product in plastic/glass jars or metal cans
Corrugated case for film over wrapped biscuits where the case is filled in different area to
biscuit wrapping
Packaging for products with reduced hygiene requirement
Clothing (coat-hangers or shirt bags)
Textiles (sheets, oven gloves or curtains)
Homeware (pots/pans, cutlery or crockery)
Household products (kettles, toasters or china ornaments)
DIY products (chisels, screws, curtain rails or mastic)
Automotive products
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