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Draft Issue 6 - Protective Clothing clause 6.5.1
5:27PM 19 November 2018
I am reading through the draft issue & would like clarification an the statement " Hair covering & beard snoods, where appropriate, shall be worn in production areas at site manufacturing materials for direct contact with food or other hygiene sensitive products". 
We manufacture BOPP for  the above categories & currently , based on hazard & risk principles we have determined that we are except from wearing snoods justified on the account of the very low likelihood of contamination occurring due to operators not standing over unprotected film path or winding stations.  
Reading the draft - Has the ability to determine & assess this risk been taken away & it will be compulsory to wear bear snoods ?

From: paul
11:03AM 28 November 2018
I was reading through this yesterday, and for me it has now removed the ability to RA out the need for Snoods, and they will be compulsory where appropriate.
10:16AM 18 April 2019
Agree, this is how I have interpreted this but I can see how some may take another view. It is not clear.
From: lorenab
4:25PM 28 November 2018
Hi Gill,
I think it would still be based on risk as they said "where appropriate". That is  just what I think :)

9:42AM 18 April 2019
I have interpreted this as that snoods will be required for all personnel with a beard. The 'where appropriate' comment is where the personnel have a beard. Why I am thinking this is because the next paragraph goes on to say that 'Hazard and risk principles shall be used to determine the need for all other protective clothing'. Therefore, no RA for snoods!
From: lorenab
4:23PM 28 November 2018
Hi Gill,
I think it would still be based on risk as they said "where appropriate". That's just what I think.

Vigencia BRC Packaging Versión 6
4:27PM 20 December 2018
Me gustaría saber en que fecha entraría en vigencia la versión 6 de BRC Packaging?

Saludos cordiales,
8:15PM 6 March 2019
Hola Luis,
Estos son los tiempos para la Versión 6:

- Principal
TTT in July 2019
- ATP training
by Sep 2019
- Sites/
auditor training by October 2019
- Issue 6
audits as of February 2020

Federico Sánchez
10:31PM 28 March 2019

Muchas gracias Federico,
saludos cordiales
6:31PM 3 January 2019

Dear all;

I am also interested in knowing how to prepare the audit of 2019, if starting with the draft of the new version or still using the version 5.

Thank you very much.

Best regards,
From: paul
8:39AM 8 January 2019
I don't believe you can prepare for Version 6 yet. It is still only a draft and the final may differ slightly or completely. Plus there has to be some kind of transition period between the old and new standard. Prepare for issue 5 as usual is my advice.

From: Jim Richardson
1:59PM 6 February 2019
I believe Issue 6 is released in August 2019 with compliance in 2020
From: Jim Richardson
1:57PM 6 February 2019
I believe Issue 6 is released in August with compliance in 2020
From: Jim Richardson
1:55PM 6 February 2019
I believe Issue 6 is released in August with compliance in 2010
7:13PM 24 January 2019

Frequency internal audit
From: Joan Rohde Pedersen
8:20PM 13 March 2019
Is the interpretation - now in BRC Food issue 8 - internal audits throughout the year = minimum 4 dates also valid for BRC Packaging?

QRB Meeting
From: paul
10:35AM 3 January 2019
Hi all and a happy new year.
I have a quick question regarding the yearly quality review board meeting. BRC says we must do this with in 12 months of the previous meeting. Normally we do this first week Jan, however due to changes in the business certain KPI are not know until Feb. My question is, is it acceptable to have the meeting as usual in Jan, but suspend it until the 1st week in Feb, where a full review will take place? So basically nothing is discussed in the Jan meeting other than a record of suspension.
I am hoping this caveat will allow us to do this and not have any effect on our Audit, any feedback would be greatly appreciated.

3:49PM 10 March 2019
As per clause 1.2.1 review has to be undertaken at appropriate planned intervals; as a minimum annually. So this is a minor NC as this clause is failing. 
Also in the interpretation guideline, it says shorter time periods are acceptable but it has to happen annually. Moreover, review must be a specific meeting with a defined agenda. Topics discussed during other events, do not constitute a review.
7:59AM 7 March 2019
No. Requirement is clear. At least every 12 months. You can always call additional management review in feb and include new kpi or other circumstances in that meeting.
Draft Issue 6 - Chapter 7 Requirements for Traded Products
From: eLVeCon
4:48PM 18 February 2019


Can someone confirm whether Chapter 7 is actually about packaging material, as the following is stated:

"Where a site purchases and sells food products that would normally fall within the scope of the Standard and
are stored at the site’s facilities, but which are not manufactured, further processed or packed at the site being

audited, the site’s management of these products is covered by the requirements in this section."


8:26PM 6 March 2019
Chapter 7 is actually about trade goods.  It means packaging or packaging materials that are trabed by a site and do not re-manufactured, re-processed or handled at any time. It is only about trading and the possibility for the site to included them into the scope of certification.
Best regards,
Federico Sanchez
From: eLVeCon
9:27AM 7 March 2019
Hi Frederico

Thanks for your answer.. I was confused by the fact that it's mensioned "food" instead of packaging material.
But you confirmed my thougth, that it's about packaging and packaging materials.

All clear... thanks again!
8:24PM 6 March 2019
Chapter 7 is actually about trade goods.  It means packaging or packaging materials that are trabed by a site and do not re-manufactured, re-processed or handled at any time. It is only about trading and the possibility for the site to included them into the scope of certifications.
Best regards,
Federico Sanchez
Position Statement
2:34PM 28 February 2019
I can't find the complete library of Position Statment. In particular I can't find the P558. Why?
Thank you

3:04PM 28 February 2019
Requirement 3.7 - Subcontractor / Supplier
4:37PM 24 January 2019
Good afternoon, everyone!
I don't know if someone can help me understand the difference between these two terms. It is always a point of conflict during the external audits, depending on the auditor I receive a different answer.
Thank you in advance for your help.
From: Ronald Tejeda Vilchez
5:02PM 24 January 2019

Ines Good afternoon,
If you mean Service and Supplier
Service, is when someone external helps you to carry out part of your productive process. Example: extrusion service, sealing service, etc.
Supplier, is the one that supplies you with strategic raw material for your different processes.
Logo BRC Packaging
From: Ronald Tejeda Vilchez
10:40PM 16 January 2019

Gentlemen good afternoon,
1. Please who could tell me which logo to use for BRC Packaging?
2. How can I get the BRC Packaging logo?
The support provided is appreciated.

Best regards

Ronald Tejeda Vilchez
Medical Bracelets
From: paul
11:40AM 3 January 2019
Jewellery other than a single sleeper type earring and a wedding band is prohibited. What are the views on medical bracelets, either medical ID or these copper type? 
Traded Goods Voluntary Module
From: Deepa
9:57PM 13 December 2018

I'm looking for some interpretation help into a part of the Traded Goods Voluntary Module, section 7.1.2.

In order to approve a supplier it needs to be GFSI approved, or a supplier audit.
supplier audit with a scope to
include product safety, traceability testing and hazard and risk management
systems and good manufacturing practices, undertaken by an experienced and
demonstrably competent product safety and quality management auditor.

I'm wondering if the site's ISO 22000 certification will be enough - it is a supplier audit conducted by a qualified auditor, but it is not undertaken by ourselves, or at our request.  Is the expectation that the audit is conducted/ paid for by the company purchasing from the site?

Draft Version 6 - Traceability
From: Deepa
2:13AM 29 November 2018
In the draft Version 6, section 7.5.3, reconcilation is required.  Is a mass balance required on all raw materials used in the batch, or just one chosen raw material?   Should 'quantities of product' read 'quantities or raw materials'?
Many thanks
Issue 5 - what should change or be improved for Issue 6?
2:27PM 8 August 2018
Issue 6 is currently in development. What doesn't work in Issue 5, or what could work better? What works well? Are there key themes in industry that we should be looking at? 
From: Deepa
2:03AM 29 November 2018
Hi Joanna

As the draft version has been issued and is out for consultation, will the feedback on the forum be considered, or do we need to submit that traceability of inks should be based on risk assessment through the feedback form?  It would be a real shame if BRC didn't recognise/ consider the comments raised below because not enough companies completed the form.
2:45PM 2 November 2018
I must agree with the traceability of inks.  It truly is impossible. We have been trying for a few years now, and it just is impossible.  When you have a jug, which can be mixed into many others to mix different colors, it just becomes a nightmare.
1:01PM 30 August 2018
I agree with iriszhang regarding the traceability of inks (above all the mass balance that it is really impossible to do!). 
Other points that should be more detailed should be the food fraud/food defence and the 3.12.8 (explaining in details how to do a moc recall). 
From: lorenab
6:44PM 30 August 2018
I am really interested how we can implement the traceability of inks. If Issue 6 can be more elaborate on that part that would be of great help for us.
12:59PM 30 August 2018
I agree with iriszhang regarding the traceability of inks (above all the mass balance that it is really impossible to do!). 
Other points that should be more detailed should be the food fraud/food defence and the 3.12.8 (explaining in details how to do a moc recall). 
From: Deepa
10:16PM 12 August 2018
We're just starting to go through the accreditation process, so it's interesting to see what's included in the standard and how we can comply.  One thing that has caused us discussion, is the traceability of inks.  The standard requires 'all raw materials', a little flexibility based on risk would be good here, as it seems to be a industry wide/ global discussion point on the forums, to what is the real food safety risk and likelihood of a recall taking place because of inks.

I really like the use of risk assessments to show whether something is required or not, and request that stays.  It does help differentiate between the packaging standard and food standard.  
11:50AM 27 September 2018
Depending on which inks you are talking about. If you print UV cured inks with for example matt lacquer on it the risk is quite huge. With matt lacquer the UV penetration is much smaller so free photoinitiators can be present even if top sufrace is perfctly hardened. If you give too much UV then print is not going to look good so operators seems to give too less instead of too much if UV and that definitely increase the risk. None of scratch test tape test could detect that and you ending up in a situation where you have free photoinitiators which are very small compounds easily migrating to food. Also those UV strips are not that accurate enough.  This group of compounds it quite toxic so limits in legislation are  low sometimes even 0.01 mg/kg. Thats why traceability of inks is very important and the story im describing happened in real life with 1000K euro costs .  
On the top of that your ink manufacturer is producing different types of inks on the same equipment. Imagine that someone is going to mix food and non-food ingredients on a production by mistake. If you dont have traceability you are recalling all batches of containers with ink from that producer, if traceability is present then you recall only that particular batch of ink. Standard is very strict in traceability and in my opinion there should be no relax in this matter. Traceability should be done on all raw material which might bring a risk and it should be done to the best practical level. 
From: JudyR
3:42PM 16 August 2018
I agree with your comments. I suggest that issue 6 reflects the requirement for risk based decisions regarding the traceability of raw materials. 
Protective clothing
From: paul
2:07PM 2 October 2018
Hi all My procedure currently requires all operators to change at work into their protective clothing. At the moment when people go out to the smoking areas they do not remove the protective clothing and change back in to their day clothes and then back again in to protective clothing. I don't want to get into the smoking debate. I have decided to allow all operators to come into and leave work in their protective clothing. I will operator a spot check system. All will be required to have a spare with them in their lockers in case they fail the spot check. I will be doing the RA  for this to ensure we don't encourage any contamination.  What are your opinions please
From: Calidad Envaflex
3:25PM 3 October 2018
Hi all. We have gone through something similar and what we have done has been to implement a standard by which our workers can’t leave without wearing a disposable protective equipment over their work clothes. At the moment when our workers go out to the rest areas they should put on that disposable protective clothing
3:04PM 2 October 2018
Hi Paul,
what do you mean with "spot check system"? 
From: paul
6:01PM 2 October 2018
the team leaders, other management will check the state of the protective clothing being worn from time to time of anyone on the shop floor. This will form part of a document to say they have checked. Anyone found to not meet the standard will be asked to change into clean clothing. We are a small factory so major contamination risks will not go in-noticed
BRC Packaging - work with material which is not suitable for food use
From: Calidad Envaflex
3:08PM 28 September 2018
Good afternoon,some doubts have arisen regarding the raw material. One of our clients wants us to work with their own material, which is not suitable for food use. Our doubts are:
      - being of high category: can we enter this material in our facilities taking the necessary preventive measures or is it not possible under any circumstances? In what section of the BRC standard does this indicate?
     - If you can work with it, does the machine you are going to work on be in an area separate from the rest of the equipment or can you share facilities with the others?
    - Once the work is finished, that machine must be sanitized to eliminate any remaining material not suitable for food before being able to work with other material, right?

Thank you very much for your feedback and guidance
Issue 5: Hand washing before entering the production area
3:36PM 21 September 2018
we have a hand washing station right between lunchroom and the entrance to production area. if employees wash hand in lunchroom after lunch or use washroom, do they need to do it again before entering the production area? the distance between lunchroom(washroom) and production entrance is less than 10 meters.
thank you, Ken

7:49AM 24 September 2018
I think that the important thing is that you should be able to give evidence that the employees wash their hands after food consumption. In my case, we have "hygienic gates", the gate will be opened only if you sanitize the hands. 
4:34AM 22 September 2018
Yes, i think it is necessary for safety, careful is never redundant!
Management of Product Withdrawals, and Incidents and Product Recalls
From: lorenab
3:19PM 5 September 2018
On Section 3.12.6 "communication with regulatory bodies", i think it would help if Issue 6 interpretation guideline specifies that this include contacting the certifying body/BRC? We were not aware about it until being told by an Auditor.

4:56AM 22 September 2018
I think if the incident is very large and due to objective reasons, it is necessary to report to the authorities, and if the problem is within the control of your company and your company can No need to report to them unless required.
Clause and use non-fragmentable blades and cutters in some processes
From: Calidad Envaflex
7:40AM 24 August 2018
Good morning,
In our company we use non-fragmentable blades and
cutters in some processes. Clause says that the use of cutters isn't allowed but we maintain a rigid control over them since for such processes they
are necessary. Can we have any problems during the audits? We have tried other
equipment and tools but none has given a satisfactory result. I'm so grateful if you can give us some recomendations

Thank you very much

4:50AM 22 September 2018

When audit, you need to show records and evidences (form, documents) about good control for this machine.
I think it is not problem during audit, good luck!
4:35AM 8 September 2018
Only snap off blades are restricted, because of chances of breakage & mix into the product. if you have other type of blade than it will not be issue. 
2ndly, cover blade hazard in risk assessment.

9:01AM 4 September 2018
Hi there, refers to snap-off blades, and it was universally agreed that there are few occasions where snap-off blades are acceptable and where non snap-off blades can't be used. This is due to the level of hazard they pose to the consumer should they remain in the packaging material. I'm afraid that should the auditor observe the use of snap-off blades during the audit then a non-conformity will likely be raised. 

Perhaps other users of the forum could suggest alternatives that enable compliance with the requirement? 
P557:Position Statement-hygiene categories
From: QualityIP
7:21AM 21 September 2018
We're producing label for food products (for buckets). Our products indirectly contact with food and so we are in the basic hygiene category. After releasing of the position statement about the hygiene categories, will we need to change our hygiene category?
Thank you in advance.
Compliance Related Points for specific country
From: ashutoshroy
11:14AM 18 September 2018
Will like to know and discuss about MOAH - MOSH in the packaging specifically Polypropylene woven sacks (FIBC) acceptable limit. Also the update with respect to USFDA and EC 10-2011 guideline. How can the compliance proved other than declaration and statements from the supplier? Also few testings are done in external lab but conducting all test are not feasible. 
Hoping to get some feedback and advice as on how people implement and comply to requirements in other industries.

Sharps Control - Loose Items
From: Deepa
10:24PM 12 August 2018
In the sharps control section (, it says no loose fastenings, such as drawing pins and staples.  Would an auditor consider magnetic buttons used on noticeboards as a loose fastenings?  It is a loose fastening, but it's not a sharp?  

Many thanks
10:34AM 23 August 2018
The main concern with the section on sharps is preventing materials that could cause harm to the consumer from contaminating the packaging material. Items such as staples or drawing pins/thumb tacks are clearly an issue, and many will be difficult to identify as a contaminant. While magnets are still a loose fastening and potentially harmful they are (perhaps) a little more visible and less likely to remain on/attached to a material when it's in production. 
I would recommend that if in doubt, a risk assessment always establishes if there is a real hazard and factors included in that risk assessment might be proximity of noticeboards to production lines or storage areas. The interpretation guideline also adds that enclosed or covered noticeboards are acceptable as mitigating the risk of these types of materials. 
From: Deepa
4:22AM 3 September 2018
Hi Joanne
Thanks for your feedback and guidance.