Amongst the myriad legislation and safety standards affecting food processing and production, it is vital not to ignore the safety and quality of packaging production.
The manufacture, printing and production of raw materials for packaging often involves potentially harmful materials and processes, from inks and coatings that have the potential to “migrate” onto food to the handling of process waste, including pellets, powder and flakes.
Standards for packaging and its manufacture are set out in the BRCGS Global Standard for Packaging and Packaging Materials, which focuses on all aspects of safety and quality and covers a wide range of issues, including hazard control, factory environment, process control and quality management systems.
The Global Standard for Packaging and Packaging Materials covers everything from food to consumer products; but, as the first packaging standard in the world to be recognised by the Global Food Safety Initiative (GSFI) benchmarking committee, it is widely accepted as a yardstick for compliance in the UK food industry.
In fact, many UK retailers require certification as a prerequisite from their suppliers, although it is also recognised by brand owners, foodservice companies and manufacturers around the world when assessing the capabilities of their suppliers.
It now provides a robust framework for all types of packaging manufacturers to assist them in the production of safe packaging materials and to manage product quality to meet customer requirements — all while maintaining legal compliance.
A sixth sense: understanding Issue 6
More than 3500 companies in more than 80 countries are certified according to the Global Standard for Packaging and Packaging Materials, which, like all similar standards, is regularly updated in line with developments to maintain safety, quality and operational criteria. In August 2019, Issue 6 was published, marking the first major update in four years and a further evolution in requirements of certified organisations.
Recognising the importance of quality management systems and consistent audits, the new Issue 6 places greater emphasis on senior management commitment and reinforces the importance of a hazard analysis and risk assessment-based product safety programme.
Its objective, to quote the BRCGS itself, is to “direct the focus of the audit towards the implementation of good manufacturing practices within a product safety and quality culture of continual improvement, while recognising the diversity and breadth of the packaging industry and the skills required to audit it.”
With this in mind, let’s examine the specific areas of change since Issue 5:
Enhancing the processes used by quality management systems in printed packaging controls with a hazard and risk analysis approach: Issue 6 reinforces the need for a hazard and risk analysis (HARA) — including through an accompanying checklist — but, for the first time, it separates hazards into product safety and quality defects.
This provides greater clarity and will help to improve the control measures necessary to prevent, eliminate or reduce each product quality hazard to acceptable levels.
Continuing to ensure consistency of the audit process across the world: The role of accredited certification bodies and audit training providers such as Bureau Veritas remains critical as supplier approval is required via a benchmarked audit or site audit by a second- or first-party audit. Low risk suppliers could still be approved by a questionnaire, as long as supplier traceability systems are tested initially and every three years afterwards.
The importance of a product safety and quality culture in the drive to improve transparency and coherence across the food supply chain: In another new clause introduced in Issue 6 (1.1.2), organisations are reminded about the importance of driving a culture of safety and quality. This clause requires sites to set up, execute and review an action plan to improve product safety and quality culture.
Auditors are not required to specifically assess the culture of the given organisation, but they must examine the efforts made to document the status of the organisational culture and the steps that are put in place to improve it.
Simplifying the hygiene requirements based solely on risk: Issue 5 used a two-tiered approach to hygiene — high and basic — but after consultation with the industry, this has now been simplified and replaced by one, risk-based approach. This simplification will also help to ensure clauses are applied appropriately in former basic hygiene sites.
Introducing a new fundamental clause, corrective and preventive actions to address issues and minimise the risk of occurrence: Fundamental clauses are those that must be implemented so that the site can be certified.
A new fundamental corrective and preventive action (CAPA) clause in Issue 6 requires the integration of root cause analysis with a structured continuous improvement approach to minimise the risk of issues reoccurring. This is in line with Issue 8 of the BRCGS Food Safety Standard.
Based on risk, putting a microbiological environmental monitoring programme in place: Another change in line with the latest update to the Food Safety Standard and to incorporate BRC Packaging issue 5 position statement P558, the new environmental monitoring clause (4.8.5) applies to all production areas.
It is designed to make sure that the production environment is fit for production and doesn’t pose a risk of contamination to the product.
A risk assessment must first determine what testing is required before the necessary control limits are applied with predefined corrective actions. Inevitably, ongoing monitoring and review is necessary.
Simplifying the unannounced audit programme: Issue 5 of the global standard offered three audit options: a full announced audit, a full unannounced audit and a split unannounced audit. The latter of these options divided the audit requirements into two separate audits, the first one unannounced and the second one announced.
In reality, the full unannounced audit option is generally preferred because it gives extra confidence to specifiers; as such, Issue 6 has removed the split unannounced audit option (in line with Issue 8 of the Food Safety Standard). Unannounced audits remain optional.
Time to act
Issue 6 has now been published and it is a welcome step forward in the evolution of safety, quality and operational criteria throughout the packaging production chain. However, these new auditing requirements will of course require some changes. Audits and certification to Issue 6 will start in February 2020, so organisations must act now to make sure they are fully prepared.
