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brc-issue-6-packaging-interpretation

As you know we’ve been really busy developing our training course for BRC Packaging Issue 6 and in doing so, have come across a number of problems – which is one of the main reasons why our conversion training release is delayed, so apologies to those of you who are waiting –  we are working as fast as we can for you!

The biggest problem we found was that the key changes document doesn’t cover the changes if you’re a basic hygiene site, as BRC have only used the high hygiene clauses as reference. If you want to read more about this, you can do this here: Warning for basic hygiene sites

The other problems that we’ve found are as follows:

  1. There are many problems in the Standard, that we would see as mistakes.
  2. BRC now seem to be bringing the interpretation of the Standard into the requirements, not just in the clauses. We think is a little frightening, as we have fallen foul of this ourselves – as we have been auditing our sites to the clauses and not the interpretation of the clauses – which means we’ve missed things. The result of this means we are now having to go through our audit templates and update them all to make sure that any interpretation requirements are included as well. So, if you’re auditing to the clauses of the Standard, you need to do this too.  And, if you’re writing procedures to meet the clauses, you now need to cross-check the requirements against the interpretation to make sure you’ve not missed anything.
  3. There are many, many confusing elements to the Standard.
  4. Where new requirements have been added into the clauses, this hasn’t always been interpreted in the interpretation. It seems to us that the interpretation from Issue 5 has just been copied and pasted across into Issue 6.

We have found the experience of going through the Standard extremely frustrating (as you can imagine) and we don’t want you to have to muddle your way through it as well – so we thought it would be helpful if we share what we’ve found. We can’t promise we’ve covered everything in this article, as we’ve obviously only been focusing on the changes, but it gives you a good idea and a starting point.  If you find any more problems, it would be great if you could add them to the article, by putting them in the reply box at the bottom.

We’re also hoping that BRC will use this information and do something about the review process, before publishing a new issue of a Standard. So, here you go, here is our list of confusing elements about the Standard and the mistakes we’ve found (mistakes are shown in red).

Section 1

1.1.1  The clause doesn’t state that the policy must be dated when it‘s signed and that this must happen at least annually, but the interpretation does.  It also needs to include that the management are committed to continual improvement, which isn’t mentioned in the clause.

1.1.2  When this clause goes live in Feb 2021 the interpretation states that culture must also be included in 1.3.1 communication (this is referenced as 1.3.2 in the interpretation but this clause number no longer exists), 3.6 corrective and preventive action and 6.1 training and competence.  And to make matters worse, culture isn’t mentioned in any of these clauses.

1.1.3  Although not mentioned in the clause, the interpretation states that where head office provide the policy, it must be reviewed, signed and dated and communicated at site.

1.1.5  Part of the clause from 3.4.3 has been added into 1.1.5, however no interpretation has been added to explain this and no interpretation of what the auditor would expect you to do, to prove that your products are compliant with the legislation in the countries where it’s used.

1.1.6  This clause now states that you must be aware of changes to the protocol that are published by BRC.  The interpretation explains that these protocols are published in the form of position statements, which can be found on the BRC website.  Finding these is not easy and also, you have to manually check to see if they’ve changed and it’s not clear when they have been changed –  you have to open the document and check it.

Also, the interpretation states that the new position statements are communicated to certification bodies and sites.  It’s true that they are sent to certification sites, however, BRC do not and will not, send them directly to sites. They expect your certification body to do this, so it depends on how good your CB is, as to whether you find out about it or not. We would strongly recommend signing up to our articles and reading them carefully, as we check the BRC weekly for updates and let you know about them – so you don’t have to.

1.2.1  Although the clause states the management review should be carried out at least annually (i.e. minimum annually). The interpretation details that the frequency of the review reflects the size and complexity of the organisation. This could be interpreted by an auditor that your site may need to have reviews more frequently than the minimum and therefore could possibly leave you open to a non-conformance being raised. So, you’ll need to have a risk assessment which justifies your review frequency.

1.2.2  Although it doesn’t state it in the clause, the interpretation is very clear that you must include data in your management review evidence, to show what information you’ve reviewed.

1.2.3  States that the management review that the objectives should be ‘revised’.  This is surely a typo, as you can’t just revise the objectives if you’re not meeting them.  I think this should say ‘The meeting shall be documented and used to review the objectives.’

1.3.1  Although the clause doesn’t say it, the interpretation states that the name of the person holding a role must be stated somewhere, if not on the organisational chart.

Section 2

2.1  This section is just about the team, it’s confusing that they’ve removed quality from the hazard analysis section, but still talk about quality in the interpretation of the clause about the hazard analysis team. This confused us at first – we have to be honest. You need to think about it this way (even if it doesn’t make much sense); although quality is no longer in the hazard analysis section (section 2) you still need to do a hazard analysis for quality, it’s just that they’ve moved the requirement to 5.4. In order to do any type of hazard analysis, whether it’s safety, legality or quality – you need a team and this team is defined in section 2.1.

QCP’s are also talked about in the interpretation of this clause, however they appear nowhere else in the standard.  Section 2 explains how CCP’s are determined, but the Standard doesn’t explain anywhere how QCP’s are determined or what’s expected in the implementation of a QCP.

2.2  Although quality has been removed from the hazard analysis, it’s nearly impossible to separate the two when you’re considering the safety implications for the customer and the consumer.  A quality hazard for a packaging manufacturer may result in a safety hazard to the consumer. Splitting them doesn’t seem to add any value and only confuses the situation.

2.2.5  In issue 5 legality was in the list of hazards to cover and has been missed in issue 6, with no comment about the fact that it’s been removed.  Therefore, we can only presume this is a typo?

2.2.7  We have no idea why section 5 has been omitted from pre-requisite sections in the interpretation, do they not form part of the pre-requisite programmes?

2.2.8 & 2.2.9  The interpretation implies that labelling of finished product should be a CCP, unless you can justify why it wouldn’t be.  The example, goes on to say that the critical limit for this CCP could be, that each pallet needs two labels and should be scanned before being accepted into the site warehouse. This example is also used in 2.2.11 which infers that it is an example of a step they would expect to see as a CCP, even though the interpretation for 2.2 says that it is typical for packaging sites not to have any CCP’s.

2.2.10  The interpretation states that monitoring should be a frequency which ensures there is enough time, to remedy any issues or failures, i.e. bring the product back since the last good check. This isn’t implied at all in the clause.

2.2.11  The corrective action procedure that is mentioned in this clause is also relevant to that of out-of-spec non-conforming products, which aren’t necessarily a safety risk but could result in down time. (We’re not sure why this factor is mentioned in this clause when it should be covered in 5.7.1: control of non-conforming product.)

Section 3

3.2.1  The interpretation states that the document control procedure must extend to external documents, such and standards, customer specs and legal info. So, make sure they are included in the document control log and are identified, as this is not stated in the clause.

3.4.3  There is no information in the current interpretation guide or the previous one, that indicates what an auditor could expect you to provide as evidence, to show that your product is legal. It only mentions that the site is required to have a statement of compliance. This doesn’t on its own provide evidence of anything. It could be possible that the auditor would want to speak with the person who created the statement, in order to evidence that is was created by someone with adequate knowledge of the legislation involved, and have them demonstrate how they are achieved.

3.11  The statement of intent doesn’t refer to legality at all, however clause 3.11.2 does.

Section 4

4.6.1  This clause is about equipment design and lubrication.  The interpretation talks about having a good quality management system that includes maintenance, it doesn’t talk about the design of equipment or lubrication.  It also says that the auditor will be looking for evidence that the equipment is producing consistent quality product, in order to comply with this clause – which is not really related to this clause and really should sit in the 5.4.6 under process control.

4.6.3  This clause is about wooden equipment, making sure it’s sealed, clean and in good condition. The interpretation states that you must check the equipment regularly, which isn’t implied in the clause.

4.7.3  This clause talks about equipment checks in addition to the planned preventive maintenance system, which our interpretation would be; start-up checks etc.  However, the interpretation talks about planned preventive maintenance systems, so there is a mis-match in the clause and interpretation.

4.8.7  The clause talks about catch tray analysis for flying insects.  The interpretation talks about bait takes, which implies rodents and doesn’t mention insects.

4.10.2  The clause is about making sure that bins are emptied and cleaned. The interpretation talks about additional requirements; siting them in the right places, making sure that waste doesn’t get back into the production stream and also checking that this is the case.

4.11  Change in terminology from pest control to pest management, with no explanation of why or what the difference is between the terms. For us, this just adds confusion and doesn’t add any value. We can only imagine the amount of work that will go on at site, because Technical Managers will want to realign their procedures to the new terms and so, they’ll update their procedures – which seems like a lot of work, for no reason at all.

Section 5

5.4  In this section the clauses do not flow, the subjects jump around.  For example, 5.4.5 is line clearance, then we switch to process characteristics in clause 5.4.6 and then back to line clearance in 5.4.7.

5.4  As quality has been removed from section 2.2 onwards and put into section 5.4, our expectation was that section 5.4 would all be about quality, and the first two or maybe even three clauses are.  However, then safety starts to come back in.  After some consideration, we came to realise, that section 5.4 is not just about quality process control, but also about all the process controls you need.  So, essentially, whatever you deem to be required through your hazard analysis in section 2 and also your hazard analysis from clause 5.4.1 needs to be implemented using the rest of section 5.4. It may seem obvious when you think about it, but it did confuse us for a while, so we’re presuming we won’t be the only ones. We really don’t know what the benefit was of moving quality out of section 2 and putting it here.  To us, it just adds confusion.

5.4.1  The quality risk assessment has been removed from section 2 and now put in section 5.4 under process control.  This is confusing, as many quality defects may actually result in safety problems for the customer or consumer, so it’s difficult to separate them. In the interpretation, the last sentence also talks about safety.  We understand the statement, but think that adding it to the interpretation of the quality clause will cause confusion and it doesn’t add any value.

5.4.2  This clause is about having process control in place but the interpretation doesn’t explain the clause, it’s just a statement that doesn’t add any value.

5.4.9  Here we have, in our opinion confusion about the difference between verification and validation.  In section 2, BRC have amended the flow chart clause to remove the term validation and replace it with verification.  You can’t validate a flow chart (prove it will work) you can only verify the flow chart (check that it’s right). Here we have a new clause and the term validation has been used in the wrong context again. They have said you need to validate the line clearance.  They don’t mean you need to prove that the line clearance will work, on further study,  it turns out that they mean you need to establish if line clearance is necessary. It would have been better to say something a bit simpler like ‘the procedure must determine what type of line clearance is necessary’.

5.5.2  This clause is about checking the accuracy of measuring equipment. However, the clause talks about calibration, which is something different and calibration is covered in 5.5.1. Even the example in this clause is really about calibration, not accuracy. Calibration and accuracy checks are related, but two different things and it would be good if BRC could write this section with this in mind, to help clarify the point.

5.6.3  Talks about checking measuring equipment for accuracy, to make sure that the accuracy checks reflect what the equipment is used for.  This should really sit in the calibration section, under accuracy checks.

5.6.7  This clause is about making sure that test methods and control samples are the most up-to-date versions and control samples must be stored correctly.  However, the interpretation talks about the reliability of test results and having a system for checking to make sure the test results are reliable – which is something different to the clause.  The risk here is that both the clause and the interpretation will be audited and therefore, by just following the clause you’ve missed part of the requirement (as you would with all the other requirements that are ‘hidden’ in the interpretation).

5.7  In this section it switches terminology, which is confusing.  The section is called non-conforming product, the statement of intent says out-of-specification product and the clauses use the terms ‘out-of-specification or non-conforming materials’ and the key changes state ‘non-conforming product’, which implies these are all different things.  It would be helpful to choose a term and stick to it. Neither non-conforming product/materials or out of specification product/materials is defined in the glossary, so it’s hard for sites to understand if there is a difference between the two.

5.8.5  Again we have the use of validation, in the wrong context.  We have to validate that raw materials are correct before issuing them to production.  What they actually mean, is that we should check that they are correct before issuing them to production, which is verification.

5.9.1  This is a new clause which covers the need for a risk assessment to produce the controls required for storage, however the old clauses which cover some of these points have still been left in, so there is repetition (5.9.3 and 5.9.6).

5.9.4  This clause is in the storage section, but talks about positive release controls for dispatch (dispatch is section 5.10).

5.10.1  The interpretation states you also need to ensure that the requirements are verified with any transport contractors that you use, which isn’t mentioned in the clause itself.

Section 6

6.2.1   This clause does not mention that sleeper earings are permitted, but the interpretation does.

6.3.6  The example in the interpretation says that a high hygiene site makes labels which do not come into contact with food and therefore they do not have to adhere to the requirements of the clause. A site who makes labels which do not come into contact with food, is a basic hygiene site, not high hygiene site, so this example is confusing.

If you’ve arrived here, thanks for taking the time to read our article, we’ve highlighted quite a lot to get your head around and hopefully, we’ve been able to explain it in a way that you can ensure your compliance doesn’t have gaps when you’re updating and adding to your systems and procedures. We thought the BRC Packaging Issue 6 interpretation was poor and littered with numerous issues that didn’t add any value or understanding. We did endure it so that we would be able to support you which is the main reason that Techni-K Smart Knowledge exists. Please ask us any questions and add to the post if you have persevered too!

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