In this article we’ll be continuing the comparison of BRCGS Standards to IFS, comparing the Packaging Standards.

If you’d like read back over the previous articles on this topic you can do that here:

Comparison and gap analysis of BRCGS Food Safety and IFS Food

 

IFS PACSecure

The IFS PACSecure Standard isn’t that well known, so let’s just cover its background a little before we start.

IFS PACSecure is a Standard that’s been developed jointly between IFS and also PAC, which stands for Packaging Association of Canada, and is now known as PAC Packaging Consortium.

You can learn more about who PAC are here.

Comparison

Right, onto the comparison. We’ll follow the same format and the information will be divided into three main headers:

  1. What’s new
  2. What’s different
  3. What’s not included

 

Again, ‘Topics not included’ only highlights the big changes. If you’re moving from BRCGS to IFS you’ll be over compliant, so we’re not going to worry about the little changes at this stage.

 

What’s new What’s different Topics not included
1. Senior management commitment
Senior management need to ensure that the QMS is reviewed annually, and whenever there is a change. And, this must be data driven based on verification measures.

There must be a review each year to create an investment plan for infrastructure and the working environment.

There must be an IFS PACSecure representative.

The technical team must have a direct reporting line into senior management.

There must be a procedure for handling external visits.

There must be a procedure for reporting of incidents to customers, including regulatory notices.

Job descriptions are needed.

Topics for the policy include environmental responsibility and sustainability.

 

 

Culture

Whistleblowing

 

2. Document management
A procedure which covers customer expectations and objectives.

Customer contracts are required.

Amendments must be carried out by authorised personnel.
3. Continuous improvement
Procedure for management and verification of corrective actions.

There must be a procedure for management of non-conforming products and notifying relevant parties.

Complaints investigations are required.

The term ‘corrective action’ seems to be used when referring to both corrective and preventive actions. However, the term preventive measures is also used, which is confusing.

There is no definition for preventive measures, but the definitions provided are:

Correction: Action to eliminate a detected non-conformity or deviation.

Corrective action: Action to eliminate the cause of a detected non-conformity, deviation or other undesirable situation.

Root cause is not mentioned.
4. Contingency
Customers need to be notified in the event of serious incidents.
5. Hazard analysis
The HACCP team must have strong senior management support and be well known by staff.

 

 

The scope of the hazard analysis doesn’t mention quality.
6. Contamination control
Controls for recycled water.

Controls for non-potable water.

Breakage procedures for glass containers are required.

Allergen management is required.

Process controls for “free from” products are required.

Strongly scented chemicals.

Controls are based on risk, so there are no specific requirements for sharps, pens, debagging or deboxing, metal detection, filters or sieves, glass containers etc.

7. Product development
Hazard analysis principles must be used to manage product development.
8. Supplier management
There is no prescriptive method for approval of suppliers.
9. Testing
Library samples to be kept where required by the customer.

Labs must not pose a risk to product.

Trending of lab results is required.

Where testing is carried out in-house, staff must be trained.

Calibrated equipment should only be used for it’s intended purpose (e.g. don’t use a probe for opening things).

Where required by the customer taste panels must be carried out.

Nutritional verification. Environmental monitoring.
10. Maintenance
Equipment must be fit for purpose, designed so that it can be cleaned and maintained and commissioned prior to use.

Product contact materials must be suitable for food use.

Change control.

Equipment failure should prompt a PPM review.

11. Product defence
Vulnerability assessment includes packaging.

Product defence team with responsibilities is required.

Access control is required if determined by risk assessment.

Tamper procedures.

Product security should be included in visitor, contractor and driver procedures.

12. Training
13. Personnel
H&S risk assessment and controls are required for personnel. Personal hygiene, PPE etc. rules are applied based on risk.
14. Site Standards
Ventilation, air conditioning and dust extraction systems must be maintained.
15. Microbiologically controlled facilities
n/a n/a n/a
16. Hygiene
Cleaning staff must be trained and retrained at a set frequency.

Verification of cleaning is required.

Cleaning procedures must be reviewed where there are changes.

Cleaning should be carried out in such a way as to not pose a risk to product.

Waste management procedure required.

Waste containers must be fit for purpose, clearly marked, cleaned and maintained.

Pest control is not prescriptive but should be applied based on risk.
17. Process control
Validation of process controls.

Procedures for process deviations and where equipment malfunctions.

Product monitoring to meet the specification.

Right product right pack controls required.

Quantity control required.

Much more focus on the practicalities of making sure the process works – based on data.

 

Traceability test must be performed following changes to the system.

18. Storage & distribution
Temperature monitoring of the internal temperature of the vehicle during transportation.

Quarantine procedure required.

Summary

  • Like the food comparison IFS is a lot less wordy than BRCGS.
  • The IFS Standard is proving to be very consistent across the different subjects. Because it’s based on risk, the application of the Standard is the same.
  • IFS isn’t as prescriptive as BRCGS, so it’s open to interpretation (rightly or wrongly).
  • There is no interpretation guide for IFS.
  • The IFS Standard focuses much more on the site understanding their own risks and developing systems to meet them, rather than describing what’s right.
  • Process control is much more robust in the IFS Standard, as it’s driven by data and validation to ensure that the product meets specification.

In summary the changes which are required to move to IFS PACSecure seem to make sense and are all based on risk. There are some really important additions, such as glass container control – so you have to make sure that broken glass containers during the manufacturing process do not contaminate the product. Meaning that the food sites shouldn’t receive contaminated packaging that they then use to fill with food.

What do you think?

So, what are your thoughts on IFS and the work that would be needed?

What do you think about the additional requirements?

What do you think about the topics that are not included?

Share your thoughts with your fellow techie’s and add them to the comments box below.

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