In this article we’re going to cover the changes to the packaging HACCP for BRC Packaging Issue 6 or hazard and risk management system as BRC now call it.


The first thing to mention is that quality has been removed from section 2. This is a little confusing, as BRC have now added it to section 5.4 instead.

Clause 5.4.1 now requires a quality hazard analysis, so you still need to do a risk assessment, it’s just not in section 2 anymore. That doesn’t mean you can’t include quality in your product safety hazard analysis, you can – that’s fine. It’s just BRC have decided to move the requirement.

The other confusing thing is that the packaging HACCP team still need to do the quality hazard analysis. So, you’ll find that section 2.1 which is all about the hazard analysis team – still talks about quality.

Packaging HACCP team

The hazard analysis team (or HARA team as BRC refer to them) need to complete a hazard analysis that covers:

  • Product safety hazards, as required for section 2
  • Legal hazards, again required for section 2
  • Quality hazards, required by clause 5.4.1

If you’re a basic hygiene site, you now need to document who is the team leader for the team. And, the team also need to be able to demonstrate that they understand HACCP principles. You can do this by completing external HACCP training, or they can be trained by someone on site who has a HACCP qualification and also has a training qualification.

The Standard doesn’t state what level of training the team must have, but we would recommend at least level 2 and ideally the team leader should have level 3.


BRC have now said you need to include hazards that are known and also hazards that are foreseeable. This means that you need to include hazards that have happened before. Hazards that are known to happen, even if they haven’t happened to you. And also, hazards that you would consider to be plausible, so ones you can imagine would happen.

There are few new additions to the events that may cause hazards. You now need to consider how the consumer may abuse the product you send to the customer. So, if you provide a plastic container that can only handle cold product, what would happen if they filled it with hot product for example?

Hazards relating to raw material fraud is now also a requirement, so you would need to consider if someone could supply you with substituted materials. However, you now need to complete a vulnerability assessment for fraud, for section 3.8 Product Authenticity, Claims and Chain of Custody. Now, there’s no point in assessing the hazards for fraud twice, so we would recommend you just do it in your vulnerability assessment and state this in the scope of your packaging HACCP.

And for finished product, you also now need to include hazards for malicious contamination. But again, you also need to do a threat assessment for section 4.4, so we would recommend you only do this once – in your threat assessment. Then reference the threat assessment in the scope of your packaging HACCP.


In your packaging HACCP you now need to write a description of the process. The best way to do this, is to describe what happens at each process step on your flow chart. We do this by literally listing each process step on the back of your flow chart and then detail all the important points about that process step.

If you would like help with your packaging HACCP we have a pack that you can use, or one of our lovely consultants can come and help you put it together.

Or you could become one our amazing Techni-K Smart Clients and get both – all of our documentation and consultant visits to help you! Interested? Then drop us an email with your requirements.

Have your say…

One thought on “Hazard analysis for issue 6 – is quality included?

  1. It was really helpful to read how to address the different requirements for hazard analysis for safety and legality (section 2) and for quality (section 5) as it was very difficult to fathom out what was meant in the Standard, because quality was mentioned in section 2 a couple of times.

Share your thoughts…

Your email address will not be published.

We've tagged this article as: