This is the second in this series of articles, where we look at the FSSC22000 Standard and review it against the BRCGS Standard, for the three Standards that FSSC provide.

In the last article we focused on  FSSC Food review for implementationIn this article we’ll look at what’s covered in the FSSC Packaging Standard.

Before we dive into it, if you want to look at our previous series of articles comparing the BRCGS and the IFS Standards, they’re all here for you:

Comparison and gap analysis of BRCGS Food Safety and IFS Food
Comparison and gap analysis of BRCGS Packaging and IFS PACSecure
Comparison and gap analysis of BRCGS Agents & Brokers with IFS Brokers
Comparison and gap analysis of BRCGS Storage & Distribution and IFS Logistics

FSSC22000 Packaging

In the FSSC Food review for implementation article we explained that we can’t compare the FSSC and BRCGS Standards, in the same way that we did for IFS. Because it’s like comparing apples and pears. We also explained the benefits and pitfalls of going with the FSSC Standard.

For this reason, we’re not comparing the Standards, but instead we’re providing you with a summary of what is needed under each of the 18 topic headings.

The FSSC22000 Packaging Standard (including FSSC Quality*) is made up of the following:

  • FSSC22000 Standard
  • ISO9001
  • ISO22000
  • ISO/TS22002-4 (Technical specification for packaging)


Under each of the 18 topics, we’ve split a summary of the requirements for ISO (9001 and 22000), FSSC and also the packaging technical specification.

*FSSC Quality is required to make this Standard comparible to BRCGS

1. Senior management commitment


There must be effective communication systems in place. This includes receiving information from external sources and feeding that information through the relevant internal channels.

Senior management must ensure that a Quality Policy is in place, along with the resources to achieve it. Roles, responsibilities and management are required and there must be a system of continuous improvement including management review.

Management must appoint a competent person to manage the management system and this role must have the required authority to lead its continuous improvement.

2. Document management


Before the management system is developed there are a number of pieces of work that are needed, to establish:

  • What is the purpose of the management system.
  • What the management system is expected to achieve.
  • What the boundaries are to the system (scope).
  • Identify the risks and opportunities that need addressing.

Once this is done a plan must be put in place to:

  • Ensure that all the above points are met.
  • To develop and implement a change management system.
  • To set, communicate and then monitor objectives to ensure that the management system is effective.
  • Ensure that all the required resources are provided to achieve the above.

When the management system is developed or managed externally, the application and day to day management must remain the responsibility of the company.

There is a specific section for customer focus to ensure that customer requirements are met.

3. Continuous improvement


Non-conforming product process is required.

Internal audits are required.

Corrective and preventive actions are needed. Root cause analysis is not specifically mentioned but implied through the need to determine the cause of non-conformances to establish preventive actions.

Continuous improvement is a key focus and covers all aspects of the Standard.

4.  Contingency


Contingency plans for emergency situations and recall and withdrawal processes are required.

Packaging technical spec

Withdrawal procedures are required.


5. Hazard analysis


The hazard analysis system must include OPRP’s (operational prerequisites). Hazards do not highlight radiological specifically. Hazard analysis is required for food safety purposes only; quality does not require hazard analysis.

A process is required for handling products that are out of specification because they are unsafe.

6.  Contamination control


An allergen risk management system is required.

Packaging Technical Spec

  • Utilities must not pose a risk of contamination, including water, boiler chemicals, air and ventilation.
  • Microbiological, allergenic (staff food) and physical contamination controls must be in place.


7.   Product development


Labelling must meet the legal requirements for the country where the product will be sold.


A product development process is required which ensures that quality objectives and customer requirements are met, including:

  • Planning
  • inputs and outputs of the system
  • review
  • verification and validation
  • and change management.

Packaging technical spec:

Compliance to customer requirements and also specifications is required.


8.  Supplier management


Where suppliers are used for systems, products or services which relate to the management system they must be selected based on set criteria and then monitored.

The system must verify that purchased materials comply with specification.

Packaging Technical Spec

Supplier selection, approval and monitoring is required.


9.  Testing


External labs used for product safety testing must comply with ISO17025 requirements.

A risk based environmental monitoring programme is required for food and packaging sites.

A system of monitoring, measuring and analysis needs to be implemented, which ensures that the product and process meets specification.

Monitoring equipment must be accurate.

Customer satisfaction must be measured.

10. Maintenance

Packaging Technical Spec

  • Equipment must be of a hygienic design.
  • Planned preventive maintenance is required.


11.   Product defence


Both a threat assessment and also a vulnerability assessment is required. There is now a new FSSC guideline about how product defence should be handled, which is similar to an interpretation guide.

Packaging Technical Spec

There must be controls in place for food defence and to prevent bioterrorism.


12.  Training


Personnel who work internally or who support externally, must be competent in their role. The company must set the competency required and then ensure that this is met.

Competency must include an understanding of:

  • The food safety policy.
  • Objectives application to their role.
  • How they contribute to the management system.
  • The benefits of getting it right and the consequences of getting it wrong.


13.  Personnel


There is a specific section of the Standard about resources. To ensure that the required resources are provided to meet the needs of the management system and in the case of personnel, they must be competent.

It also states that the work environment that is provided for personnel must be suitable.

This means it must be suitable from:

  • An ethical perspective (e.g. regarding discrimination).
  • A physiological perspective (e.g. mental health).
  • A health and well being perspective (e.g. noise, temperature).

Packaging Technical Spec

  • Hygienic staff facilities must be provided, including staff eating areas.
  • Personal hygiene and behaviour rules must be set.
  • Protective clothing must be appropriate and to a hygienic standard.
  • Medical screening is required.

14. Site standards


Also within the resources section, the company must provide the resources needed to ensure that the physical infrastructure of the site is fit for purpose and maintained.

Packaging Technical Spec

  • Building construction must be fit for purpose and maintained.
  • Assessment of the local area must be carried out.
  • The site must be maintained.
  • Layouts and flow must adhere to good hygiene practices.
  • Internal fabrication must be fit for purpose and maintained.
  • Equipment must be located so that it is hygienic.
  • Temporary or mobile buildings must not be a source of contamination including pests.
  • Lighting must be adequate.

15. Microbiologically controlled facilities

Not mentioned specifically.

16. Hygiene


Customer property (product) that is unsuitable for use must be controlled.

Food Technical Spec

  • Waste and drainage must be managed hygienically.
  • A cleaning programme is required.
  • Cleaning of product contact surfaces, plant, utensils and equipment must be cleaned at defined frequencies and to a hygienic condition.
  • Cleaning must be verified as effective.
  • A pest management system is required.


17.  Process control


Operational processes are required, suitable to the operation. This includes traceability.

Packaging Technical Spec

Rework and its use must be controlled.


18. Storage & distribution


Transport and system conditions must minimise the risk to product.


A positive release process is required.

The product must be preserved and protected.

Packaging Technical Spec

  • Materials must be protected from contamination during storage and transport.
  • Vehicle checks must be carried out.
  • Warehousing and transport environmental conditions must be controlled.
  • Waste and chemicals must be stored separately.
  • Stock rotation must be in place.



  • FSSC requires the implementation of many documents; FSSC22000, ISO 22000, ISO 9001 and for food ISO22002-4:2009 (please note; when we refer to ‘FSSC’ in this summary we mean FSSC and all the associated documents).
  • When reading through the different sections and requirements, there’s nothing really that stands out as different – other than needing aspects such as OPRP’s.
  • The way a management system for FSSC needs to be put together is totally different to BRCGS.
  • It requires a great deal of initial preparation and much more focus on establishing and developing the needed controls.
  • There is a ‘flow’ throughout the Standard. Everything you do for FSSC has a purpose; an input and an output. The output of which then leads into the input of the next requirement.
  • This ‘input and output’ theory could be drawn as a flow chart and is a totally different way of thinking from BRC.
  • The language used in FSSC is difficult to read and understand.
  • The requirements are very brief as they are all based on risk, so it’s very open to interpretation (rightly or wrongly) and there is no interpretation guide.

What do you think?

So, what are your thoughts on FSSC 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.

Have your say…

One thought on “FSSC Packaging review for implementation

  1. I have a lot of experience with FSSC 22000 and would like to make the following comments. Many companies have already implemented ISO 9001:2015 and feel very comfortable with the structure of ISO 22000, since both standards follow the same higher-level structure.
    It is true that the company has to work out many things in a risk-oriented way, but this also gives the opportunity to build a system that fits the company and is better accepted by the employees. The disadvantage is that there will be endless discussions until everyone in the company takes the word “risk-oriented” seriously and does not pick out a loose standard in the vague description of the preventive measures in ISO 22004-4.
    I have to veto it when it is said that the requirements of ISO 22000 are analogous to the BRC Packaging Standard. Especially in the part supplier management the ISO 22000 does not have the regular requirements of the BRC Packaging Standard. This passage in the BRC leads precisely to the fact that many in Germany turn away from the BRC, because the suppliers are not willing to submit to the requirements for GFSI certification or an audit or a questionaire.

    Best regards

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