Well – where do we start! This article, is going to open a whole can of worms (and that’s putting it politely!)
In issue 5 of the packaging standard, the standard was split into two distinct parts; high hygiene and basic hygiene. For issue 6 of the packaging standard, BRC have now combined all the clauses into just one standard.
When BRC produced the clauses of the new issue 6 standard, they used all of the high hygiene clauses to do this. Not the basic hygiene clauses.
Then, they produced a key changes guide, which helps sites to understand what the changes are from issue 5 to issue 6. Which is great, because you can then clearly see which clauses are new and so, you can use this to update just the new bits into your systems at site.
Because the key changes document compares the clauses from the high hygiene section of the standard with the new clause for issue 6, it means that any changes from the basic clauses to the new clauses have been missed.
To explain what we mean, let’s look at an example:
Here you can see in the interpretation guide for issue 5, the high hygiene clause and the basic hygiene clause are shown side by side.
Source: BRC Issue 5 Interpretation Guide
For the same clause, the requirements are different. The high hygiene clause is more detailed, with the difference shown in yellow marker.
Now, if you look at the Issue 6 Key Changes document for the same clause you can see that BRC have shown that there are no changes.
Source: BRC Issue 6 Key Changes Guidance
Which, if you’re a basic hygiene site, isn’t right – as there are changes between the issue 5 basic clause and the issue 6 clause.
This means there is a huge risk, of basic hygiene sites missing the changes that are applicable to them, and so, they’re at risk of getting many, many non-conformances in their issue 6 audit.
I’m not sure if BRC have realised, what they’ve done here. My concern is that their training will only focus on the changes highlighted in the key changes document. Which we nearly did, until we realised the problem – so we’ve now had to go back to the beginning and amend the course, to make sure it includes the changes for basic hygiene sites as well.
Moving from issue 5 to issue 6 incurs a lot of work. Now for basic hygiene sites, this is even more challenging. There are many risk assessments to do, to justify your controls, which we talked about in the previous article: BRC Packaging Risk Assessments galore – 46 to be exact! Plus, reviewing your basic hygiene management system, with the requirements of the high hygiene requirements is going to take a lot of time.
And there’s more problems…
As we’ve gone through the standard to develop our Issue 5 to 6 Packaging Conversion Course, we’ve noticed so many errors and confusing statements, which may cause delays to the implementation. The most concerning thing we’ve noticed is that there are now requirements in the interpretation guide that are not in the clauses themselves – which is going to really trip people up!
Given that we’re now only 4 months away from go live for issue 6, there’s not much time…
Help is on it’s way
We will, in the forthcoming articles cover the things we’ve noticed that we think you need to be aware of, when updating your systems – so that you don’t fall foul of the problems we’ve encountered.
And, when we’ve finished our conversion course, we’re then going to move onto producing tools for you to help you update your systems to issue 6. And don’t worry – we won’t be doing a ‘one fits all’ solution, we’ll do one set for basic hygiene sites and one set for high hygiene sites, so that you don’t have to muddle your way through the differences!
We’d love to know your thoughts on this, please add your feedback and comments in the reply box below.