BRC/IOP

BRC/IOP Technical Standard

for Companies Manufacturing
& Supplying Food Packaging
Material for Retailer Branded
Products

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Background

UK Retailers & their suppliers of retailed branded
products must take “all reasonable precautions &
exercise all due diligence”, in development,
manufacture, distribution, advertising or sale of
food products to consumer.

Suppliers of packaging to UK retailers, which now

become global retailers, or suppliers of packaging
to food manufacturers, have obligation to put
appropriate systems and & controls in place to
ensure suitability of their packaging for safe food
and safe product use.

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The British Retail Consortium

The BRC is
The trade association
Represents the retail trade in UK.
Its members operate a variety of outlets from large
multiples & department stores through to corner
shops.
Directly involved in a number of important issues
affecting retailing & consumer, including food
safety

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The Institute Of Packaging

The IoP
Was established in 1947
As professional membership for packaging
industry, is of central importance
Provides membership services, learning
opportunities & commercial activities for people in,
& associated with, wider packaging industry.
Member of the IoP are drawn from all sectors of
industry.

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Background

In 2001,
The BRC & The IoP developed Technical Standard
& protocol for companies manufacturing &
supplying food packaging materials for retailer
branded products.
To assist retailers & food manufacturers in
fulfilment of their legal, technical, hygienic obligations.
The standard was introduced to help in protection
consumer by providing a common basis for
evaluation of companies supplying packaging for
food products to retailers.

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Development of the Standard

This standard hails as a first for the packaging

industry

Provides common ground on auditing

Brings quality & hygiene standards under one
umbrella

Means a single audit for packaging manufacturers

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Development of the Standard

It is hoped that the standard will cascade through

the packaging industry

Retailers will require their contract packers to
ensure all of their packaging manufacturers are
accredited

The Standard requires them to ensure their
suppliers are up to an adequate standard

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Development of the Standard

The new Standard is designed to be dynamic

Regular Standard updates will be carried out

A Standard review body will sit every six months
& look at problems that have arisen

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What are the Objectives?

To ensure all food packaging manufacturers are

satisfactory in both hygiene & technical matters

To ensure all packaging users are able to trust their
packaging material to be hygienic & consistent

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What are the Objectives?

The Standard is based on both pre-requisites &

risk assessment

Control of Hygiene in every aspect of a production
unit

Ensure consistent adherence to a specification

Covers and defines high & low risk areas

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Who were Involved?

Institutions

United Kingdom Accreditation Services (UKAS)

The Institution of Packaging (IOP)

The British Retail Consortium (BRC)

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Benefits of the Standard

Removes “burden” of “routine” visits

Broad base standard, including; quality & hygiene

Requirement for on-going surveillance

Focusing on process improvement

The standard covers issues that are also covered
within an ISO 9001 standard

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BRC- Standard Contents

Scope

Organization

Hazard & Risk Management System

Technical Management System

Factory Standards

Contamination Control

Personnel's

Risk Category Determination

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BRC – Technical Standard

The BRC Standard is divided into two levels, in
consideration of the supplied

Category A - Non Food Contact Packaging

Category B – Food Contact Packaging

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1. Scope:

Management Procedures

Factory Standards

Implementation of Hygiene Management System

Establishment of Quality Management System

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1. Scope:

The standard applies to

Manufacturing of converted packaging used in
food packaging & filling operations Prior
converting operations
Operations that supplying packaging material from
stock where additional product processing or
repacking occurs

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1. Scope:

The standard also applies to
Consumer disposable goods that come into contact with
food that made from packaging materials or material
intended for food preparation
For examples:
- paper plates,
- disposable plastic drinking cups,
- aluminium foil,
- food grade parchment paper,
- cling film and
- disposable cutlery

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2. Organization:

Responsibilities for implementation & maintenance of
standard shall be defined

Verifiable evidence of acknowledgement

A Designated personnel within the structure of the
organisation shall be appointed as system coordinator
1. Qualified
2. Suitably senior
3. Deputy (delegate responsibility in his absence)

Management review system (can be integrated with QMS)

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3. Hazard and Risk Management

Conduct a hazard analysis

Customer specific hazard analysis

The hazard analysis shall incorporate the
following steps

Establish validated plan of process

Identify and record the hazards

Assess the level of risk

Identify the critical steps

Define exclusion

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3. Hazard and Risk Management

Confirm process control and monitoring
procedures

Establish documentation and records to maintain
process control

The controls shall be reviewed, verified and
validated.

Measure to monitor critical process step shall be
implemented

Procedures shall have senior management
commitment

Verify the procedures during internal audits
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4. Technical management system

4.1 Technical management policy (quality
and hygiene policy)

Company’s intention to product safe and legal
products

Documented, Understood, Implemented and
Communicated

Reviewed at regular intervals

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Exercise: - 1

Each question carries 5 marks, max time 15
min.

BRC……………IOP…………..

BRC/IOP standard for ………………..

Scope of BRC/IOP (define five products covered
by this standard)

Define Category A and Category B

Define your food packaging safety policy

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4. Technical management system

4.2 Quality manual

Manual to demonstrate compliance to this
standard

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4. Technical management system

4.3 Record keeping

Records of product
Maintenance
compliance
Control of non production

Training glass and brittle plastic

Cleaning schedules and
Control of sharp and
cleaning records blades

Contamination
Product recall

Customer complaint
Non conforming goods

Internal auditing
Traceability

Pest control

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4. Technical management system

4.4 Documentation control

Documented procedure

Authorised

Current version

Legible

Accessible

Changes controlled

Control of obsolete documents

Retention

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4. Technical management system

4.5 Specification

Raw material (COA)

Intermediate product

Finished product

Specification where appropriate for food contact

material shall be agreed with the customers

Specification review procedure

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4. Technical management system

4.6 Management of Incidents & Product Recalls:

Guidance on events that would constitute an incident

Documented incident reporting procedure

Documented recall procedure

Customer notification

Product re-call at all stages of production

Verification of recall system

Control of non conforming product

Corrective & preventive actions

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4. Technical management system

4.7 Traceability:

Raw materials

Work in progress

Finished goods

Product identification at all stages of production

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4. Technical management system
4.8 Process Control:

Sufficient & appropriate controls to monitor and
control critical defects

Segregation of raw material, work in progress &
finished goods

Process & equipment verification

Legal compliance

Equipment calibrated & traceable to National
Standard

Control of raw material supply
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4. Technical management system
4.9 Internal Audits:

Programme of audits in consideration of risk

Trained & independent auditors

Documented results of audit

Review of audit results

Corrective & preventive action

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4. Technical management system
4.10 Compliant Procedure:

Documented system for complaints

Management team shall analyse customer
complaints and implement corrective & preventive
actions (no reoccurrence)

Complete records of action taken and effective
closure of customer complaint.

Monitor customer complaint trends

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4. Technical management system

4.11 Supplier Monitoring:

Evaluation & selection of suppliers

Define selection criteria for suppliers

Assess capability to supply conforming product

Maintain an approved supplier list

Measurement of supplier performance

Verification of supplier claims/ approvals

Supplier audits

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4. Technical management system

4.12 Sub Contracting of Production:

Effective control of sub-contracting

Include hazard analysis

Identify responsibility

Verification of Subcontractor Technical Systems

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4. Technical management system

4.13 Product Analysis:

Reliability of Test Results (RUT)

Qualification/competency of quality personnel

Accredited Sub Contracted Laboratories ( or other
body)

Agreed & documented Test Methods

Compliance with Specifications

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5. Factory standards

5.1 Perimeter & Grounds:

Unobstructed Access & Debris Free

Defined External Eating Area

Access Point Proofed

Protected Appropriate Drainage System

Traffic Routes Surfaced (tarred)

Protected external Storage

Designated Refuse Collection Areas

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5. Factory standards

5.2 Layout & Product Flow:

Prevention of Cross Contamination (tags and
labels)

Control of work in progress

Product handling and sorting in designated areas
(Conditions shall be same as production area)

Designated personnel route for entry to production

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5. Factory standards

5.3 Building Fabric:

Sound construction

Suspended ceiling accessible

Adequate lighting

Cleaning schedules for internal surfaces

Walls capable of being cleaned

Internal drainage trapped

Sufficient ventilation

Proofing of ventilation opening

Proofed against pest ingress

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5. Factory standards
5.4 Maintenance of Equipments:

Well maintained

Cleaning schedules

Wooden equipment

Minimized use

Good condition

Properly sealed

Notice boards

Temporary engineering

Documented hygiene clearance

Contract maintenance shall be supervised
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5. Factory standards

5.4 Maintenance of Equipment:

Planned maintenance programs

Control of compressed air

Use of tape engineering

Operate to hygiene, health & safety requirements

Control of contractors

Post maintenance checks

Documented post maintenance checks

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5. Factory standards
5.5 Housekeeping & Cleaning:

Clean as you go policy

Cleaning schedules

Item to be cleaned

Frequency

Method

Cleaning materials

Responsibility

Cleaning records checks

Use of approved cleaning detergents

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5. Factory standards
5.5 Housekeeping & Cleaning:

Monitoring of effectiveness

Storage of cleaning equipment

Control of stationery

Cleaning chemical tagged and labeled

Toilet cleaning products segregated

Control of tool & maintenance equipment

Control of workstations to prevent product contamination

Suitable storage facilities for workstations

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5. Factory standards

5.6 Waste & Waste Disposal:

Minimize accumulation of waste in production

Use of appropriate containers

Disposal of putrescible waste (lined & lidded)

Disposal of Trademarked waste

Use of licensed waste contractors

Collection of recycling waste

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6. Contamination Control:

6.1 Foreign Body Control

Staff training

Written policy for glass & brittle plastic

Glass & brittle plastic register

Written policy for “sharps” control

Issue & control of “sharps”

Snap off knife blades banned

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6. Contamination Control:

6.2 Chemical & Biological Control:

Chemicals, cleaning materials, lubricants &
adhesives controlled to prevent product
contamination

Aseptic control systems where required shall be
controlled

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6. Contamination Control:

6.3 Pest Control:

Formalized preventative programme

Use of approved contractors for pest control

Windows screened

Records & location of pest control baits

Correctly sited EFK’s

Layout of baiting points

Follow up actions

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6. Contamination Control:

6.4 Transport, Storage & Distribution:

Finished product protected

Product movements between premises

Checking of wooden pallets

Control of contract haulage, hygiene checking

Written contract with haulers

Integrity checks of Raw material

Documented checks of Raw material

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6. Contamination Control

6.4 Transport Storage & Distribution contd…

Non conforming products

Vehicle drivers

Clean & suitable transport

Cleaning programme for vehicles

Pre loading checks for vehicles

Control of off site storage

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7. Personnel

7.1 Access & Movement of Personnel

Designated entrances

Site security

Designated walkways

Logical movements

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7. Personnel

7.2 Locker Rooms:

Provision of lockers

Access to locker room & overall/ protective
clothing segregation

Control of eating, smoking & drinking

Food control

Visitors & contractors facilities

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7. Personnel

7.3 Toilets & hand Washing:

Hand wash facilities

Advisory signs

Hand wash disciplines

Hand wash disciplines entering production areas

Hand wash facilities at entrances to production
area

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7. Personnel

7.4 Facilities for eating, Drinking & Use of

Tobacco Products:

Prohibited within direct production areas

Provision of facilities

Facilities for smoking- internal or external

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7. Personnel

7.5 Personal Health:

Illness notification / return to work

Medical questionnaires for visitors/ contractors

Covering of cuts with appropriate dressing

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7. Personnel
7.6 Jewellery & Personal Items:

Jewellery policy-

Plain band rings, sleeper earrings

Wrist watches shall not be worn

False nails & nails varnish

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7. Personnel

7.7 Protective Clothing:

Appropriate clothing

Appropriate clothing ( spares)

Hair covered to prevent contamination

Self care protective clothing

Approved laundry services ( Contractors)

Segregation of clean & dirty clothing

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7. Personnel

7.8 Hygiene training:

Introduction training

Formal basic hygiene training

Refresher hygiene training

Training records

Contractor & visitor hygiene procedures

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Exercise: -2
Question one carries 4 marks rest 3 marks,
max time 20 min (If your answer is false
why?)

Define you glass and sharp policy

Hands shall be washed before entering the
production area: - T/F

Snap off blade knives are suitable for slitting: - T/F

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Exercise: -2

Truck drivers can enter the production without any
hygiene checks : - T/F

Employee can directly report to work after a long
leave : - T/F

After equipment maintenance the equipment can
directly be used for production : - T/F

Visitors can wear wrist watch, diamond rings, false
nail varnish, etc. : - T/F

Personnel with open wound shall be allowed to
handle the product : - T/F

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Protocol

Certification Bodies:

Only Accredited Certification bodies to EN45011 with the
appropriate scope, shall carry out evaluations against the
BRC Standard, & issue certification

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Protocol

Before the initial evaluation

The Suppliers is required to review the BRC Standard

Make any necessary amendments or improvements to its
operation & systems

Provide background information on the site concerned, by
completion of a pre-evaluation questionnaires or pro-forma
information sheet

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Protocol

The scope of the evaluation shall be defined between the

Supplier & the Certification Body

The scope shall be identified in the evaluation report & any
certificate of inspection

The Supplier may contract the Certification Body to
evaluate maters beyond the scope of the BRC Standard,
but no relevant elements of the Standard shall be omitted

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Protocol

Evaluation procedures

Duration of evaluation will be dependant upon a number of
factors but due regard must be given to;

Size of the site

The types of processes to produce & store product

Number of product lines

The number of non conformance’s as recorded in previous
evaluation

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Protocol

At all evaluations there are four elements, which shall be

carried out;

Opening meeting

Review of quality systems & procedures

Site inspection

Closing meeting

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Protocol

Critical Non-Conformance

There is a critical failure to comply with a food safety or
legal issue

This would constitute a critical non conformance & the
Company would not gain certification until the non
conformity had been corrected & corrective action verified
by the certification body

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Protocol

Major Non- Conformance

There is substantial failures to meet requirements of a
statement of intent & any mandatory clause of the Standard

The Certification of approval will only be awarded where
the Certification Body has evidence that all major non
conformities have been rectified

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Protocol

Minor Non- Conformance

This is where absolute compliance to the statement of
intent & a mandatory clause has not been demonstrated,
but the basis of objective evidence the conformity of the
potential product safety & legality is not in doub0t

A certification of approval may be awarded before
outstanding non conformities are corrected, where a
documented statement of intent to address the issue raised,
giving dates by which rectification or changes will be
made, is provided to the certification body

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Protocol

Recommendation

There is a failure to meet a recommendation of good
practice

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Protocol

The report contains the following sections

Evaluation details

Evaluation summary- overview of performance

Details of non- conformance & corrective action plan

Detailed evaluation report

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Protocol

Evaluation Visits
Category A- initially 6 months
Category B- initially 6 months

Where companies have been evaluated & found to have no
major non conformance then the evaluation frequency will
be raised to 12 months

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The Standard Requirements

What to do next:

Make sure your factories are up to the requirements of the
Standard

Become accredited under the packaging Technical
Standard

Ensure your suppliers are as good as you require by
insisting they become accredited

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