Identifying the main differences between Packaging Materials Issue 5 and the new version Issue 6

OK! So BRCGS Packaging Materials Issue 6 has been out there since 01 August with the first audits due to take place commencing 01 Feb 2020. The Standard continues to evolve and raise the bar by harmonising with requirements from the Global Food Safety Initiative.

Further revisions originate from consultation and input from industry-category experts. As always, the evolution of a good compliance standard needs to be practical and it must not throw up compliance barriers which are unrealistic and difficult to put into practice.

There is a significant emphasis on better risk management in the shape of Hazard Analysis Risk Assessment (HARA) and preventing, eliminating or reducing product quality hazards.

To make meeting the new standard as straightforward as possible, it is really useful to know which clauses are new or updated in the new version.

The idea that we can help make compliance as straightforward for you as possible works on the assumption that the unchanged ones should be fine, as long as you are already compliant with PM Issue 5. This allows you to focus on the new or updated clauses and close those gaps, if any, in order to meet the standards of Issue 6.

Overview of the key changes

The main changes from Issue 5 to 6:

• Introduction of a new clause on ‘culture’ becoming auditable from February 2021 (See more details below)
• New fundamental requirement: 3.6. Corrective and Preventive Action (focus on root cause analysis)
• Better raw material management: Partly intended to reduce risks of contamination of the human food chain.
• Consolidation of the two previous hygiene categories (High Hygiene/Basic Hygiene) to simplify the hygiene requirement based on risk. Categories are removed). This is particularly important to you if you were Basic, as you now have more work to do to comply with Issue 6.
• New section: Traded Products

New Clauses:

• 1.2 Product safety and quality culture
• 1.10 BRC Logo
• 2.6 Elevated walkways
• 5.5 Hygiene audits
• 6 Corrective and Preventive Action
• 8 Product Authenticity
• 9.5 Outsourced process traceability
• 11.6 Traceability of test data and samples
• 8.5 Microbiological environmental monitoring programme
• 4 Process control (added sub-clauses)
• 6.9 Automated inspection equipment

A special word on culture

It’s is worth highlighting that clause 1.1.2 does not start getting audited until Feb 2021. Auditing product safety and quality culture is already applicable to food safety in last year’s Issue 8, but, for Packaging Materials it has been deferred for a year to allow further planning, review and implementation by packaging manufacturers.

This may seem a long way off, but you are going to need to demonstrate you have assessed your position and tried to address the requirement. So, you need to start working on it as soon as possible. Food manufacturers tell us that this clause is their biggest headache for the Food Safety standard, so we can expect it to be a similar challenge for Packaging.

BRC for Packaging and Packaging Materials Issue 6: Clause 1.1.2

The site’s senior management shall define and maintain a clear and effective plan for the development and continuing improvement of a product safety and quality culture. This shall include:

• Defined activities involving all sections of the site that have an impact on product safety and quality
• An action plan indicating how the activities will be undertaken and measured, and the intended timescales
• Be prepared for BRCGS Packaging Materials Issue 6 with BRC Gap Analysis. A review of the effectiveness of completed and ongoing activities 

We hope this top high-level view of the major differences between BRCGS Packaging Materials Issues 5 and 6 helps you to focus your energies. With only around 4 months until auditing against Issue 6 commences, the clock is running down.

BRC Gap Analysis offers a unique solution, helping you to tackle compliance with greater efficiency and certainty. It is the only tool currently on the market dedicated to the specific purpose of achieving packaging compliance.

We strongly recommend experiencing the system for yourself first-hand so you can see how it helps you tackle your packaging compliance challenges. Simply register for the free trial. There are no strings attached and no credit card is required.