We are just under three months away from the start of audits to Issue 6 of the BRCGS Standard for Packaging Materials Issue 6. In this first blog of our series we examine what you should be aware of, to prepare for audit. The first audits to Issue 6 start February 2020.
Main changes from Issue 5 of the BRC Standard for Packaging Materials
Abolition of separate Hygiene Categories
The biggest change of all, for most, will be the combination of the previous Basic Hygiene and High Hygiene categories into one. This will be a bigger shock for those (estimated as 17%) of businesses who were audited under the Basic Hygiene Category. This does not necessarily mean that you will have to suddenly “adopt” all previous High Hygiene Requirements. There is facility in most sections to risk assess the need for and level of control required. This is the first cautionary tale of our blog. The Certification Body auditor will be expecting a level of documented risk assessment if trying to justify lower level of control.
Risk assessment to justify clause exemptions
To give an illustration of this, see the screen-capture from the Key Changes document available from BRC if you are certified or part of BRCGS Participate, here. This excerpt from the BRCGS Guide to Key Changes illustrates a change from Issue 5, wherein you could document exemptions within your Hazard and Risk Management Plan. Section 2.3 has now been removed from Issue 6. So the notes remind us that any exemptions must be supported by risk assessment.
Local guidance with The Standard
More locally within the Standard there is indication as to whether a clause applies. But this is not always clear. For instance, for clause 3.4.3 on the Declaration of Compliance. This now states, “Where packaging for food or other hygiene sensitive products is produced a statement of compliance shall be maintained….”. But you really need to read the comments section against this clause in the Key Changes document. This makes it clear that “because of the removal of different hygiene levels, this clause applies only to sites manufacturing packaging that will come into direct contact with food or other hygiene-sensitive products”.
What this illustrates is that there is a danger in just trying to do the job of converting from Issue 5 to Issue 6 with The Standard alone. So the Interpretation Guide and Key Changes Document are key to this job.
If you need help with Issue 6 of the BRCGS Standard for Packaging Materials just contact us. We can help with a full gap audit and plan for those starting their journey! We can conduct a review of your progress so far. Or we can perform some, or all, of your internal audits and help that way. Find out more here