BRC/IOP A new standard for the Food Packaging Sector Siobhan Walsh Bsc., Food Supply Chain Specialist, Team BDS

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1 BRC/IOP A new standard for the Food Packaging Sector Siobhan Walsh Bsc., Food Supply Chain Specialist, Team BDS Siobhan Walsh has over 12 years experience implementing a range of systems and standards within the food supply chain including HACCP, EFSIS, ISO, BRC and more recently this new standard, BRC/IOP Manufacturers and suppliers of packaging materials are an integral link in the food industry supply chain. Up to recently however, this sector has not been subjected to the same level of certification requirements regarding hygiene and food safety as the food manufacturing sector. With the launch of the BRC/IOP technical standard in late 2001, this is no longer the case. Food safety and hygiene is certainly not new to the food packaging sector. Customer audits and evaluation questionnaires are increasingly referring to HACCP (Hazard Analysis & Critical Control Points), cleaning procedures and more recently the BRC/IOP standard. For many food packaging companies, customer reference to BRC/IOP Certification has now become a demand. One of the first manufacturers to request BRC/IOP certification was Cuisine de France Ltd. A market leader in the premium bakery products sector, Cuisine de France was the first bakery in Ireland and the UK to achieve higher level EFSIS certification (European Food Safety Inspection Service). To continue to assure their consumers of consistently safe products, the company has formally requested their packaging suppliers achieve BRC/IOP certification. So where has the standard come from? The British Retail Consortium (BRC) is a trade association representing approximately 90% of retailers in the UK including the major multiples like Tesco. They provide guidance and support to their members in areas such as legislation, food safety, retail crime, e-commerce etc. In relation to food safety, the BRC has developed a range of technical standards to assist their members in meeting their legal obligations to protect their customers. These standards serve to provide a common basis for inspection of suppliers. The BRC and the Institute of Packaging (IOP), in consultation with retailers, food producers and packaging companies, developed a specific technical standard for the packaging sector and hence the BRC/IOP standard was born. Who does the standard target? The standard applies to manufacturers and suppliers of converted packaging for use in food packaging or filling operations, for example: Flexible films Bags paper, plastic, laminates Corrugated cases Cartons

2 Trays Bottles Cans Consumer disposables plates, cups, cutlery, straws Contact / Barrier sheets What is involved? The BRC/IOP technical standard is essentially a list of management procedures and factory standards to be implemented by food packaging organizations. The ultimate objective of the standard is to minimise the risk of contamination of foodstuffs. The main requirements include the maintenance of a hazard analysis system, technical management system and control of factory standards, processes and products. In addition the standard specifies requirements in relation to personnel including staff facilities, personal hygiene and training. The layout of the standard is quite straightforward with requirements detailed under the following headings: Organisation Resources and management commitment Hazard & Risk Management System Implemented HACCP programme developed in accordance to 7 HACCP principles (Codex Alimentarius) Technical Management System Documentation control Specification Control Management of incidents and product recalls Traceability Process Control Internal Audits Complaints Procedure Supplier Monitoring Sub Contracting of Production Product Analysis Factory Standards Perimeter and Grounds Layout and Product Flow Building Fabric Maintenance of Equipment Housekeeping and Cleaning Waste and Waste Disposal

3 Contamination Control Foreign Body Control (e.g. glass, hard plastic, metal etc.) Chemical and Biological Control Pest Control Transport, Storage and Distribution Personnel Access and Movement of Personnel Locker Rooms Toilets and Hand Washing Facilities Facilities for Eating, Drinking and Smoking Personal Health Jewellery and Personal Items Protective Clothing Hygiene Training There are two categories of certification, A and B. The appropriate category for each food packaging company is determined by the end use of the packaging products. The Decision Tree (figure 1) can be used to assist companies in determining the appropriate category for certification. Category B is the higher level of certification and is required for packaging materials, which will have direct contact with foodstuffs. Containers for Consumer Prepared Meals and bottles for example would fall into this category. This category specifies additional requirements in the areas of factory standards, contamination control and personnel. The category B requirement for protective clothing for example, obliges companies to carry out controlled laundering of clothing whereas self-care is permitted for category A. Packaging materials suitable for Category A certification would include mainly secondary packaging for example labels and corrugated cases where there is no direct contact with the food or drink product. Certification Benefits: Since the launch of the BRC/IOP standard, certification has been driven predominantly by customer demand. Apart from customer satisfaction however, there are additional benefits to achieving certification to both the packaging supplier and their customers in the Food & Drink Sector. Benefits of BRC/IOP certification to packaging suppliers: Increasing competitive advantage Potential reduction in number of customer audits Upgrading of procedures, processes and practices in relation to hygiene and food safety Reduction of associated customer complaints and internal non-conformances

4 Development of employees through training and coaching Benefits to food manufacturers in using BRC/IOP certified packaging suppliers: Assistance in meeting requirements of EFSIS, BRC and HACCP (IS 343) Certification Assistance in meeting standards in food safety and hygiene as demanded by retailers and ultimately consumers Potential reduction in number of complaints and non-conformances Reduction in number of supplier audits Potential for reduction in level of testing of incoming packaging materials Increased confidence in supplier and materials supplied. The standard presents a practical approach to hygiene and food safety for food packaging companies. It compliments existing Quality Management Systems like ISO 9001:2000. There is a considerable overlap in terms of the requirements of the two standards. Companies who are registered to the ISO 9001:2000 standard have generally, for the most part, met the requirements under the Technical Management section in the BRC/IOP standard. An additional advantage to ISO registered companies is that all documentation required by the BRC/IOP standard can be incorporated into existing quality manual systems thereby minimizing duplication and additional paperwork. Preparation for Certification: The first step in preparing for certification should be the determination of the appropriate category for the company. Ideally a 3-step approach is then required to achieve certification. Firstly an initial assessment against the requirements of the standard should be conducted to identify any non-conformances. Secondly an action plan should be prepared which details appropriate corrective actions and improvements and finally the action plan should be implemented. An independent 3rd party auditor, accredited to EN conducts the certification audits. Auditors located in Ireland include NSAI and SGS Ireland. For convenience, it may be possible to combine ISO and BRC/IOP audits in agreement with the auditing body. Resource requirements: The time frame for implementation will vary from one organisation to another. Where substantial improvements are required to the factory buildings, the completion time for implementation may be considerably extended. Such improvements may include proofing of the building and in extreme cases construction repair or alterations. In terms of implementation costs, the main cost incurred is usually staff time and where appropriate, professional technical support. Capital expenditure may be required particularly where improvements to the buildings are required. On-going annual costs may also be incurred for example hygiene training of personnel and the controlled laundering of protective clothing (category B only).

5 As with any initiative the essential requirements in preparing for BRC/IOP certification are the 3 C s: Competence fully understand the requirements of the appropriate category of the BRC/IOP standard. Copies of the BRC/IOP Technical Standard can be purchased from the BRC Stationary Office at or from the on-line book store at Communication inform all personnel, including union representatives of what is involved before, during and after the implementation process. Commitment from senior management to direct employees, commitment to the process is essential to both achieve and maintain BRC/IOP certification. The BRC/IOP standard presents a new challenge for food packaging companies, a challenge that should also be viewed as an opportunity for improvement and overall upgrading of the sector and indeed the entire food supply chain.

6 Figure 1: Category A or B - Decision Tree Is the end use for direct contact packaging of food? Will the packaging enter an environment where there are unprotected or open food products? Does the food product have an adequate natural barrier? Does the packaging have the potential to contaminate the food? Category A Category B Category B Category A

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