presented by David Burns

1. AWARENESS TRAINING PROGRAMMETechnical Standardfor Companies Manufacturing and Supplying Food Packaging Materials for Retailer Branded Products presented by David Burns

2. INTRODUCTIONBRC / IOP Technical Standardfor Companies Manufacturing and Supplying Food Packaging Materials for Retailer Branded Products

3. Development of the Standard • This standard hails as a first for the packaging industry • It provides common ground on auditing • It underpins due diligence to users. • It brings quality and hygiene standards, and many manufacturers to new heights. • It means a single audit for packaging manufacturers

4. Development of the Standard • The BRC / IOP Technical Standard was bench-marked to several existing standards during writing • It covers all packaging industry types, not just one, as are many codes of practices that are issued by trade associations • The BRC/IOP Standard encompasses all problem areas within packaging production.

5. Development of the Standard • It is hoped that the Standard will cascade through the packaging industry • Retailers will require their packer fillers to ensure all of their packaging manufacturers are accredited • The Standard requires them to ensure their suppliers are up to an adequate standard • The best way to achieve this is by accredited certification

6. Development of the Standard • The cascade effect will ensure all packaging manufacturers, converters and suppliers have the same standard. • Transparency of auditing will ensure companies will not be commercially disadvantaged by non compliant companies.

7. 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 and look at problems that have arisen

8. Background Information • Following the Food Hygiene Standard, it was agreed that the Packaging Standard had to be credible • It should be backed by the EN45011 standard • All standard audit bodies must be accredited under the EN 45011 standard requirements • Each evaluator will have to prove competence by examination in both hygiene and packaging.

9. UKAS Accreditation

10. Standard Integrity • Only bodies that are accredited to the EN45011 standard will be allowed to carry out audits • Audit bodies will not be allowed to carry out both consultations and audits • Individual Inspectors will need to have specific qualifications based on packaging, hygiene and audit management

11. Why have a common Standard ? • Provides a level playing field • Being able to demonstrate Due Diligence • A single audit, one certificate that will be acceptable by all interested parties • Reduction in cost, speed up of auditing

12. What are the objectives ? • To ensure all food packaging manufacturers are satisfactory in both hygiene and technical matters • To ensure all packaging users are able to trust their packaging materials to be hygienic and consistent

13. What are the objectives ? • The Standard is based on both pre-requisites and risk assessment • The Standard is prescriptive in many areas • Control of hygiene in every aspect of a production unit • Ensures consistent adherence to a specification • Covers high and low risk areas • Defines high and low risk

14. Who Were Involved ? • Institutions • United Kingdom Accreditation Service (UKAS) • The Institute of Packaging (IOP) • The British Retail Consortium (BRC)

15. Who Were Involved ? • Others • The Standard has not been written by the retailers and then imposed on the packaging industry. The committee was made up from the following: • Audit bodies, Institute of Packaging, Academia, Manufacturing Trade Bodies, Packaging Manufacturers, Food Manufacturers (Packer Fillers) and Retailers

16. Benefits of the Standard • Accepted Standard based on best practise • Certification bodies accredited to EN45011 to achieve maximum consistency in application and interpretation • Open and transparent • Encourages continuous improvement • Cost effective, removes need for multiple customer inspections

17. Benefits of the Standard • Removes “burden” of “routine” visits • Broad based standard, including; quality, hygiene, and safety • The standard addresses “due diligence” • Requirement for on-going surveillance • Focusing on process improvement

18. Benefits of the Standard • The Standard covers issues that are also covered within an ISO9000 standard. • Provided your ISO9000 certification can be shown to be acceptable to the assessor much of the Packaging Technical Standard may be covered.

19. What does the Standard cover ? • Management Responsibilities • Risk Assessment • Documentation Requirements • Factory Standards

20. What does the Standard cover ? • Quality Assurance/ Process Control • Contamination Control • Personal Hygiene • Glossary of Terms

21. What does the Standard protocol cover ? • Audit Body Requirements • Frequency of Evaluation and follow up. • Evaluation Reporting. • Certification. • Competency of Inspectors. • Standard and Protocol development. • The Auditors Report

22. BRC - STANDARD CONTENTS • 1. Scope • 2. Organisation • 3. Hazard and Risk Management System • 4. Technical Management System • 5. Factory Standards • 6. Contamination Control • 7. Personnel • 8. Risk Category Determination

23. BRC - TECHNICAL STANDARD • The BRC Standard is divided into two levels, in consideration of the product supplied • Category A – Non Food Contact Packaging • Category B – Food Contact Packaging • The priority categories associated with your company’s requirements will beexplained, as follows:

24. THE STANDARD REQUIREMENTS 1. SCOPE 2. Organisation • Responsibilities for implementation and maintenance of standard • Designated Manager (within structure) • Qualified • Suitably senior • Acknowledged deputy • Management review system

25. THE STANDARD REQUIREMENTS 4.Technical Management System 4.1 Technical Management Policy • Quality and Hygiene Policy Statement • Published and issued statement by the Senior Management: • Legal compliance • Commitment to consumer protection • Documented system implementation • Training and resource management • Review of system effectiveness

26. THE STANDARD REQUIREMENTS 4.2 Document Control • Demonstrate compliance with the standard • Documented management system (procedures / methods) shall be authorised (at all levels) • Formally issued and controlled • Obsolete documentation removed from use • Complete records controlled at all appropriate levels

27. THE STANDARD REQUIREMENTS 4.2 Document Control (Required Records) • Training • Cleaning Schedules • Foreign Body Incidents • Customer Complaints and Product Recall • Internal Audits • Pest Control (internal and external) • Maintenance / Engineering • Glass and Brittle Plastic Policies • Blades and Sharps Control • Non Conforming Products • Traceability

28. THE STANDARD REQUIREMENTS 4.3 Specifications • Raw Materials • Finished Goods • Suitable for food contact use • Adequate, accurate and legally compliant • Agreed with relevant parties • Trademark agreement • Review procedure

29. THE STANDARD REQUIREMENTS 4.4 Management Of Incidents And Product Recall • Documented incident reporting procedure • Customer notification • Documented recall procedure • Product re-call at all stages of production • Control of non conforming products • Corrective and preventive actions • Verification of recall systems

30. THE STANDARD REQUIREMENTS 4.5 Traceability • Raw materials • Work in progress • Finished goods • Product identifiable at all stages of production

31. THE STANDARD REQUIREMENTS 4.6 Process Control • Hazard Analysis • Sufficient and appropriate controls • Segregation of raw materials, work in progress and finished goods • Process and equipment verification • Legal compliance and customer satisfaction • Equipment calibrated and traceable to National Standard • Control of raw material supply

32. THE STANDARD REQUIREMENTS 4.7 Internal Audits • Programme of audits in consideration of risk • Trained and independent auditors • Documented results of audit • Review of audit results • Corrective and preventive actions

33. THE STANDARD REQUIREMENTS 4.8 Complaint Procedure • Documented system for complaints • Effective management review • Implementation of corrective and preventive actions • Complete records of action taken • Approval of actions

34. THE STANDARD REQUIREMENTS 4.9 Supplier Monitoring • Evaluation and selection of suppliers • Selection criteria against procedures • Assess ability to supply conforming product • Maintain an approved supplier list • Measurement of supplier performance • Verification of supplier claims / approvals

35. THE STANDARD REQUIREMENTS 4.10 Sub Contracting Of Production • Effective control of sub-contracting • Include hazard analysis • Identify responsibility • Verification of Subcontractor Technical Systems

36. THE STANDARD REQUIREMENTS 4.11 Product Analysis • Hazard Analysis • Reliability of Test Results • Qualified Personnel • Accredited Sub Contracted Laboratories (or other body) • Agreed and Documented Test Methods • Compliance with Specifications

37. THE STANDARD REQUIREMENTS 5. Factory Standards • As indicated within earlier slides, the Standard is divided into two categories: • Category A,(indicated in orange)and; • Category B(indicated in green) • The priority categories associated with your company’s requirements will beexplained, as follows:

38. THE STANDARD REQUIREMENTS 5. Factory Standards 5.1 Perimeter And Grounds • Unobstructed Access and Debris Free • Defined External Eating Area • Access Points Proofed • Protected Appropriate Drainage Systems • Traffic Routes Surfaced • Protected External Storage • Designated Refuse Collection Areas

39. THE STANDARD REQUIREMENTS 5.2 Layout And Product Flow • Prevention of cross contamination • Control of work in progress • Product handling areas • Designated personnel routes

40. THE STANDARD REQUIREMENTS 5.3 Building Fabric • Sound construction • Suspended ceilings accessible • Adequate lighting • Cleaning schedules for internal surfaces • Walls capable of being cleaned • Drainage protection • Sufficient ventilation • Proofing of ventilation openings • Proofed against pest ingress

41. THE STANDARD REQUIREMENTS 5.4 Maintenance Of Equipment • Well maintained • Cleaning schedules • Wooden equipment • Minimised use • Good condition • Properly sealed • Notice-boards

42. THE STANDARD REQUIREMENTS • Maintenance Of Equipment • Planned maintenance programmes • Control of compressed air • Use of tape engineering • Operate to hygiene, health and safety requirements • Control of contractors • Post maintenance checks • Documented post maintenance checks

43. THE STANDARD REQUIREMENTS 5.4 Housekeeping And Cleaning • Clean as you go policy • Cleaning schedules • Item to be cleaned • Frequency • Method • Cleaning materials • Responsibility • Cleaning record checks • Use of approved cleaning detergents • Monitoring of effectiveness

44. THE STANDARD REQUIREMENTS 5.4 Housekeeping And Cleaning • Storage of cleaning equipment • Toilet cleaning products segregated • Control of tools and maintenance equipment • Control of workstations to prevent product contamination • Suitable storage facilities for workstations

45. THE STANDARD REQUIREMENTS 5.6 Waste And Waste Disposal • Minimise accumulation of waste in production • Use of appropriate containers • Disposal of putrescible waste (lined and lidded) • Disposal of Trademarked waste • Use of licensed waste contractors • Collection of recycling waste

46. THE STANDARD REQUIREMENTS 6. Contamination Control 6.1 Foreign Body Control • Staff training • Written policy for glass and brittle plastic • Glass and brittle plastic register • Written policy for “sharps” control • Issue and control of “sharps” • Snap off knife blades

47. THE STANDARD REQUIREMENTS 6.2 Chemical And Biological Control • Chemicals, cleaning materials, lubricants and adhesives controlled to prevent product contamination • Aseptic control systems

48. THE STANDARD REQUIREMENTS 6.3 Pest Control • Formalised preventative programme • Use of approved contractors for pest control • Records and location of pest control baits • Correctly sited EFKs • Follow up actions

49. THE STANDARD REQUIREMENTS 6.4 Transport, Storage And Distribution • Finished product protected • Product movements between premises • Checking of wooden pallets • Control of contract haulage • Written contract with hauliers • Integrity checks of raw materials • Documented checks of raw materials

50. THE STANDARD REQUIREMENTS 6.4 Transport, Storage And Distribution • Non conforming products • Vehicle drivers • Clean and suitable transport • Cleaning programme for vehicles • Pre loading checks of vehicles • Control of off site storage