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Protective clothing
From: paul
2:07PM 2 October 2018
Hi all My procedure currently requires all operators to change at work into their protective clothing. At the moment when people go out to the smoking areas they do not remove the protective clothing and change back in to their day clothes and then back again in to protective clothing. I don't want to get into the smoking debate. I have decided to allow all operators to come into and leave work in their protective clothing. I will operator a spot check system. All will be required to have a spare with them in their lockers in case they fail the spot check. I will be doing the RA  for this to ensure we don't encourage any contamination.  What are your opinions please
From: Calidad Envaflex
3:25PM 3 October 2018
Hi all. We have gone through something similar and what we have done has been to implement a standard by which our workers can’t leave without wearing a disposable protective equipment over their work clothes. At the moment when our workers go out to the rest areas they should put on that disposable protective clothing
From: a.molteni@alcom.it
3:04PM 2 October 2018
Hi Paul,
what do you mean with "spot check system"? 
From: paul
6:01PM 2 October 2018
the team leaders, other management will check the state of the protective clothing being worn from time to time of anyone on the shop floor. This will form part of a document to say they have checked. Anyone found to not meet the standard will be asked to change into clean clothing. We are a small factory so major contamination risks will not go in-noticed
BRC Packaging - work with material which is not suitable for food use
From: Calidad Envaflex
3:08PM 28 September 2018
Good afternoon,some doubts have arisen regarding the raw material. One of our clients wants us to work with their own material, which is not suitable for food use. Our doubts are:
      - being of high category: can we enter this material in our facilities taking the necessary preventive measures or is it not possible under any circumstances? In what section of the BRC standard does this indicate?
     - If you can work with it, does the machine you are going to work on be in an area separate from the rest of the equipment or can you share facilities with the others?
    - Once the work is finished, that machine must be sanitized to eliminate any remaining material not suitable for food before being able to work with other material, right?


Thank you very much for your feedback and guidance
Issue 5 - what should change or be improved for Issue 6?
From: Joanna Griffiths
2:27PM 8 August 2018
Issue 6 is currently in development. What doesn't work in Issue 5, or what could work better? What works well? Are there key themes in industry that we should be looking at? 
From: a.molteni@alcom.it
1:01PM 30 August 2018
Hi, 
I agree with iriszhang regarding the traceability of inks (above all the mass balance that it is really impossible to do!). 
Other points that should be more detailed should be the food fraud/food defence and the 3.12.8 (explaining in details how to do a moc recall). 
From: lorenab
6:44PM 30 August 2018
I am really interested how we can implement the traceability of inks. If Issue 6 can be more elaborate on that part that would be of great help for us.
From: a.molteni@alcom.it
12:59PM 30 August 2018
Hi, 
I agree with iriszhang regarding the traceability of inks (above all the mass balance that it is really impossible to do!). 
Other points that should be more detailed should be the food fraud/food defence and the 3.12.8 (explaining in details how to do a moc recall). 
From: iriszhang
10:16PM 12 August 2018
Hi
We're just starting to go through the accreditation process, so it's interesting to see what's included in the standard and how we can comply.  One thing that has caused us discussion, is the traceability of inks.  The standard requires 'all raw materials', a little flexibility based on risk would be good here, as it seems to be a industry wide/ global discussion point on the forums, to what is the real food safety risk and likelihood of a recall taking place because of inks.


I really like the use of risk assessments to show whether something is required or not, and request that stays.  It does help differentiate between the packaging standard and food standard.  
From: michal.kaminski@rpc-superfos.com
11:50AM 27 September 2018
Depending on which inks you are talking about. If you print UV cured inks with for example matt lacquer on it the risk is quite huge. With matt lacquer the UV penetration is much smaller so free photoinitiators can be present even if top sufrace is perfctly hardened. If you give too much UV then print is not going to look good so operators seems to give too less instead of too much if UV and that definitely increase the risk. None of scratch test tape test could detect that and you ending up in a situation where you have free photoinitiators which are very small compounds easily migrating to food. Also those UV strips are not that accurate enough.  This group of compounds it quite toxic so limits in legislation are  low sometimes even 0.01 mg/kg. Thats why traceability of inks is very important and the story im describing happened in real life with 1000K euro costs .  
On the top of that your ink manufacturer is producing different types of inks on the same equipment. Imagine that someone is going to mix food and non-food ingredients on a production by mistake. If you dont have traceability you are recalling all batches of containers with ink from that producer, if traceability is present then you recall only that particular batch of ink. Standard is very strict in traceability and in my opinion there should be no relax in this matter. Traceability should be done on all raw material which might bring a risk and it should be done to the best practical level. 
From: JudyR
3:42PM 16 August 2018
I agree with your comments. I suggest that issue 6 reflects the requirement for risk based decisions regarding the traceability of raw materials. 
Issue 5: Hand washing before entering the production area
From: Ken.Xu@vivacan.com
3:36PM 21 September 2018
we have a hand washing station right between lunchroom and the entrance to production area. if employees wash hand in lunchroom after lunch or use washroom, do they need to do it again before entering the production area? the distance between lunchroom(washroom) and production entrance is less than 10 meters.
thank you, Ken

From: a.molteni@alcom.it
7:49AM 24 September 2018
I think that the important thing is that you should be able to give evidence that the employees wash their hands after food consumption. In my case, we have "hygienic gates", the gate will be opened only if you sanitize the hands. 
From: chatluong01@minhha.com.vn
4:34AM 22 September 2018
Yes, i think it is necessary for safety, careful is never redundant!
Management of Product Withdrawals, and Incidents and Product Recalls
From: lorenab
3:19PM 5 September 2018
Hi,
On Section 3.12.6 "communication with regulatory bodies", i think it would help if Issue 6 interpretation guideline specifies that this include contacting the certifying body/BRC? We were not aware about it until being told by an Auditor.


From: chatluong01@minhha.com.vn
4:56AM 22 September 2018
I think if the incident is very large and due to objective reasons, it is necessary to report to the authorities, and if the problem is within the control of your company and your company can No need to report to them unless required.
Clause 4.9.2.4. and use non-fragmentable blades and cutters in some processes
From: Calidad Envaflex
7:40AM 24 August 2018
Good morning,
In our company we use non-fragmentable blades and
cutters in some processes. Clause 4.9.2.4 says that the use of cutters isn't allowed but we maintain a rigid control over them since for such processes they
are necessary. Can we have any problems during the audits? We have tried other
equipment and tools but none has given a satisfactory result. I'm so grateful if you can give us some recomendations


Thank you very much


 
From: chatluong01@minhha.com.vn
4:50AM 22 September 2018

When audit, you need to show records and evidences (form, documents) about good control for this machine.
I think it is not problem during audit, good luck!
From: lab@cristalplastic.com
4:35AM 8 September 2018
Dear, 
Only snap off blades are restricted, because of chances of breakage & mix into the product. if you have other type of blade than it will not be issue. 
2ndly, cover blade hazard in risk assessment.


 
From: Joanna Griffiths
9:01AM 4 September 2018
Hi there, 
4.9.2.4 refers to snap-off blades, and it was universally agreed that there are few occasions where snap-off blades are acceptable and where non snap-off blades can't be used. This is due to the level of hazard they pose to the consumer should they remain in the packaging material. I'm afraid that should the auditor observe the use of snap-off blades during the audit then a non-conformity will likely be raised. 


Perhaps other users of the forum could suggest alternatives that enable compliance with the requirement? 
P557:Position Statement-hygiene categories
From: QualityIP
7:21AM 21 September 2018
Hi,
We're producing label for food products (for buckets). Our products indirectly contact with food and so we are in the basic hygiene category. After releasing of the position statement about the hygiene categories, will we need to change our hygiene category?
Thank you in advance.
Compliance Related Points for specific country
From: ashutoshroy
11:14AM 18 September 2018
Hi,
Will like to know and discuss about MOAH - MOSH in the packaging specifically Polypropylene woven sacks (FIBC) acceptable limit. Also the update with respect to USFDA and EC 10-2011 guideline. How can the compliance proved other than declaration and statements from the supplier? Also few testings are done in external lab but conducting all test are not feasible. 
Hoping to get some feedback and advice as on how people implement and comply to requirements in other industries.

Sharps Control - Loose Items
From: iriszhang
10:24PM 12 August 2018
In the sharps control section (4.9.2.5), it says no loose fastenings, such as drawing pins and staples.  Would an auditor consider magnetic buttons used on noticeboards as a loose fastenings?  It is a loose fastening, but it's not a sharp?  


Many thanks
From: Joanna Griffiths
10:34AM 23 August 2018
Hi! 
The main concern with the section on sharps is preventing materials that could cause harm to the consumer from contaminating the packaging material. Items such as staples or drawing pins/thumb tacks are clearly an issue, and many will be difficult to identify as a contaminant. While magnets are still a loose fastening and potentially harmful they are (perhaps) a little more visible and less likely to remain on/attached to a material when it's in production. 
I would recommend that if in doubt, a risk assessment always establishes if there is a real hazard and factors included in that risk assessment might be proximity of noticeboards to production lines or storage areas. The interpretation guideline also adds that enclosed or covered noticeboards are acceptable as mitigating the risk of these types of materials. 
From: iriszhang
4:22AM 3 September 2018
Hi Joanne
Thanks for your feedback and guidance.