Systems Implementation Guide for the Packaging Standard

Introduction 6
The Risk of a Non-Integrated Approach 7
What This Guide is for and How to Use it 8
A Systems Approach to Implementing and Managing the BRC/IOP Global
Standard for Packaging and Packaging Materials 9
1. Senior Management Commitment and Continual Improvement 14
1.1 Product Safety and Quality Management Policy 14
1.2 Senior Management Commitment 15
1.3 Organisational Structure, Responsibilities and Management Authority 17
1.4 Management Review 18
2. Hazard and Risk Management 20
2.1 Hazard and Risk Management Team 20
2.2 Hazard and Risk Analysis 21
2.3 Exemption of Requirements Based on Risk Analysis 23
3. Product Safety and Quality Management System 24
3.1 Product Safety and Quality Manual 25
3.2 Customer Focus and Contract Review 26
3.3 Internal Audits 27
3.4 Supplier Approval and Performance Monitoring 28
3.5 Subcontracting of Production 29
3.6 Documentation Control 30
3.7 Specifcations 33
3.8 Record Keeping 34
3.9 Traceability 35
3.10 Complaint Handling 36
3.11 Management of Incidents, Product Withdrawals and Recalls 37
4. Site Standards 41
4.1 External Standards and 4.2 Building Fabric and Interiors 41
Contents
4.3 Utilities 43
4.4 Security 45
4.5 Layout and Product Flow 47
4.6 Equipment 48
4.7 Maintenance 50
4.8 Staff Facilities 51
4.9 Housekeeping and Cleaning 52
4.10 Waste and Waste Control 53
4.11 Pest Control 55
4.12 Transport Storage and Distribution 56
5.0 Product and Process Control 58
5.1 Product Design and Development 59
5.2 Packaging Print Control 60
5.3 Process Control 62
5.4 Product Inspection and Analysis 64
5.5 Inline Testing and Measuring Equipment and 5.6 Calibration 66
5.7 Control of Non-Conforming Product 68
5.8 Foreign Body Contamination Control 70
6.0 Personnel 72
6.1 Training and Competence 72
6.2 Access and Movement of Personnel 73
6.3 Personal Hygiene 74
6.4 Medical Screening 75
6.5 Protective Clothing 76
Glossary 78
6
First published in 2001, the BRC IOP Global Standard for Packaging and Packaging Materials has since
become the main standard for packaging businesses worldwide that supply into the food and drinks industry.
In recent years, the standard has also been growing in popularity abroad, especially in companies operating in
countries that supply UK markets.
According to the standard itself, its used to assist businesses in the safe production of food grade packaging.
It helps with the safety, quality and operational criteria required to achieve the legal and compliance obligations
of packaging businesses and is ultimately designed to protect the consumer.
Fig 1: Overview of BRC Global Standards
The standards are compiled collaboratively between retailers, manufacturers and industry experts, with the
BRC acting as the standard owner and enforcer. This approach ensures that the standards can be established
and adhered to, as well as providing a relatively level playing feld for packaging companies to compete in.
The standard is revised regularly in order to improve it. This has been effective in driving product safety and
quality standards. Designed to be a Product Safety and Quality Management framework, the standard does not
dictate how companies will meet its requirements, therefore it is not surprising that businesses take differing
approaches to its implementation and maintenance.
These differing approaches to implementing and maintaining the standard occur as naturally as the variation of
the companies themselves, each having their own set of constraints and cultural attitudes to compliance and
how they implement and manage it.
Introduction
Retailers
Manufacturers
Safe
Production
Experts
BRC Global Standards are
a Collaborative Approach to
Product Safety and Quality
Introduction
7
The Risk of a Non-Integrated Approach
Many businesses are still operating to the standard using manual paper based and fragmented systems such
as spreadsheets and Word documents. Others still use systems built in-house that cover some, but not all of
the required areas.
Management
Supplier Sales Purchasing Quality Technical Production Staff Customer
change
standards waste/harm
Documents
Training
Incident
Analysis Audit CA/PA
Loss of
Control
Fig 2: An Integrated Approach to BRC Global Standards
These approaches can lead to several issues that are likely to be refected in audit results and also in day-to-
day operations such as:
Non-conformity due to a lack of document control One of the most common problems, this regularly
causes issues at audit. It is important because documents are the bedrock of any quality and safety
management system. They defne what the operational plans are and set quality and product safety
standards. If documents are out-of-date or not being followed then this signifcantly increases product safety
and quality risk and can be the direct cause of many costly, but otherwise preventable, product safety and
quality incidents, such as product rejection or recall.
Training records not being kept up-to-date Even when the documentation is both ft for purpose and
kept up-to-date, it can be completely ineffective if relevant staff are not aware or trained in the procedures
they contain. For this reason training activities need to be closely aligned with the operational plans
embedded in both the procedures and content of documents. This is a commonly underestimated task that
contributes to problems on a regular basis in all industries.
A lack of proper management review Whether it is market conditions, changes in legislation, changes
in interpretation of the BRC/IOP Global Standard for Packaging itself or new innovations in plant and
equipment, nothing stays the same for very long. Its therefore vital that operational systems that help
manage quality and product safety are properly reviewed on a regular basis. Not doing so risks drifting into
problems and business issues that puts jobs, reputations and consumers at risk.
Q-Pulse Systems Implementation Guide for the Packaging Standard
8
A lack of true analysis information that is used to drive continuous improvement Analysis takes
place in almost every other part of a business: from annual accounts to weekly production and sales
meetings, its simply part of the culture. In these scenarios, much information is gathered in order to
understand why the business is successful or not. The information is then used to direct future actions
and strategy. Whilst many quality and technical departments do carry out such analysis its often compiled
manually and is fxed in its scope. True analysis allows the business to drill into underlying data in order
to quickly expose problems and opportunities, as well as to give the high level performance picture. The
inability of businesses to do this kind of analysis limits responsiveness and reduces scope for improvement.
Poor engagement by the business outside the quality department This can be a major issue in many
businesses and is, in part at least, brought about by cultural attitudes to any departmental demarcation
lines. The very fact that quality departments exist drives attitudes that absolve others of responsibility,
leaving the action to the quality department. Quality is, in fact, central to all other operations in a business
and should oversee all quality related activities and tasks, most of which should be actioned by other
departments of the business that are in the best position to infuence outcomes. Hard pressed quality
managers the world over struggle with their colleagues on a daily basis because of this damaging issue
that causes stagnation or even a decline in standards over time.
Poorly managed Supplier Assurance Programmes A signifcant number of problems in any
manufacturing business can be traced to poorly performing suppliers. Yet the disconnect between
different parts of the business, for example quality and procurement, can cause major issues that can
cost the business signifcant amounts of time, money, waste and reputation. Proactive and collaborative
management of suppliers and their assurance programmes are therefore key to ensuring a consistent and
proftable business.
Many of these issues can be traced back to a lack of integration between disciplines such as Internal Audit and
Document Control, Supplier Assurance Programmes, People and Training, Assets and Equipment.
Corrective action programmes represent the core mechanism for gathering information whilst dealing with
the issues, as well as providing an opportunity to learn from what is actually happening in the business, at its
suppliers and customers. Corrective action programmes do this by providing information that is gathered in a
structured way that is directly aligned to business objectives. This then allows for real time monitoring and root
cause analysis to uncover opportunities, trends and monitor performance.
What This Guide is for and How to Use it
This guide highlights how Gaels Q-Pulse solution presents a way to manage a successful implementation and
maintenance of the standard. It can also be a much more cost effective way that truly helps drive continuous
improvement and increases the prospects of growth in your business.
This guide will walk through each section of the BRC IOP Global Standard for Packaging and highlight how
Q-Pulse can help with each area so that you are aware of the tools and techniques that can be used to
automate many of the low-value tasks that your business does each and every day.
This approach helps release time and resource, and produces relevant analysis information to both identify
opportunities for improvement and intervene in emerging problems that, if unchecked, will end up costing your
business money, time and reputation, thus stifing opportunity for improvement and growth.
PLAN
CHECK
A
C
T
D
O
QUALITY
MANAGEMENT
SAFETY
MANAGEMENT
PERFORMANCE
MANAGEMENT
RISK
MANAGEMENT
BRC/IOP Global Standard for Packaging
Gael Best Practice Framework
Senior Management
Commitment
Product Safety/Quality
Management System
Hazard & Risk
Management System
Site Standards
Process Control
Personnel
Fig 2a: Gael Best Practice Framework