New member transitioning to BRC Printing and Packaging standards

New member so sorry if the questions sound stupid by your trained professional standards.

We are a Canadian company who is being forced by our new Canadian Food Safe legislation to transition from our Provincial Agriculture HACCP recognition to global standards. I've recommended BRC Global Standard for Packaging and Packaging Materials to management as the most logical to transition to (opinions welcomed). We are a company that prints BOTH food-contact (about 15% of the time) and non food contact (85% of the time) labels only. No food components on site ever. 

Not having purchased the full BRC Packaging and packaging materials manual yet, I've only briefed my committee on what to expect, with the free downloadable version and any information I've gleaned from forums.

I am having a difficult time determining how we can (if even possible) separate the high-risk (food-contact) and low-risk (non-food contact) portions of the business out for the purposes of the BRC program. Is it even possible for run a high and low risk parallel standard if implementing BRC?

When we produce food-contact labels (high-risk portion) it is only done in a small portion of our production plant. We already implement sanitization protocols throughout this process. Majority of our cleaning, maintenance, shipping and receiving operate under the HACCP food-contact (higher) standards all the time.

Some of our employees never come in contact with any of the food-contact portion of production. I am having a bit of a nightmare with things like the jewelry (facial piercings), hair/beard nets, etc. with the majority of production staff that will never work in food-contact production.

Any and all suggestions are welcomed.

Hie :)

When implementing any international standard there is what we call "scope" which specifies the product line with which you intend to cater for using that particular standard. So it doesn't necessarily have to cover the non food contact labels that you print, your scope will be limited to the high risk group. The workers therefore that will be of concern are those that work in the food contact portion. Therefore yes it is possible to separate high risk and low risk if you specify the scope in your documentation process.

I hope this helps

who told you this??

new Canadian Food Safe legislation to transition from our Provincial Agriculture HACCP recognition to global standards.?????

To meet the new SFCR you are NOT required to have a GFSI.............not even the slightest

I've been in Canadian food for 20+ years and am happy to help

Scampi

It is a requirement on one of our largest customers who uses both food and non-food contact labels.

To be a supplier for them they have stated that they [quote] "will no longer be accepting third party audits completed by organizations outside those that complete ISO, AIB, NSF and GFSI audits" thus our provincially recognized HACCP audit is not acceptable.

I recommended the BRC Global Standard for Packaging and Packaging Materials to management as I thought it would be the easiest transition from HACCP.

The only concern I have is how to split our production into high hygiene and low hygiene production standards.

Got it, the way you had it worded it read like you were under the impression the government was forcing you GFSI, my apologies

BRC has the most stringent requirements........SQF will offer you a lot more flexibility.

My #1 suggestion would be to have a good look at the SQF packaging program (and you don't need to buy it to read the entire thing) and re-evaluate. BRC is probably going to give you alot of headaches unnecessarily that SQF won't (like high hygiene vs low)

https://www.sqfi.com...ging1212017.pdf

https://www.sqfi.com...-with-desk.xlsx

To satisfy BRC, you'll probably have to separate by production days as I don't see any other way around it...........

oh and BRC is more expensive

We literally created a "Zone" in which all of our higher exposure to contamination processes are performed. We call it the "Blue Zone" and in it hair / beard nets are worn and cleaning is increased. If there is a way to segregate the "high hygiene" area it is easily monitored and the rest of the facility need not hold the higher standard.

BRC and SQF each have there own quirks or things they are picky about.  I have not experienced one costing more that the other in my experience.  I would say they run very similar in price. 

The manner in which the BRC standard is written is more clear cut and easily understandable.  SQF leaves more to interpretation of the guidance documentation. 

The free version of the BRC manual that you downloaded is the actual standard.  There is no paid copy of the standard for BRC nor SQF.  

2 of the biggest differences I have noticed are......

BRC more required risk assessments in addition to a HACCP Plan

SQF stronger environmental monitoring requirements (Micro testing)

As stated above "SCOPE" is very important during implementation to determine your risk level.  I would not try and split your facility into high and low risk as you might has trouble defining the separation in the higher level processes.  I have seen many sites that do both choose the high risk category and comply to the stricter requirements. 

Sorry,for coming in late but I've not been on the site for a while.

As a matter of interest, what food products are you applying labels directly on? It is quite unusual and I can only really think of fruits and vegetables.

Foodworker

The product with the food contact label is a cured meat product. Label is contained within the cryovac packaging.

SQF in my opinon is always "easier" but then again I've been involved in SQF auditing and consulting now for over 10 years which allows us to create systems extremely fast and well done.

You would really have two ways to go with SQF, you can scope out just the area that does the high risk and leave out all other areas.

Or, just include it all under the scope.

Interestingly enough we have a new potential client that is a packaging company, but in one area they repack packaged condiments (like sugar, sugar sub, stir stick, dry creamer, etc) into a clear heat seal plastic pounch and that is the only area that will be under the scope - 90% of the facility is not.

Is it not possible to label on the outside of the packaging?

Adequate barrier definitions aside, putting a printed label inside a pack like that opens up a huge range of issues with the choice of materials, especially inks. Is it a PP label?

Finding a workable ink that is suitable for direct food contact is very hard and expensive. Many ink suppliers claim that they have a range of inks which are suitable, but when you dig down they are not.

You also have to consider cleaning protocols after running 'food grade' after non food grade on your print machines.

Perfect traceability will also be required which is never easy with inks. (ever tried a mass balance on inks?)

The personal hygiene elements are probably the easiest of your problems to solve.

(Sorry to sound negative!) 

Foodworker

Thanks for the eye opening input (and I did not consider it negative).

Unfortunately the label being inside is dictated by the customer, so no real choice for us to change (or if we do we lose the business as we do not print cyrovac). The label in printed on PP and covered with a clear 2mil Polypropylene BOPP laminate barrier overtop. No laminate on the back surface (raw DLI Grade - C2S three layered BOPP film) which touches the cured meat.

I don't know anything about Canadian legislation, but in the EU, for a plastic item in food contact to comply, the whole item - all the plastic layers, laminating adhesives and inks, as a combined package, must meet the requirements of EU10/2011 and its amendments. 

The problem is that currently there is no separate specific EU legislation for inks and adhesives. Suppliers know this and their compliance statements are generally full of clauses passing the responsibility to the printer.

The only legislation related to food contact inks that I know is a joint Swiss and German Ordinance released in 2017 (Sorry, I thought I had a copy but can't find it).

The European Printing Ink Association EUPIA publish a few related papers if you have trouble sleeping and maybe there is a Canadian equivalent.

If you haven't already done so, you will need to get compliance statements from all of the individual suppliers and see what they say.

Can someone from the SQF community confirm that we can in fact that the SQF certification would be a correct fit for a company that only prints the non- and food-contact labels. We have no packaging of food being done in our plant. In fact no food items at all. Raw stock, printed, packaged labels to customer.

Thanks again

We are a food packaging manufacturer, you should be fine with SQF Ed 8 Manufacture of Food Packaging. As long as your Approved Supplier program is strong and enforced and your PRPs are sufficient. I echo the idea of segregating all your contact packaging to a single area and implementing "Heightened Hygiene" in that area. As I stated earlier, we painted a blue line on the floor around the production and staging area where the highest food safety hazards exist. Hair nets, beard covers, no jewelry, fake nails / nail polish, expanded cleaning, additional hand wash stations etc. I'm curious if you have identified and CCPs?

We don't have any CCPs as we are a small operation and that area is pretty self contained. Press to bundle to packaging. Our policies are strict enough for any identified CCPs. Only issue we have is because of distance we rely on our Supplier Approval process being paper approvals and not on site. Some of these suppliers are smaller by nature and don't have any type of GFSI standard programs, or ISO programs in place. This causes me concern when it comes to the approval/traceability issue of either SQF or BRC. Larger stock suppliers can provide COCs so they are of no concern to me.

We have solid core hygiene policies in place for our Provincially regulated HACCP program, but suppliers not dictate that we provide a 3rd party GFSI audit so we are working toward complying.

I just don't want to start a program that is near impossible for us to comply with.

Creating safe direct food contact packaging is difficult if you can't verify the supplier's processes unless, as in our case, they are the actual creator / formulator of the supplied product and / or their processes provide effective "kill steps"  or otherwise guarantee there can be no contaminants from their processes that would create a food safety risk in yours. That information can be had as well as LOGs and / or allergen letters etc that can allow a questionnaire to be submitted and assessments to be done remotely. It's not really as complicated as it sounds and once you have it in place it's maintenance from there on.