BRCGS Packaging - do we need to inform CB in case of recall?

Hallo dear colleagues!

First of all - wish you all the best in 2022! ))

In BRC Food there is a requirement to inform certification body in case of recall within 3 days.

Don't you know if there are some similar rules for Food Packaging?

Or do we need to inform only the customer?

I can not find anything in the requirements, but may be I miss it somehow?

Many thanks in advance! 

We are SQF and manufacture paperboard packaging. For us, it is not likely we would have a formal "recall" we might issue a withdrawal for product so your documentation should emphasize that action. That being said, we have very limited recall language and perform a "mock" recall annually which is actually more of a trace exercise. What type of packaging do you produce?

Hallo, wie geht's?

For SQF, it's my understanding that SQFI and the certification body must be notified in writing if there is any food safety event that requires public notification.  I would guess that BRCGS would be similar and would think that if it's a recall for a product under the scope of the certification, even if it's food packaging, then the certification body would need to be notified.  However, this is just a hunch.

Matthew

Many thanks for your answers.

We produce primary flexible food packaging (plastic, paper) and perform the "withdrawal-test" annually - as it is required by the Standard.

In fact, till now we did not have any real recall-cases. But during the last audit, the auditor mentioned that we need to inform CB in case of recall.

The problem is, that I cannot find it as a requirement in the standard, so I don't have any reference to make the changes in our recall procedure.

Many thanks for your answers.

We produce primary flexible food packaging (plastic, paper) and perform the "withdrawal-test" annually - as it is required by the Standard.

In fact, till now we did not have any real recall-cases. But during the last audit, the auditor mentioned that we need to inform CB in case of recall.

The problem is, that I cannot find it as a requirement in the standard, so I don't have any reference to make the changes in our recall procedure.

I couldn't see this in the standard either - it's missing from the equivalent clause in which it is found in the food standard.
I don't think it's an unreasonable requirement in general, but if you've been audited against a standard then the audit should only include things in that standard, IMO.
The NCs issued in the audit should normally reference the clause(s) they've been given against, but if that isn't present then it's probably be worth asking your CB to clarify for you. If it wasn't raised as an NC then it might still be worth asking them to confirm this, as that way you've got a formal response to show if an auditor challenges it again.

There were many changes to the SQF code from Ed 8.1 to Ed 9. Nearly all of the remaining "food" language was removed. SQF seems to generally view recall for only food products. Withdrawals for other products (like packaging) would typically be for function and / or quality issues that were not caught by internal methods, customer complaints and the sort. Our auditor said the chances of a recall for our paperboard products is practically zero given the control we employ. The only "recall" language we have is leftover from previous editions and will likely be removed this year during review though I will leave some in the Crisis Management Plan.

I agree with what pHruit already said, Your CB must justify more about the NC.

Even the requirement does not specify the case, but the situation can become an NC if it is against other significant documents, e.g. (food) industry standards or laws.

Example here for the clause 3.13.5

 

...

- a communications plan that includes methods of informing customers and (where necessary) regulatory bodies in a timely manner.

win the interpretation guide:

 

This clause contains specific points to help ensure that an effective recall system is designed that includes communication with key contacts, both internal and external.

...

IMO, the NC would be accepted when your CB proves themselves they are a key contact by any legitimate mean.

For communication requirements (not only recall), see BRCGS packaging 6 standard in Section 5 General protocol - post audit.

For the timeline and specific requirements like reporting method you need to check with your certification body as they will have their own procedures or instructions.

Also the food safety government agency will have specific requirements.

Best to combine all requirements into 1 flow and inform all together in the most strictest way.