10 January 2012
GUIDELINES FOR THE IMPLEMENTATION OF THE BRC/IOP GLOBAL
STANDARD FOR PACKAGING & PACKAGING MATERIALS
PART 1 THE BASIS OF THE GUIDELINES
1.
Purpose of the Guidelines
The purpose of these guidelines is to enable a uniform and practical interpretation of
the BRC/IOP Global Standard for Packaging and Packaging Materials (“the Global
Standard”) within the glass container manufacturing industry. While the general
recommendations in these guidelines will cover most applications in the glass
factory, they may need to be modified for special or certain individual cases as
determined by the glass manufacturer. The guidelines particularly address the
BRC/IOP Global Standard’s relationship to other important and well-established
Management systems such as BS EN ISO 9000.
The guidelines can be used by industry members as a reference document and
check list to ensure that internal procedures and Standards meet all the necessary
requirements of the Global Standard and to assist manufacturers to fulfil their due
diligence responsibilities to their customers.
2.
Preparation of the Guidelines
The guidelines have been prepared by the British Glass Technical Committee which
is made up of technical representatives from all the UK glass container
manufacturing companies. The views of a BRC-approved auditor with practical
Global Standard and BS EN ISO9000 auditing experience were also considered.
The guidelines took into consideration the recommendations of CETIE – a European
International Technical Centre for bottling and packaging in which European glass
container manufacturers are represented. In particular CETIE Data Sheet DT16 was
considered which concerns Hygiene recommendations for European glass container
manufacturers.
Members of the British Glass Technical Committee have actively participated in the
preparation of the Global Standards through the various issue numbers.
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3.
Implementation of the BRC/IOP Global Standards
The guidelines are based on the results of Hazard Analyses carried out at member
companies in relation to the Global Standard and other Management System
Standards.
The Global Standard is a general standard for all packaging sectors. The Global
Standard states that not all clauses will be applicable to all individual packaging
sectors. One purpose of the Hazard Analysis is to identify those clauses which are
exemptions applying to glass container manufacture or which are applicable only to
parts of the factory. These are identified in the Global Standard Clause Matrix (Part
II) which considers each clause of the Global Standard in relation to those parts or
zones of the glass container factory where it might be applicable. For the purpose of
the guidelines the defined zones are the areas within which the activity takes place.
The local site will define the "high care" areas within their operation as detailed in
6.2.1 of the Global Standard. These are areas where there is an increased possibility
of product contamination. Such areas include the Cold End from the lehr exits to the
palletiser, rework and secondary added value areas. The analysis relates to Zones
within the plant where specific activities take place; for example if an employee
normally works in the hot end zone he will need to obey all of the Hygiene rules
within his work area; if he goes into a high risk area such as Secondary added value,
he must obey the rules of that zone.
Where Global Standard clauses are applicable, the degree of application may be
determined by the risk elements of Hazard Analysis. The application should ensure
the glass containers are suitable for their intended use but should be appropriate to
the circumstances and normal environment within a glass container manufacturing
facility. Where additional precautions may be necessary there could be a time
interval before they can be fully implemented.
The Global Standard requires that exemptions are reviewed and may be exempt in
any subsequent audits provided that there is no change in circumstances Similarly
where parallel clauses with other Management System Standards have been verified
during the initial audit the results of any accredited Audit concerning such parallel
clauses in the future may be accepted by subsequent BRC/IOP auditors. This helps
to avoid possible differences in interpretation by different auditors on these clauses.
If this situation arose it could cause confusion within glass container manufacturing
control systems.
4.
General factors considered as part of hazard analysis to determine the
relevance of BRC/IOP Global Standard for Packaging & Packaging
Materials clauses to glass container manufacture
Unlike other packaging materials covered by the Global Standard, glass raw
materials are melted in a furnace at temperatures around 1500 °C. Additionally glass
containers are formed and annealed at temperatures around 500 °C.
Glass as a material is regarded by the BRC as providing an absolute barrier to any
form of product contamination. It is the only packaging material rated as “GRAS” or
“Generally Regarded as Safe” by the US food and drug administration.
After leaving the glass container manufacturers’ control all glass containers should
be cleaned (washed, air blown or rinsed and inverted) or inspected immediately prior
to filling. This amplifies a CETIE recommendation applicable to all European glass
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containers stated in CETIE Data Sheet DT14 – General Guidelines for the use of
glass containers.
The filling and packaging of food/drink does not take place in glass container
manufacturing factories.
Many aspects of Hazard Analyses/complaint analyses carried out in relation to BS
EN ISO 9000 and HACCP systems are similarly applicable to the Global Standard.
Glass is an inert material and as such provides a natural barrier to migration or
permeability issues and concerns. The nature of the conversion of raw materials to
molten glass means that upstream traceability is effectively curtailed at the container
forming stage. This limitation is recognized in the “Industry Guideline on Traceability
of Glass Packaging Containers (Bottles and Jars)” published by FEVE
Glass containers are primary contact packaging materials. The Global Standard
decision tree gives all such containers based on the product contained regardless of
material type a “High hygiene risk” classification. This classification was determined
by the British Glass Technical Committee.
5.
Auditing to the BRC/IOP Standard for glass container manufacture
It is the objective of the Global Standard that auditing be carried out by an auditor
who has expertise in all aspects of the glass container manufacturing process.
It is intended that these guidelines can be made available as necessary by member
companies to any third party auditors. If an auditor has any concern over the advice
given in these guidelines regarding any particular aspects of the Technical Standard
this can be referred by the member company to the British Glass Technical
Committee for discussion and resolution.
The auditing of the Global Standard is covered in Section IV, where it states that
auditors must have expertise in the relevant packaging field. If the company does
not think the auditor has the relevant experience for the audit it can reject the auditor
in a timely manner prior to the audit.
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Part II – Typical Zones of operation for glass container production
BRC/IOP Global Standard for Packaging & Packaging Materials
Applicable clause matrix
Zone 1
-
Design
Zone 2
-
Batch Plant including glass melting raw materials
Zone 3
-
Furnace – glass melting
Zone 4
-
Hot end – glass forming and lehr
Zone 5
-
Cold end – inspection and palletising
Zone 6
-
Secondary added value processing.
Zone 7
-
Warehouse
Zone 8
-
Logistics
Zone 9
-
Engineering/Maintenance workshops
Zone 10
-
QC/QA – including laboratories
Zone 11
-
Mould Shop
Zone 12
-
External site
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