Name: Navigating the Transition – BRCGS Packaging Materials Issue 7
Uploaded: 2025-10-14T16:17:43.572Z
Duration: 1 h 8 min 44 s
Description: Navigating the Transition – BRCGS Packaging Materials Issue 7

Transcript for "Navigating the Transition – BRCGS Packaging Materials Issue 7": Hello, everyone, and welcome to today's webinar, navigating the transition, DRCGS packaging materials issue seven. Before we start, a few production notes. This session will be recorded and will be available on demand in the future so you can review the information again or share it with others. To ensure the best audio and video quality, your cameras and microphones will remain turned off, but you can submit questions and answers using the Q and A function on your console. Your questions are important, so use the Q and A space to send your questions during the session. At the end of the presentation, our experts will answer as many of the questions as possible. A brief note about NSF's services. NSF is a not for profit global organization that provides standards, certification, auditing, consulting, and training in the areas of water, food, health sciences, and information technology. We'll now hand things over to Glenda to present our presentation. Thank you, Kenneth, and hi, everybody. Actually, it is September, and that says August. But but what's a month between us? So, thank you very much. I'm just gonna do a little introduction about myself. This is just a document we have to show for all BRCGS presentations just to say that this material that I share today is ours and and can't be used for any other training purposes. So I'm Gwen De Jarrett. I'm the programist managing non food at BRCGS based in The UK. I've been in the industry gosh many years now, coming up thirty eight years. I've I'm a foodie by training. I've done extra training actually in the packaging industry and consumer products industry. I've been a packaging auditor since the inception of the standard by BRCGS, but I've only actually been at BRCGS for about the last fifteen months, where I started, March. So and I'm actually looking after the non food standard, which includes the packaging material standard, consumer product standard, and the ethical source and respond responsible source and standard. So I always say 2024 was my blue year. Blue year because that was the year that we actually started and finished, the review of, packaging material standard, which is blue in color. So let me just go on. So what we're gonna cover today is I've really given you an overview of the changes. I'm gonna go into some requirements in more detail than others. I'll also then talk about the protocol. The protocol is as important as the requirements. And then as this will be probably about my fiftieth webinar that we've actually done on this standard, I know the, the place where I can actually share with you some of the themes and questions we've had back during those, webinars so I can share with you some of those questions and and some of our answers. So just to give you an overview of the standard, this is the second largest standard actually within BRCGS. Our largest standard is food safety. When you think about it, all products actually have packaging. Not all products have salt or sugar, but they all have pot packaging. So that's how how important this standard is. It's now in the seventh issue. It's almost coming up to a quarter of a century old. It was, issued in twenty o one, which is a seems a long time ago now. It's been around a long time because it's practical, supportive, challenging sites, to actually make sure that they improve and meet the needs and expectations of the food industry, the non food industry, and anybody who actually deals with packaging like food manufacturers. There's been a lot of focus on packaging sector in recent times from the reduction in weight of packaging to focus on the use of less, resources. So the requirement to move away from plastics or the plastic lobbying and the developments in paper manufacturing. This demonstrates how diverse the packaging industry actually is and I'm sure I don't need to tell you that. So just to give you a brief overview, and for those of you who like numbers, issue six had 316 requirements. That includes the statement of intent. Issue seven has 315. So one less. However, we have made a number of changes. We know that's true because we actually counted them because we wanted to see kind of what the the difference was. All in all, during the revision process, we actually touched a 167 of the clauses. So when you look at our key changes document, you will actually see a lot of red which indicates where there's been change. So, Carol, if you can just show the video, maybe useful for people to understand about our standard. For over two decades, the BRCGS global standard packaging materials has set the benchmark for packaging excellence worldwide. Now in its seventh issue, there are over 6,000 certificated sites across 90 countries. With global applicability and consideration of GFSI benchmarking and accreditation requirements, it is established as the cornerstone of quality and safety for manufacturers. The standard supports manufacturers with the challenges presented by the modern global marketplace by adopting best practice and reducing operational risk. This is why it is often the preferred choice for retailers and specifiers. BRCGS certification extends benefits beyond the certificate. The BRCGS service package supports certificated sites with continuous improvement between audits. By committing to the highest standards in packaging materials, you send a message that your packaging is more than just a container. It's a promise of safety, quality, and trust. So thank you for the opportunity of actually sharing that. So let's go on then to look at a little bit more about the standard. So the standard was launched last October, so almost a year ago now. And the standard's actually been active since, the twenty eighth, the April 8 this year. And to date, we've had probably about a quarter of the sites that were certificate have actually gone through the certification to issue seven. So the scope of the standard sets out the requirements for the manufacture of packaging materials that are used in food, feed, beverage, industry, or for the containment of product of a hygiene sensitive products such as cosmetics and pharmaceutical products, and also for non food products. So those which actually supply into maybe the automotive industry or to consumer goods. The industry is incredibly diverse with a wide range of material types, manufacturing technologies, and applications. And issue seven of the standard has addressed the range of products that can be, certificated actually and under this standard. The standard recognizes that some packaging manufacturing sites also manufacture things like disposable, plastic and paper products for use in the food service sector. The manufacturing materials or technologies used are the same for both the packaging and for these disposable products. So those can actually be included underneath the scope of this standard. Only products that undergo manufacture at the site may be certificated. So not, if you buy in goods. Standard does not cover wholesale, transportation, importation, or storage activities, which are outside the control of the site to be certificated. BRCGS has a range of other standards such as stores and distribution and agents and brokers that actually cover these activities. There are no additional modules introduced in issue seven. Module 10 is still available, and it was reviewed to align with issue seven. That's the TMS Harvey standard. Packaging materials, packaging raw materials, packaging materials, and product manufactured using some similar technologies can be assessed against this standard. Single use disposable products we've had a lot of inquiries about this. I will try to maybe answer some of those inquiries now. So products manufactured using the same or similar technology as those used to make packaging materials, and all the raw materials, those can be, considered for certification under this standard if you the majority of the products you do offer the food industry, the containment of product, or offer food service. If you're manufacturing those kind of products, but they go into bags, which go to the retail shop, and it's sold as a 100 or 200 plates or or knives and forks, that is can be assessed under our, consumer product standard. So we do have an alternative standard. Throughout the review of the standard, there's been a very particular focus on the intended use of the finished product when considering and doing all the risk assessments associated with the standard. This allows the site to consider the risks and perform documented risk assessments to justify some of the decisions and rationales they use in the, product safety management system. We can go through that in more detail as we go through. So this is one of those key changes is the single use disposable products and is probably one of the most common questions we're getting. There is a seventy thirty rule. If if you're making at least 70% or more than 70% of of packaging materials or products destined for use in food service, they can be certificate against the site. If you're doing less than 30% or less, consumer products, then you can still use the standard. If you're doing over 30% of your production by volume is aimed at food service, then it's consumer products is the standard for you. That is currently being reviewed. So I'm red this year rather than blue. So I'm now gonna give you an overview of the changes. So whenever a BRCGS standard is issued, we always accompany it with two key documents. The first one is the key changes document, which you see on the right here. And I just give you a few snips from this document, and you can see here, you see some red writing. There's also some black cross step. Red writing is all the new requirements in the standard, and black crossed out is what indicates what was removed or amended. We highly recommend that you download a copy of the standard. If you had a certificated site, you should have access to this in participate. You actually see it in a PDF form. If not, you can buy it from the store. But it really does give you a good idea of what has actually changed within the the standard. On the right is our interpretation guideline, which is a very hefty document. I think it's about 250 pages now. If you don't know how to interpret the standard, if you don't know how to start the for the new requirements, the interpretation guide, which is not an auditable document, it gives you what could be best practice or at least a starting point. Again, a document we highly recommend that you access. So what are some of the the key changes from issue six to issue seven? One of the key updates is in section two, which is hazard analysis and risk assessment. This extra section is being reviewed in line with the requirement of codex alimentarius and to actually harmonize it with some of our other standards. There has been or there appears to be a lot of change. What has happened is we've actually reviewed the requirements, and we've put them much more streamlined in a systematic, way that you follow through step by step. So there's a lot of red, but when you look at it, there's not really that much new. Here is actually about the way we've set it out. Product safety culture from the first implementation of product safety culture by BRCGS has been a greater understanding of what culture is all about. As part of this standard further enhancement of consideration of behaviors and changes needed to improve culture have been embedded. Even now in 2024 was probably the last order that I did. Site still don't really know how to approach or how to demonstrate product safety culture. So in the requirements, we're kinda leading you through what you need to do in order to be able to demonstrate this. But let's be honest, You didn't wait for BRCGS to come along to tell you you need a product safety culture, product safety and quality culture. So, actually, you should already have that embedded. It's just how you demonstrate it. Management of outsourced processes. This has always been an area of some misunderstanding. So within this version of the standard, we've given some clarity on the definition, of what is outsourced products. And we've removed that term, which always, raised some confusion, which was subcontracted processes. Check our glossary to make sure you understand what the terms are. Allergen management. With recognition of the packaging industry's place as a key part of the supply chain for food and hygiene sensitive product, consideration for allergen risks from cross contact has been enhanced to ensure that where there is a risk identified by the horror team that appropriate control controls like segregation or personal training are put in place. Traceability, again, clarification has been given on the expectations of the importance of the traceability exercise. I will cover that in a bit more detail. Changes have been made to the protocol to bring this standard in line with other BRCGS standards, and we again, we'll cover that later. So let's move into some of those changes. So firstly probably the first thing to say is about the harmonization. As we, develop any standard within BRCGS, we try to harmonize the standard so there's a a BRCGS way of doing things. So we continue to have an emphasis on management commitment. It's section one of product but actually by design. Product safety management system based on risk assessment has the analysis and risk assessment is a key requirement. The continuing objective of the standard is to focus on the intended use of the finished product, risk assessments in relation to the manufacturing process, with that intended use in mind. This ensured ensures that product is made safely and in a legal way. We also make sure that the culture that we require or we suggest you put in place actually results in continual improvement. So there's been a a big harmonization of this standard. There's also been some change in terminology, which are quite key if you're used to this standard. We've tried to harmonize this through our technical working group, so it's a very global understanding. So we've removed, staff employees, and every time we talk about people, we talk about personnel. Production to ensure ambiguity is being changed to manufacture, because in some countries and cultures, they talk about manufacture. Intermediate is being exchanged with, for clarity purposes with work in progress. Company and site very often are synonymous. We try to use site where we talk about the site that has been certificated but we do understand that sometimes there's a head office organization or company so we try to use those words there for clarity. The terminology packaging has been replaced with product because now of course we're covering single use disposable products so we can't call it just packaging anymore. And then the removal of subcontracted activities is now referred to as outsourced processes. So this is a snip actually of section one. Senior management commitment, as I said, they're by design, not by default. And you can see here as a snip from the interpretive from the key to prod key changes document. You can see in red where there's been some change. So the statement of intent has been enhanced to include a clear requirement for continual improvement. No ifs or buts, but there should be continual improvement. This was a key consideration during the review process to ensure that there is the senior leadership commitment in all areas with the aim of ensuring improvements are effective and add value to the organization. You will see from this snip on the right hand side just to show you what the key changes look like. We've given a little a few small comments just to say why the changes were were made. Moving on then to section one, one point one point two, product safety and culture. A fundamental factor in the management of product safety is the culture which prevails at the site. The attitudes, values, and beliefs of those who work within the organization. This needs good strong leadership through commitment, support, communication both ways upwards and downwards and resources. Without this culture and management, continual management commitment, it is unlikely that the standard would be consistently applied or certification achieved or maintained. In line with the focus on product safety and quality culture, some sites still struggle on how to implement or demonstrate why they do what they do and what the improvements are. So through the requirements we've added to the the standard, we hopefully guide insights through what needs to be in place so they can demonstrate. So and a third party, the auditor, that this system is now in place. So moving on to an, a new section, which is one point one point three, and this is about the harmonization with other standards. We brought in this requirement for confidential reporting. There is a need for mechanism to be in place and all personnel to understand their responsibilities to bring concerns to the attention of the company or site or to use the reporting system for confidential issues and for records of the issues to be maintained so the site can demonstrate that this is actually in place. One point three point three on resources. It's been recognized that a number of organizations rely on additional external expertise to supplement knowledge which supports product safety legality and quality requirements on-site. So it's now clear that where external expertise is used is vital that it remains understood that the management of all requirements of the standard does remain the responsibility of the site and have not devolved out to a third party. It's a bit small, but has this analysis and risk assessment. Let me go through some of the changes. We've reviewed this in line with, Cortex alimentarius. Obviously, it's not a food standard, but we've tried to use the same logical flow of the process. There's a need for a team to be set up. That's the very first thing you do. The set team should be knowledgeable in the processes, products, and knowledge in the standard and the use of the product for its intended purposes. Review of prerequisite programs and how they support the site in the manufacture of safe, legal, and quality products. Those are the three buzzwords all the way through. Prerequisites to all those supporting systems from procedures to walls, floors, and ceilings, and the structure of the plant, internal and external audits, supplier approval, pest management, storage, training, control of contamination risks, etcetera. All those are the prerequisite corporates that needs to be in place to ensure the manufacture of those safe products. There are other requirements in terms of HACCP. The process flow there needs to be a process flow diagram, which is put in place after the, HAS analysis has been put in place, and that is actually verified. There's then a requirement to determine where you have your critical requirements, and we here, we have made a change from critical control points, which is very much food orientated, to critical control measures. So this is very much owned by the packaging industry. And it's one of the the biggest kind of, changes we've made, but it's not really in what you do. You still control the critical things, those essential to the production of safe products. Doesn't matter what you call it. It's how you control it. And you'll see in the definition, we've got a definition of critical control measures, but there are is the same as critical control points. We just try to move it away from food. There's a requirement for the documentation and keeping of records. So allergen management. So as a requirement of of horror, allergen management is a requirement of this the the horror team to look at where it could be an issue for allergens from cross contact with which need to be considered, by the site in terms of you need extra segregation, do you need training of personnel? So allergen management is very much now forefront within the standard and needs to be considered as part of the HARA. If you had to review your HARA in line with issue seven, please make sure that you review what the requirements are for allergen management. We then get on to section three, which is about product safety and quality management systems. It's falling off the end of the slide there, I'm afraid. In many instances, the standard specifically states that the requirement shall be satisfied by procedures, processes, plans, or records in other areas of the standard this is implied. Let's understand and be clear. There is still an expectation that there will be a documented system in place so that there can be consistency in approach, documents for training, work instructions, and those documents needed to ensure that the requirements, behaviors, processes, etcetera, are understood and are in place. Documents and records can be hard copy or electronic versions. Some of the key areas where there's been a change. Under the requirements for specification, so 3.4, changes made to ensure that there is always sufficient detail within the documents to allow consideration for product safety, legality, and quality. These are requirements for materials that impart or provide functional effects on the safety of the final products, maybe a barrier layer in a bottle that stops light or oxygen. That the specification shall include references to substantiate proof of any claims including the effectiveness of the claim. Internal audit, this is now this is now being made clear even though there seems to be some questions that the expectations of the orders to occur throughout the year, so more than once, and not just once a year. Also, the all activities within the product safety and quality management system will be subject to an internal audit at least annually. The aim is to ensure that the benefits of the audits are achieved and information can be reviewed by senior leaders. So particularly if a if there's been an investment in, say, allergen training, that the through the internal audit, you can demonstrate if that is actually being effective and and is added value. 3.6, supplier approval and performance monitoring. Here the main update has been to clarify the approval process and what materials are included, both raw materials and finished product packaging materials. Three point six point two, there is now acceptance of globally recognized quality management systems such as ISO 20 ISO 19 ISO 9,001. Sorry. That as long as those audits that are carried out at your supplies that they have a prerequisites traceability and they confirm the safety and legality of the product, that based on your risk assessment, you can actually choose to accept those certificates and reports because you need to look at the report. For example, some of the very large multinational global resin companies, for example, they don't necessarily partake in one of these GFSI recognized standards, but they have ISO 9,001. This allows you, as long as you can prove that the product's safe, legal, with the traceability and prerequisites are in place, that you can actually accept that as part of your supplier approval. Another key change is the management of outsourced processes. So here, the requirement is the, and and there is a definition that if you, make a product and you send it off-site for a process, that then is brought back onto your site for finishing. That's an outsourced process. And it's important that people understand that and check and see how they review those activities. Any outsourced processes are to be agreed and documented in service specifications, and this should be reviewed within the horror plan. There is also requirement for monitoring and approval of outsourced processes, so more robustness has been added to this requirement. Traceability three ten four always seems to be a a key one, but traceability is vitally important. Changes made to this section, are to ensure that the trace exercises performed across the product range. There shall be a summary of the traceability test, and all documents referenced during the test shall be part of the evidence of the test to confirm the effectiveness and that the exercise the trace exercise should should, not shall, should be completed within four hours. We move on then to the new section of three fourteen six, which is which is the management of the incidents. This is the only new clause in three fourteen. This specifies that sites must notify their current certification body in the event of any significant product safety or legality issue within three working days of the issue. The kind of issues could be a product recall. So you now need to tell your CV. If we get on then to section four and site standards, I'm only gonna go through some of the main changes. There are some changes. If we look at section 4.2, building fabric. Here we have divided the requirements. Before, it was walls, floors, and ceilings all kind of in the same area. If in order to raise a nonconformity, you didn't necessarily know if it was walls, floors, and ceilings. So what we've done is we split this out into those individual categories. If you have an issue against your floor, it's raised against floors. So that helps you in doing your corrective actions in the order turn, being able to assign the the issue to the right clause. Four three one for utilities. It is for the site to consider the intended use of the finished product when looking at utilities and standards that need to be maintained. Clause four point four point one for product defense. More guidance has been given on what needs to be considered for the product defense plan. Four six four, the equipment the for equipment, there is now a new requirement for specifications. I really recommend you read, the this in detail. So prior to the procurement of new or new to site equipment, things that have been moved from a sister site, there is a requirement now that, the intended use of the equipment is defined, and any specific requirements for product safety can be built into the specification of this material prior to procurement so you make sure that you actually buy it right first time. These requirements should be assessed by the whole team or suitable on-site personnel. Commissioning of equipment should be risk based and line clearance in place after installation with the aim to reduce the potential for contamination of the product. Then move on to four point eight point six, the previous standards for the introduction of environmental monitoring programs. Now in issue seven, we've moved forward on this. There's a new clause added to ensure that with it is programmed, then there is a review of the program at least annually to ensure it's effective. This is a new requirement, and sites really need to be familiar with this requirement to ensure that they are confident in their programs. This is where the program is being requested or is needed. If you don't need one, then you don't need to do that. But if you have to have an environmental monitoring program, you have to verify it. Going on to allergen management, this was not considered in issue six in the same way as we have it here as its own clause. Sites must now consider allergens as part of the horror. I've already said that. And establish, implement, and maintain an allergen management plan. Where there's an allergen risk identified, then the mitigation for control is needed. It also includes requirement for training of personnel and control via segregation if that's what's needed. Four point nine point five, is new. It's not a new requirement, but it's a new clause. What we've done is all those extraneous matter, foreign bodies like, pens, pencils, and screws, nuts bolts. We brought that all into its own sections. So, if there's a foreign body issue without having to try to find somewhere to put it, we've now allocated a new clause for the potential physical contamination. Section five, product and process control. Here, there are a few clauses that have been added or amended to align with other BRCGS standards. The most significant are the amendments made to section 5.4, manufacturing process control. So five point four point six to which requires, a procedure to be in place in the event of equipment failure and the appropriate controls of product to prevent nonconforming product release. So it's about that control. Five point four point seven requires that the site ensure that product conforms to legal or customer requirements The product is sold by count or or weight. The requirement is to ensure the controls are in place to meet customer needs. Five four eight, where requirements required by the customer sample retention processes are in place. We had it as a requirement for artwork before. This is where, the customer requires sample retention. Five four ten requires site to consider the safety, legality, and quality risks associated with products, materials, or areas of the site that are outside the scope of certification. So it's important to sites to realize even those, products, process, or storage areas which are effectively out scope, if they can have an impact on the manufacturing activities covered into the scope of the standard, they are and can be part of the the audit activity. Further additional clauses, five point five point two, which requires that the accuracy of measuring equipment relative to product parameters being controlled, are maintained within permitted tolerances and are able to demonstrate this. So this is about calibration. Five six two has added that equipment used for inspection and testing are validated, and there's a procedure for this and where possible that recognized test methods are actually used. We then get to personnel section six. Training and competence of personnel, remember personnel not employees or staff. This is still remains a fundamental. The emphasis of the review of personal requirements is focused on the intended use of a finished product and the site assessment of risks associated with their manufacturing operations. There is a change, and this relies on the site's risk assessment, which needs to be available for review. There's no right and there's no wrong. It's how well it's justified now on what you do what you do in relation to the intended use of the product. This ensures that appropriate measures are put in place relevant to the processes. For example, for class glass manufacture, they we do have a glass manufacturing guideline. They may allow or need to allow drinking of water near to the line because of the temperature which glass is actually produced. We then look at protective clothing. It's up to the site note to justify if a hairnet is needed. If it's product food contact, packaging, it's very hard to justify why you wouldn't wear full protective clothing. So section seven, traded products. The requirement has been aligned with the requirements laid out in other standards, so other BRCGS standards. And it has also been aligned with the requirements of section three. The main change here has been the addition of clause 7.1 that all operations must now be considered as part of the horror plan. This can be as a separate horror plan or within the site, the certificate of site's horror plan. The aim is to ensure that all products and the processes for which the site is responsible for are considered under horror. This is, as a minimum, is expected to be the receipt storage and dispatch of goods. Seven point two point two approval and performance monitoring of manufacturers, packers of traded products. This is now aligned with the requirements of the standard, but does require a traceability test to be performed for these product, for the traded products. If you bring in a quantity, you should be able to trace it. Ongoing approval of those, sites delivering manufacturers and packers needs to be performed on a risk based at determined intervals, agree agreed intervals. Other changes to the clauses in this section have been made to provide clarity and to line with other standards. So So that was a very brief outline of the changes, and it was quite rapid. Remember, we have a key changes document as well as the interpretation guideline, which are available, which gives more information. What I'd like to do now is to just move on and talk about some of the changes in the protocol. Audit options. Audit options brings packaging materials in line with the BRCG a g a yeah. BRCGS standards. The number of audits, that an auditor can now perform has been changed. So US certificated sites may have seen the same auditor for, three years, and then your auditor had to change. We've actually changed that for a couple of reasons. One is because there is a a lack of auditors in the industry. But, also, we felt that it wasn't actually, so important that auditors couldn't build up some experience at the site. So now auditors can visit your sites for up to five consecutive audits before they need to change with the aim that people don't get too familiar. The audit duration, will remain the same. What we do with the new standard for the first six months, the standard is launched. We keep the same audit duration. We collect data from sites, from auditors and CVs to see if based on the new requirements we need more time. Remember, we had three three hundred and sixteen requirements in issue six and three hundred and fifteen in issue seven. The feedback so far is it it seems to be working quite well. Audit options. There are three audit options. This hasn't really changed. But, again, this is aligned with with other standards within BRCGS. We've got announced audits, the blended audits, and the, unannounced voluntary audit. Announced audits because, BRCGS, it has been recognized in the past against GFSI requirements, the global food safety requirements. It is a GFSI requirement that one in every three years, the audit is unannounced. So if you sign up to the announced system, mandatorily, one in every three years, that audit needs to be unannounced. And that's truly unannounced. There's no telephone call I'm on my way. There's no telephone call saying coming tomorrow, it's unannounced. We then have the blended audit, which has two elements, the the on-site document review followed up sometime later by the the the factory inspection. And this audit, even if you sign up to the blended audit, one audit every three years must be unannounced. So that can't be a blended audit. It's also then the voluntary unannounced audit where the site you can volunteer and you speak to your CB about this, that you volunteer for all your audits to be unannounced. That's true confidence. So we move on then. Audit duration. I've already covered that. Supporting documents. So what do we have? So here's the standard. So on the left, you can see the standard. In the middle is the interpretation guide, and on the end is the key changes document, all of which are available either for download from our store or if you're in participate, you can access them. We have a, audit duration calculator, which the CBs will use. There are auditor and site self assessment checklist, which are available for if you're transitioning from six to seven, you can have access to the checklist. So you you as a site can actually see if you're you're ready for your audit and can plan, and can plan for it. Coming out probably about October, six months after the standard was launched, but by the end of the year, we will have a frequently asked questions. This is a dynamic document. We will be able to then, keep it a flowing document about what questions are being raised so we can answer those, and that is accessible. We have, best practice guidelines, one of which is a guideline for glass manufacturer, as well as additional modules. All that is available from the normal places. So this is just a little bit more. For auditors, there's a document on auditing techniques, there's certificate templates, and there's requirements for auditor competence as well. Translations. We started off with four translations. We had English, Italian, Chinese, and Spanish. We backed this up, I think it was issued probably around April time in German and French. So they have the standard, and they have the checklist. Let me be clear. The definitive and kind of legal standard is always the English standard. We do our very best in translations. We get the best help we can, but there are always new in nuances in language. So if in doubt, always refer to the English copy. The last part of my presentation today then is really to share with you some of the the feedback that we've been getting. Hopefully, this is value added. It says 48 plus. I've probably done about 50 of these, webinars. Now we've spoken to way, way over 8,000 people, and we've had hundreds of questions. But I'd like to go through the themes. So one of the themes was internal audit as probably you would have expected. And some of the queries we had was, well, I'm only a small site. Surely, I don't need to do, audits throughout the year or, you know, I'm I'm part of a corporate site. Do I really need to have an independent auditor? You can see some of the questions there. Let me answer, in general. There seems to be a a reluctance to do internal audit. Internal audit is seen maybe as a chore. It doesn't produce anything. It usually costs to do it, but it's one of the most valuable tools on your tool belt. As I said earlier, making sure that your systems are working for you and you are not a slave to your system. Use an internal audit. It should be a senior leadership tool to make sure that things are working as they are. Before things go wrong, you check-in to make sure that things are happening. So so, yes, there is a requirement that any size organizations do internal audits and there is throughout the year. It's at least at least two throughout the year suggest more than one. Personally, short, sharp, and sweet. Do lots of little audits, collect data, and to make sure that the system is working for yourself and see it as a value added tool. We then had some, questions on horror. So you can see here from the snips I've got that when you look at that, you can see there is actually appears to be a lot of change in horror. As I said earlier on, we've actually kind of made into more of a systematic flow. So there's a lot of red because there's a lot of movement. So a lot of sites have said, with all this change and all this red task, do do I need to go on training? Will my HACCP some people call it HACCP. Some people say CCP. It doesn't matter what you call it. It's what you do with it. Do I need to do training? My my my answer back is not necessarily. You review what you have. You review what standard requires. You review what you have, and you'll probably find that yours you're meeting the requirements and maybe some modifications you need to make. If you feel, I think I need some more training in Harla, then obviously get Harla training. And we did launch back in about June, I think, in new Harla training. I'm not here to to sell training. I'm here to tell you about the standard. Some of the other, questions we have, you know, I make I don't make full contact packaging. Do I need to wear a hairnet? I make food contact packaging. Do I need to wear a hairnet? It's up to you now. We've actually put the responsibility on the site to say, you need to do a risk assessment based on the intended use of the finished product to determine what protective clothing you need to to weigh, provide, and ensure is being worn properly to ensure that the control is in place for the product. So, again, it's about your risk assessment. It has to be documented, and you need to justify it well. And it's not one sentence or one paragraph. It's a really good in-depth study, and that needs to be available to actually show to the auditor. And then my my last slide is some other areas that we've had key questions on, which is about quality certification for suppliers. Yes. We do now allow, ISO 9,001 to be considered as part of your supplier approval procedure or process based on the fact you ensure traceability is in place and the product is legal and safe. Migration is covered by two point five point one. That is a very important part of the standard and, is for organizations to damage it, what that they understand, what the migration requirements are. Again, depending on the intended use of the finished product. Sorry if that was a bit fast, but that is kind of the end of my presentation. I'm gonna hand back to, Kenneth. Welcome, Emily from NSF, who's going to talk about, the auditing system. Thank you, Glenda, for the end of overview. Hello. I'm Emily Barnan, technical scheme lead for BRCGS within NSF. In my role, I manage compliance globally for all of the BRCGS certified standards within NSF. In this webinar, I will be reviewing two important elements within the BRCGS packaging standard that are often a question for facilities, the choice of audit programs and corrective action responses. Within the BRCGS packaging standard, facilities may opt for one of three audit programs, blended announced, voluntary and unannounced, or one in three mandatory unannounced. In blended announced, up to half of the audit duration is completed by remote technology, such as through Microsoft Teams, Zoom, etcetera. And at least half of the audit is completed on-site for the facility inspection. Remote part of the audit is completed first, followed by the inspection, which must occur within twenty eight days of the scheduled remote. Blended audits can only be announced. When the site is scheduled for the mandatory one and three unannounced, the blend and announce audit must then be fully on-site. A second program is the voluntary unannounced. Every year, the audit is completed as an unannounced audit with the date of audit falling sometime in the four months before the audit boundary end date. This is a voluntary program. If the facility does not opt for voluntary unannounced, then it must take part in the next program, which is the mandatory one in three unannounced. The mandatory one in three unannounced program requires that at least one audit every three years be unannounced. As you can see on the slide for the example here, the initial registration for this site was in 2024 and was announced. And in 2025, the reassessment was also announced. The facility then must have an unannounced audit in 2026. This is required under GFSI benchmark protocols and is detailed within section three of the standard. The specific program chosen by a facility should be discussed with NSF as the certification body when agreements are made or the facility contracts with NSF. Changes to which program you opt can be made from one program to another, such as from voluntary unannounced to blended announced, but this must occur within the three months following the last audit certification. Changes after this time may require approval by BRCGS under a concession and may not be granted at the time between the request and the facility's boundary date is too short. Blackout days are part of an unannounced audit protocol. For each unannounced audit, the facility will be asked to provide nominated blackout days. For sites that are on a twelve month audit schedule, the nomination of ten days is permitted. For sites that are on a six month audit schedule, such as if you have received a c or d grade, Nominated days are limited to five days. The facility should make NSF aware of any dates the facility is not operational, such as downtime events for maintenance holidays, as it is required that the audit is conducted when the site is operational and manufacturing. NSF cannot conduct an audit when the site is not manufacturing. These blackout dates or these downtime dates are not part of the nominated blackout days. Blackout days, by definition, are reserved for dates when the facility is operational, but the facility is not able to accommodate an audit due to planned activities. Examples of this may include scheduled regulatory visits, customer visit, or another audit. A certification body can challenge the reason for blackout dates and request evidence if needed. Examples of reasons that may be challenged include managers being sick or on vacation, as sites are still operating, and they train deputies required under the BRCGS standard. Another example that may prompt a challenge is when a facility gives ten consecutive Wednesdays or multiple weeks of consecutive Wednesdays to prevent an audit from being scheduled. This narrows down the available time for the audit, which lessens the ability for the audit to be truly unannounced. The standard requires the site or facility to notify their certification body at least four weeks prior to the beginning of the boundary window of any changes to downtime schedules, blackout dates, etcetera. Remember, for unannounced audits, the boundary window time frame is four months. And for announced audits, the boundary window is the twenty eight days prior to the boundary end date. Of course, if an emergency occurs, it is important to notify NSF immediately as BRCGS does allow the certification bodies to use discretion when it comes to emergencies. After an auditor has completed their audit, the next step a facility must take is to respond to any nonconformities with a corrective action. The audit is not complete and a certificate decision is not made until the nonconformities, if any, are closed and approved. Facilities are required to respond to nonconformities within specific time frames. For the initial registration audit under BRCGS packaging, facilities are allowed up to ninety days to submit their corrective action responses. However, they will not receive their certification until the responses have been reviewed by NSF and approved. So it is important to begin the process as soon as possible after the audit closing meeting on the last day to expedite the certification. Reassessment audits are for facilities previously certified, and the deadline for submitting corrective action responses is twenty eight days. This is to allow time for review and approval by the technical team or auditor and to request more information if needed and still meet the forty two days certification cycle deadline. In order to ensure a timely certification turnaround time, NSF requests all nonconformances responses be submitted within twenty one days of the last day to allow time for accurate review and to garner any needed clarification to avoid late car closures. NSF sends automated email reminders regarding the deadline dates for car closure. However, again, the requirement is within the twenty eight days. When responding to nonconformities in the corrective action report, it is important to remember that there are four elements required. Rejection of responses and request for more clarification can often occur because attention isn't paid to a robust corrective action response. Let's briefly discuss each element. The corrective action is the immediate action taken to correct the nonconformity. For an example, let's use a nonconformity of a piece of product or product contact tool or equipment found on the floor. The corrective action may be that equipment or tool was immediately removed from the floor, cleaned, sanitized, and placed in the appropriate location. Corrective actions may occur immediately or at a time when it's appropriate, but they address that immediate instance of the nonconformity found and how it was corrected. The second element is root cause. Determining the root cause through the use of root cause analysis methods such as five whys or Ishikawa diagrams is important. Conducting a robust root cause analysis is paramount to continuous improvement. It answers why the nonconformity occurred. In this example, it may be easy to say the operator did not follow training or needed more training, which is often a response our technical review team observes. But this is not in most case but this is in most cases a weak response and not the true root cause. In determining a root cause, dig deep into the nonconformity. For example, in this instance, it wasn't that the operator wasn't trained properly and so placed the eye on the floor, which he did. The root cause is that there was no place to stage the tool equipment within reasonable proximity to the operator, So they opted to place it on the floor instead of walking a long distance away from their station. They have been disciplined from leaving their station before. Root cause determination is not restating the nonconformity, but a deep dive into the true reason why the nonconformity existed. This leads us now to preventative action. The prevent action plan, therefore, must address the root cause. A preventive action plan aims to prevent the nonconformity from happening again. In this instance, the facility relocated the tool equipment platform closer to the point of use. In the NSF connect system, facilities can upload the evidence in support of the previous three elements. Evidence to prove the nonconformity has been addressed must be included to for review in order to move the audit to certification. What is considered evidence will depend on the type of nonconformity, but it can include pictures of before and after, revised SOPs, or revised records, etcetera. All elements of the corrective action response or report are reviewed by the NSF technical response team or by the auditor and must be closed as approved in order for the facility to receive a decision of BRCGS certified. All protocols presented here are supported and available to the facilities within the packaging standard in section three. Now I will turn the webinar back over to Ken. I'll address a couple, housekeeping items, and then we'll move to the q and a section. So, our first housekeeping item is that NSF does offer additional training about lots of ERCGS topics. So you can see down the slide here some of the upcoming courses that are happening, throughout the last part of 2025. And you can scan that QR code to access that training page on nsf.org or visit that website that's listed there below. The other piece of information that we'd like to share is some exciting news that NSF has, recently acquired Cambium Analytica. Cambium Analytica is a, analytical testing and developing company serving the natural food, beverage, and dietary supplement industries. With the addition of Cambium Analytica, NSF is now even better positioned to meet the accelerating demands of clients. And this enables companies to grow demand for natural food, beverage, and supplement products while ensuring safety and quality, particularly in those seeking to innovate. So if you'd like to learn more about what Cambium Analytica can do, you can certainly scan that QR code there or visit nsf.org and click on the homepage link for Cambium Analytica. We're now going to move to the q and a section. I am going to pull up a couple of the questions, and I know Glenda was ready to answer a few of those. So I'm gonna share the first one, which is, do you have any data on audit results against issue seven, such as common findings? So, Glenda, when you're able, please move to the move use your move on stage button, and we'll see if we can address the question. K. While we're while we are waiting for Glenda to get on stage, we did have a question about what is HARA an abbreviation for. We can address that right away. That is a Hazard Analysis and Risk Assessment is what HARA stands for. So let me, again, check and see if we can get Glenda and Emily to come on stage. If not, I will continue to share questions. She's been typing some answers, so we actually do have some we could get to. Here we are. Okay. Hi, Glenda. Hi, Emily. I wanted to announce that, also, Kenneth NSF was awarded, at the America's Conference certification body of the year for The Americas for 2025. So that's something that we are quite proud of. That is good news, and congratulations to you and your team on that one. Wanda, are you ready to respond to the question about data on auto re audit results against issue seven, some common findings? I I think so. Can you hear me now? Yes. We can. Perfect. Sorry about that technical issues. It's a very, very good question. What usually happens with a new standard at BRCGS, we wait, at least six months from the date of the go live audit, which was the April 28, to be able to collect data. So at the moment, we don't actually have any information directly from audits. We are compiling that information. At our recent conference in North America, I think I only had, like, three and a half months data, which is not significant to actually show any trends. What I will, feedback is that the audit duration seems to be kind of acceptable. We are looking at the audit duration. And in general, the new aspects of the standard seem to be well understood and applied. But, watch this space. I think you would be closer to the end of the year, early twenty twenty six when we'll be able to put out some information through also, a frequently asked questions document which will become right towards the end of the year. I know that's not acceptable, but, yeah, we have to wait until we get all of this data. That's terrific. Thank you. Another, another additional question. Must critical control measures include quality targets? I'll share that on the screen. Yeah. And that is very interesting question. Not necessarily. I mean, critical control measures, depending on on the product and the intended use of the product, it is actually aimed at the horror is actually aimed at product set to legality. Quality is really covered in other sections where you actually look at quality. But that kinda let's be honest. If you're doing a horror review and you're identifying really important quality parameters to the intended use of that product or customer requirements, there's no reason why you can't include it as long as it's made very clear it's a product quality and not product safety and legality. Great. Thank you. We have a a couple of other questions. One which is answered fairly easily. I will share that to the screen now, which was how can one register for the HARA cost offered by BRCGS? And, I got an internal note here from Glenda that BRCGS does have a link, where folks can register to the BRCGS HARA course. So I will add that link to the chat as we move as we move forward to our next question, which was, could you please give, some more explanation about the changes regarding allergens overall and specifically in the heart? Absolutely. And, again, some of the frequently asked questions you've had during the the myriad of, webinars you've done has been on allergens. So allergens, is not new to the standard, but what we've done is we've kind of pulled allergens out. So once part of horror, the manufacturing site is now expected to actually consider, biological, chemical, microbiological, radiological, and allergens, maybe under chemical or not, to consider if allergens is actually a risk to the manufacturing process and to the manufacturing environment. And then we actually have a new section, which is four point nine point five, which actually looks at that if the horror identifies the allergens at a risk, it actually goes through then what is expected at the site to actually take that risk and actually mitigate that risk, which could be training of, their their staff so they understand the risk associated with allergens, remembering how close the packaging is to the the finished product, which could be food. But also then if there are any additional requirements which you needed like segregation, product segregation, time segregation, physical segregation to make sure that allergens can be contained and not become a risk. I would suggest people look at at the interpretation guidance where there's a lot more information there. Great. And we have one last question, who's asking about any training on subject we've heard, we've heard about before. The five whys of corrective action. Now I don't know whether NSF specifically has training on there, but do use that NSF training link. You can check on there. Wanda, is there anything that BRCGS offers on the five whys of corrective action? Yes. I mean, definitely, we have training courses on root cause analysis. We also have a publication on root cause analysis. It's not necessarily direct, only for use for the BRCGS standard, but it's actually looking at the technique of root cause analysis in all of the different ways and the different tools that can be used. And to be very honest, root cause analysis team still seems to be a mystery to a lot of people. They're they go into the first way, addressing that without actually looking deeper, and then having further issues. So we have a publication, which is available on the BRCGS store. Or if you're a certificated site, you can access it from participate. Or there's also not or. And there's also a root cause analysis training course, which is available from BRCGS and the, approved training providers. That's great. Thank you. Well, I think we have worked through all of the questions that we've had submitted. So once again, we're very thankful to our presenters, Emily and Glenda, for all of that great information today. If you're a participant today and you have further follow-up questions, you can always contact NSF using the contact section of n s f dot org. Beyond that, we appreciate your participation and your support of food safety. And, this will end today's webinar. Thank you everyone for attending. And, again, thank you to our presenters. Thank you. And you're welcome.