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Industry Spotlight: New BRCGS Issue 8 – Part 3

May 17, 2022 BRCGS
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Industry Spotlight: New BRCGS Issue 8 – Part 3


We have been covering the changes introduced by the BRCGS (Brand Reputation Compliance Global Standards) in its latest issue 8 through our three-part blog series. You can read the first part here (4 New Changes in New BRCGS Issue 8 and How They Affect Food Grade FIBCs – Part 1) and the second part here (Industry Spotlight: New BRCGS Issue 8 – Part 2).

In this third and final part, we’ll shed the light on some of the other important revisions of Issue 8.

Risk Assessment

Clause 4.2.3 comes with new regulations and a wider remit than in Issue 7. It requires areas of external storage and intake points for products and raw materials to be assessed for risk. The provision also includes risk assessment for packaging. It emphasizes policies and systems to be enforced to ensure access to production and storage areas only by authorised personnel, while controlling the access of employees, contractors and visitors to the site.

Protection of Bulbs and Strip Lights

Clause 4.9.3.5 calls for adequate protection of bulbs and strip lights (including those on electric fly-killer devices) where they pose a risk to product. In case, it’s not possible to offer full protection, there should be an alternative arrangement such as wire-mesh screens or monitoring procedures in place.

Management of Clean-in-Place (CIP) Systems

Clause 4.11.7.1 is a rewriting of the older clause to improve clarity and include guidelines for the management of CIP systems. It says that a competent individual must authorize any changes or additions to the CIP system before the alterations take place. A record of changes should be maintained and the system must be revalidated at intervals, depending on the risk after any change or addition.

Environmental Monitoring

Clause 4.11.8.3 recommends a company to review their environmental monitoring programme annually and in case of events such as:

  • changes in processing conditions, process flow or equipment
  • new developments in scientific information
  • failures of the programme

The review should be considered for internal audits.

Preventing the Use of Obsolete Packaging

Clause 5.5.3 prescribes a new guideline to ensure that processes are in place to prevent accidental use of obsolete packaging. It requires the company to maintain a process to manage obsolete packaging (including labels). The process should include

  • mechanisms to prevent careless or unintentional use of obsolete packaging
  • control and disposal of obsolete packaging
  • proper procedures for the disposal of obsolete printed materials

Waste Disposal

A new addition to the Issue 8, clause 8.6.1 covers guidelines for waste disposal systems to minimize the risk of contamination and control any potential cross-contamination. The risk assessment process should take into account the transfer and flow of waste and waste containers. As an example, it states “waste bins should be dedicated to either high-risk or high care areas and not be moved between different production risk zones”.

At BulkCorp, we operate with a thorough understanding and compliance of BRCGS guidelines of safe packaging. We will continue to adapt and upgrade our operations to the evolving BRCGS regulations to not only safeguard, but bolster the trust of food-grade FIBC buyers in our products.

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