In November 2017, BRC issued the first draft of the proposed BRC Global Standard for Food Safety Issue 8 (often referred to as ‘BRC8’). The consultation period allowed us to preview the amends and their impact, as well as submit feedback.
As expected, the proposal includes several new clauses. One of these relates to factory pens and detectable pens. Clause 220.127.116.11 states “Pens used in open product areas shall be controlled to minimise risk of physical contamination (e.g. designed without small parts and detectable by foreign body detection equipment)”.
This presents potential problems with the pens some food factories are using. The key phrases in this clause include “controlled”, “minimise risk”, “without small parts” and “detectable”. “Controlled” and “minimise risk” have become key industry phrases in recent years. In fact, we would now consider them to be standard procedure, so they do not cause any alarm.
However, “without small parts” is a potential cause for concern. As there is no fixed definition of “small parts”, it is open to interpretation. Nevertheless, it is widely accepted to cover anything that may prove difficult for metal and/or x-ray detectors to identify. This introduces variables around the fourth key phrase – “detectable” – into consideration.
If you take the factory pen apart, are there any components which are likely to cause a problem? A common offender is metal coil springs. You may think metal springs are detectable because they are metal, but this is a wrong assumption. A spring is only a coiled piece of wire. This means the ‘signal’ omitted is hardly different to the background signal (especially in ‘wet’ products such as ready meals). As a result, it has a negligible chance of being detected. This is before we even take the orientation of the spring as it passes through the metal or x-ray detector into consideration.
You then need to consider what happens to your factory pen under force. Does it snap and shatter or does it flex and bend? The higher the metal content of a detectable pen the more brittle it becomes, and brittle is not a good thing. It means there is a substantially higher risk of your pen shattering under pressure. As a result, small ‘splinters’ are flung far and wide in an uncontrolled manner. Such small fragments are almost impossible for metal and x-ray detectors to pick up (especially over the background ‘signal’). Consequently, detectable pens which shatter are not compliant with the new BRC8 clause.
Prevention before detection.
This new BRC8 clause means many factories will need to change their factory pens and detectable pens if they wish to comply. How does this affect users of the Retreeva Global detectable pen? In short, it doesn’t. Retreeva Global’s policy of ‘prevention before detection’ means our pens are already compliant. You can download the Technical Memorandum as documented proof for your auditors.
So just how do Retreeva Global pens comply with the new BRC8 requirements?
- Detectable by both metal and x-ray foreign body detection equipment.
- Virtually unbreakable. Made from shatterproof polymers, they are not prone to cracking, snapping or shattering. Under unreasonable and unnatural force, they may bend or distort, but do not splinter into un-detectable shards.
- Do not contain metal springs.
- Minimum number of components. Retreeva Global pens contain no more than 3 components, further reducing the contamination risk.
- Lanyard loops and pocket clips are an integral part of the pen -they are not detachable components. This eliminates the issue of small parts presented by many detectable pens.
How should you you prepare for these BRC8 requirements?
The BRC Global Standard for Food Safety Issue 8 is expected to be published in August 2018 and auditable from February 2019. Consider the following three steps:
- Check your current pens against clause 18.104.22.168. Think about how you can reduce foreign body contamination risks and improve the detectability of your factory pens.
- Consider conducting a shatter test on your current detectable pen – can you account for every splinter and shard? If not, you need to take action.
- Do your current factory pens contain metal springs? If yes, you need to take action.
Retreeva Global is the detectable pen of choice for many leading food manufacturers. This includes Cargill, PepsiCo, Heinz, GreenCore, Moy Park, Muller Wiseman, 2 Sisters Food Group, XPO Logistics and many others! Contact the Retreeva team today to find distributors in your region.