Issue 9 of The BRCGS Global Food Safety Standard has been auditable since February 2023. Only one section mentions pens directly – Clause 18.104.22.168
Benchmarking standards of safety and quality for global food training, Issue 9 of the Food Safety Standard is a popular resource for food and beverage production sites around the world. In fact, many sites have already been audited against this issue, with early audit data shared towards the end of last year. Covering topics like product control, site standards, personnel, and food safety, this publication directly references pens in Clause 22.214.171.124. This clause also appeared in Issue 8 of the Food Safety Standard. It stated:
“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)”.
(BRCGS8 Ref. 126.96.36.199.)
In Issue 9, the message behind this clause is almost identical. However, BRCGS has now outlined its expectations in more detail:
“Portable handheld equipment, e.g. stationery items (pens, pencils ect.), mobile phones, tablets and similar portable items used in open product areas, shall be controlled by the site to minimise the risk of physical contamination. The site may consider, for example:
- Excluding non-approved items
- Restricting the use to site-issued equipment
- Ensuring stationery items such as pens are designed without small external parts and are detectable by foreign-body detection equipment, or are used in designated areas where contamination is prevented.”
(BRCGS9 Ref. 188.8.131.52.)
There are two key phrases to unpack here: “without small external parts” and “detectable by foreign-body detection equipment.”
Small External Parts
Whilst Issue 8 referenced “small parts”, Issue 9 places emphasis on “small external parts” such as lanyard loops and pocket clips.
These features can prove invaluable when it comes to operatives keeping hold of their pens – reducing the risk of an item ending up somewhere it shouldn’t be, namely your product.
So, what’s the solution if small external parts are officially classed as a risk?
Here at Retreeva Global, the lanyard loops and pockets clips on our pens are integral. This means that instead of being detachable components, they are built into the body of the pen, eliminating the risk of them snapping off.
The next step is to consider what happens to your 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 the more likely it is to shatter under pressure. As a result, small ‘splinters’ are flung far and wide in an uncontrolled manner. Fragments of this size are almost impossible for metal and x-ray detectors to pick up (especially over the background ‘signal’). Consequently, detectable pens that shatter are not compliant with BRCGS guidelines.
Fortunately, we operate under the ethos: prevention before detection, offering shatterproof pens that will not splinter under duress. Even if they are subjected to unnatural or unreasonable force, Retreeva Global pens will only ever bend or break into two parts. This eliminates the risk of miniscule shards making their way into your product.
We have also found a way to produce pens that provide a firm writing experience without the presence of a metal spring. Instead, they feature a unique cartridge suspension system that offers the smooth feel of a spring pen, without any of the unnecessary risks.
Why is this such an important breakthrough?
It would make sense to assume a metal spring will be picked up by your metal detectors, but this is incorrect. A spring is only a coiled piece of wire, so the ‘signal’ it omits is almost identical to the background signal of your detector. This is especially true of ‘wet’ products such as ready meals. As a result, a metal spring has almost no chance of being detected, and this is before we even factor in the orientation of the spring as it passes through the detector.
Download your Technical Memorandum
Clause 184.108.40.206 will require many factories to change their pens in an effort to secure compliance.
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.
How do Retreeva Global pens comply with BRCGS 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.
- Contain the minimum number of components. Retreeva Global pens contain no more than three 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 risk of small parts snapping off.
How do I ensure my pens meet the requirements outlined in Issue 9 of the BRCGS Global Food Safety Standard?
- Check your current pens against Clause 220.127.116.11. Think about how you can reduce foreign body contamination risks and improve the detectability of your factory pens.
- Conduct a shatter test on the pens at your site. Can you account for every splinter and shard? If not, you need to consider the consequences of this happening around an active production line.
- Do your current factory pens contain metal springs? If yes, we would recommend switching to an alternative.
Retreeva Global is the detectable pen of choice for many leading food manufacturers. This list 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.