In November 2017, BRC issued the first draft of the proposed BRC Global Standard for Food Safety Issue 8 (often referred to as ‘BRC8’). BRC Issue 7 was published in January 2015 and came into effect July 1st 2015. Issue 8 will be published in July/August 2018 comes into effect from January/February 2019.
The number of BRC accredited/certified sites shows the increased international popularity of the BRC Global Standard for Food Safety. Currently there are almost 26,000 certified sites in 130 countries with the USA being the area of greatest growth. The new BRC8 proposal includes multiple new clauses, one relating to factory pens and detectable pens.
Clause 188.8.131.52 states:
“Pens used in open product areas shall be controlled to minimize risk of physical contamination (e.g. designed without small parts and detectable by foreign body detection equipment)”.
Some key phrases from Clause 184.108.40.206 include; “controlled”, “minimize risk”, “without small parts” and “detectable”.
While “controlled” and “minimize risk” have become key industry phrases in recent years, “without small parts” has an open ended definition as it is arguable what is considered to be “small parts.” 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.
Some foods facilities are using pens that are not in protocol with the new global food standard. For example, if you were to ask are there any components to a non detectable factory pen that could cause a contamination issue, there are a few common offenders.
- Metal Coil Springs:
These springs are commonly thought as a detectable “small part” because they are metal, however these springs are really 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 slim 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.
- When force is applied, does your pen snap and shatter or does it flex and bend?
The higher the metal content of a detectable pen, the more brittle it becomes. Having a brittle pen can result in 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.