Packaging Hygiene and Contamination Control: BRCGS Issue 7 Checklist

Where do you start: how does the HARA set the level of hygiene?

With the intended use of each product. Issue 7 does not hand out one list of controls for every site. It asks the HARA team to describe each product, its intended use and its restrictions on use, such as direct contact with food or other hygiene-sensitive products (clause 2.3.2), then to analyse microbiological, physical and chemical hazards at every step (2.5.1).

The analysis singles out significant hazards by weighing two criteria: the likelihood of occurrence, given the prerequisite programmes in place, and the severity of the outcome (2.5.2). The prerequisite programmes the Standard lists are precisely about hygiene: cleaning, contamination control, pest management, maintenance, personal hygiene (2.2.1).

Take two sites we often meet. A tray maker in Kenitra supplies berry packers: the fruit will not be washed, the tray is in direct contact, and microbiological contamination or a fragment becomes a consumer risk. A carton maker in the Souss region produces transport cases for citrus: contact is indirect, and the main hazard is physical (staples, splinters, pests). Both apply the same Standard, but not the same clothing, the same cleaning or the same sampling frequency.

The HARA leads to a map of areas. Areas where exposed food or hygiene-sensitive contact surfaces are present must be defined, clearly identified, monitored and controlled (4.4.1). The site plan shows staff access points, the routes taken by raw materials, work in progress, finished products and waste, and the areas that need additional controls, such as a clean room (4.5.1).

How do you control foreign bodies?

Through written rules for each known source, and through recorded checks. Clause 4.9 asks the site to take every practicable step to identify, eliminate, avoid or minimise the risk of foreign-body contamination. The sources to cover are always the same.

• Glass and brittle materials. No unnecessary glass; a register giving the location, number, type and condition of each item, with checks at a risk-based frequency; a breakage procedure that puts a responsible person in charge, prevents contamination of other areas, segregates affected product and records every incident (4.9.1). Windows and lighting, including on flying-insect control devices, are protected where they present a risk (4.2.5 and 4.2.6).
• Sharps and metal. A procedure for issuing and storing knives, blades, needles and wires, with records of replacements and breakages. Snap-off blade knives are banned, and blades built into machines are monitored (4.9.2).
• Wood, staples, paper clips, drawing pins. Wooden furniture is sealed and free of splinters where it presents a risk; staples, paper clips and drawing pins are not used where product is exposed (4.9.5).
• Portable equipment. Phones, tablets and instruments issued by the site are controlled (4.9.5.4).
• Maintenance. Equipment whose failure could release fragments is inspected at set intervals, every intervention ends with a clearance inspection, tools are put away, and workshops are kept clean, with swarf trap mats (4.7.2 to 4.7.5). After new equipment is installed, an inspection records that contamination hazards have been removed (4.6.3).
• Pallets and vehicles. Pallets are checked before use and must be intact, dry and clean; vehicles and containers are checked for cleanliness and odour before loading (5.9.3 and 5.9.5).

Where detection relies on in-line equipment (camera, detector), the site checks that it is set up correctly and able to alert or reject, at the start and end of runs where appropriate (5.6.4).

How do you handle chemicals, migration and allergens?

At three levels: the plant’s own chemicals, substances that can migrate from the packaging into the food, and allergens.

Non-manufacturing chemicals (lubricants, cleaning products) are covered by a procedure that includes, at a minimum, a register of approved chemicals, confirmation that they are suitable, including for food or hygiene-sensitive contact, safety data sheets, no strongly scented products where they could taint, designated storage with restricted access, and use by trained staff only (4.9.3). Lubrication points must not be able to contaminate the product (4.6.1).

Migration is handled in the HARA, which must take into account the migration of substances and recycled materials (2.5.1). The critical-use parameters agreed with the customer include migration testing where relevant (5.1.1). For packaging sold in the European Union, the European Commission notes that Regulation (EU) No 10/2011 sets, for plastics, an overall migration limit of 60 mg/kg of food or 10 mg/dm², together with specific migration limits. Any test critical to safety or legality must be carried out by a laboratory that is accredited or operates to the requirements and principles of ISO/IEC 17025 (5.6.6). The result feeds the statement of compliance required for every food-contact product (3.4.3).

For a printer, the typical hazard is set-off: ink transferring from the printed side to the food-contact side, on the reel or in the stack. You manage it with the data sheets from your ink, varnish and adhesive suppliers. BRCGS also lists PFAS and mineral oils among the sector’s emerging concerns.

Allergens: if the HARA identifies a risk of contamination from allergens or intrinsically allergenic components, the site sets up an allergen management plan that meets labelling law in the country of sale, reviewed in particular whenever raw materials or lubricants change (4.9.4).

How do you clean, disinfect and prove it works?

With risk-based cleaning schedules, then proof that the result is achieved. Cleaning is a fundamental requirement of Issue 7 (4.8).

Each schedule states who is responsible, the area or item, the frequency, the method, the materials, the record and the verification (4.8.2). Since 10 August 2026, position statement P708 adds disinfection where appropriate, and requires cleaning standards to be validated and verified according to the risk of the product’s intended use. Housekeeping includes a “clean as you go” or condition-based cleaning policy (4.8.1). Cleaning equipment is fit for purpose and kept in a designated place, and the equipment used for toilets is kept separate from the rest (4.8.3 and 4.8.4).

A monitoring programme that has returned only negative results for years must itself be reviewed: clause 4.8.6 requires a review when results are consistently negative.

What rules apply to people and pests?

Risk-based rules, written down, checked and explained in the teams’ own language. Personal hygiene requirements take the intended use of the finished product into account (6.2.1).

• Jewellery, watches, nails, perfume: rules set from the risk assessment, with the exceptions the Standard allows (plain wedding ring, medical alert jewellery), and routine checks (6.2.1).
• Plasters: a colour different from the product, preferably blue (6.2.4).
• Handwashing: before work, after breaks and as often as the risk requires; washbasins with water at a suitable temperature, unscented soap, hand drying and signs in the appropriate languages (6.2.5 and 6.3.4).
• Eating, drinking, smoking: banned in production and storage; water allowed only in designated areas, in suitable containers (6.3.8 and 6.3.9).
• Health: symptoms to report, and exclusion from work in contact with the product for as long as they persist where there is a risk (6.4.1).
• Clothing: hair coverings, beard snoods, protective clothing, footwear and gloves considered according to risk, with any exemption justified; no external pockets above the waist and no sewn-on buttons (6.5.1 and 6.5.2).
• Pests: a preventive programme across the whole site, adjusted for the seasons, a numbered plan of devices, catch analysis from insect control devices, and measures to keep birds out above loading bays (4.11).

Which hotspots apply to your material?

The same clauses apply to everyone, but the dominant hazards change. The table shows the ones we deal with first on our assignments.

Use this checklist on every shop-floor round:

• The map of hygiene-sensitive areas is displayed, up to date and consistent with the HARA.
  
• The glass and brittle materials register has been checked at the planned frequency, with no open deviation.
  
• No snap-off blade knives, staples or drawing pins where product is exposed.
  
• Machine blades have been checked and replacements recorded.
  
• Every maintenance job today has a signed clearance inspection.
  
• The chemicals present are on the register, labelled and stored in a restricted area.
  
• The latest cleaning schedule is signed and verified; disinfection is done where P708 requires it.
  
• Clothing, jewellery, nails and plasters follow the written rules.
  
• Pest control devices are in place, numbered, with no untreated activity.
  
• Today’s pallets, loading bays and vehicles have been checked.
  

Three mistakes keep coming up in the mock audits we run: the same hygiene rules for every area, with no link to the product’s use; cleaning that is documented but never validated; and a HARA that ignores migration and recycled materials. The context of these requirements is set out in our guide to BRCGS Packaging Materials Issue 7, and their effect on the budget in our article on BRCGS Packaging certification cost.