BRC Requirements and detectable pens
The humble pen is a staple item in any industry. However, to ensure that rigorous food safety and product integrity requirements are upheld in the food and beverage industry, pens which are used in such environments must be food safe, and are perhaps not quite as humble as you may first think. Pens have a habit of getting lost or broken, and whilst this may not be a problem in an ordinary office, it is a problem in an area preparing food and beverages.
All of this means ordinary ball point or fountain pens are a no-go in the food industry. Instead, detectable pens must be used. BRC’s Global Standard for Food Safety Issue 8 was launched in August 2018 and provides more specific guidance relating to the use of detectable pens. This presents potential problems to the pens that some food factories have been using.
Risk Factors in the Food, Beverage and Pharma Industries
There are several key risks which pens bring to the food industry. It is all too easy for an operative to inadvertently put a pen down to complete another task and forget to pick it up again. In such situations, what happens to the pen? Does someone pick it up? Does it roll off the machine and onto the production line or onto the floor?
The ultimate question is what foreign body or contamination risk could pens create in my factory? Production line shut down, recalling of products, or in the worst-case scenario, consumers may even ingest one or more of these foreign bodies. Even with the use of metal and x-ray detectors, ‘small parts’ are unlikely to be detected – but what constitutes a small part?
Firstly, let’s look at the pen in its whole state. If you take it apart, are there any components which are likely to cause a problem? A common offender is a metal coil spring. Often a wrong assumption is made that they are detectable because they are metal. However, as a spring is simply a coiled piece of wire, the ‘signal’ omitted is not significantly different enough to the background signal of the product (especially wet products such as ready meals), and has a very negligible chance of being detected.
Secondly, what happens to the 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. This means it is more likely to shatter under pressure, with small ‘splinters’ being thrown far and wide. Such small fragments are almost impossible to detect over the background ‘signal’ emitted by the product. Therefore, when choosing a detectable pen, it is important to ensure they do not shatter. This prevents small pieces from entering the production line.
Do Metal Pens Solve these Problems?
One way to reduce the risks is to use metal pens. Metal is often seen as more detectable than plastic (although this is not always the case) and does not shatter. However, metal pens have their problems, too. They are cold, often not very easy to hold (particularly in damp and sub-zero environments), and therefore difficult to write with. Whilst this may sound a minor detail, this can greatly affect the productivity of your team. Metal pens are also notorious for being slippery and rolling, meaning that they do not alleviate the problem of controlling mobile equipment.
BRC 8 Requirements
In August 2018 the new BRC Global standard for food safety was issued. A key clause in the BRC 8 looks at ‘other physical contaminants’ – specifically pens and raw material packaging. Clause 126.96.36.199 is a new clause relating specifically to pens:
“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)”.
The clause is intended to make the food production process even safer for consumers, ensuring continuous improvements in standards across the board. As such, it is problematic for metal pens, which are often made with small parts such as springs, as well as for some plastic pens that are not detectable or shatter-resistant enough to prevent small fragments entering the production line should pens be shattered.
Retreeva Detectable Pens
This clause makes the use of detectable pens in the food industry much more complicated. This may mean that factories will have to change the types of pens they use, potentially disrupting their supply chains. However, this is not a problem for those using Retreeva Global pens who operate on the principle of ‘prevention before detection’. Because their metal detectable pens are designed to prevent rather than cure, they are already compliant with the new BRC clause.
There are several reasons for this
Retreeva pens are detectable by foreign body detection equipment (metal and x-ray) and are virtually unbreakable; they are not prone to cracking, snapping or shattering. Under unreasonable and un-natural force, they may bend or distort. However, they stay in large, easily visible pieces, all of which are detectable by metal and x-ray detection.
Whilst being retractable, Retreeva Global pens do not contain separate metal springs., In addition, the lanyard loops and pocket clips are integrated into the mould rather than being detachable components. This eliminates the issue of small parts that many detectable pens have. A further benefit of the Retreeva Global pocket clip and lanyard loop design is that it is impossible for the pens to roll away.
Preparing for BRC 8 Requirements
Whilst these new requirements took effect in August, January 2019 was the expected date for audit enforcement. Therefore preparation is important to ensure compliance. We suggest checking your current pens against clause 188.8.131.52 and thinking about how you can reduce the risks of foreign bodies, and improve the detectability of the pens that you use. Why not conduct a snap test on your current detectable pen? Can you account for every piece (or splinter/shard) to ensure they do not create a foreign body hazard?