BRC - Packaging - 5 - Voluntary Module - En-Awareness - v8 - High-Res

BRC GLOBAL STANDARD
PACKAGING AND PACKAGING

MATERIALS ISSUE 5
VOLUNTARY
MODULE 8
ENVIRONMENTAL
AWARENESS
LIABILITY
The BRC publishes information and expresses opinions in good faith, but accepts no liability for any error or omission in any such
information or opinion, including any information or opinion contained in this publication.
Whilst the BRC has endeavoured to ensure that the information in this publication is accurate, it shall not be liable for any damages
(including without limitation damages for pure economic loss or loss of business or loss of profits or depletion of goodwill or
otherwise in each case, whether direct, indirect or consequential) or any claims for consequential compensation whatsoever
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Nothing excludes or limits the liability of the BRC for death or personal injury caused by its negligence, for fraud or fraudulent
misrepresentation or for any matter which it would be illegal for it to exclude or attempt to exclude liability for.
The BRC Global Standard for Packaging and Packaging Materials: Voluntary Module 8 – Environmental Awareness and the
terms of the disclaimer set out above shall be construed in accordance with English law and shall be subject to the non-exclusive
jurisdiction of the English Courts.
COPYRIGHT
© British Retail Consortium 2015
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Tel: +44 (0) 20 7854 8900

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CONTENTS
PART I INTRODUCTION
How this publication is organised 3
Requirements and scope 3
Principles of the Module 4
About the audit and certification process 4
Benefits of the Module 5
How the requirements are set out in Part II 5
PART II REQUIREMENTS OF THE

ENVIRONMENTAL AWARENESS MODULE
1 Senior management commitment and continual improvement 6
1.1 Environmental management policy 6
1.2 Senior management commitment 6
1.3 Organisational structure, responsibilities and management authority 7
1.4 Management review 7
2 Environmental aspect and impact management system 8

2.1 Energy use 8
2.2 Raw material usage 8
2.3 Water use 9
2.4 Effluent and waste water 10
2.5 Emissions to air 10
2.6 Transport, storage and distribution 11
2.7 Waste management 11
2.8 Land use 12
2.9 Nuisance 13
3 Pollution and incident identification and management system 14

3.1 Pollution prevention team 14
3.2 Pollution and incident identification and management through hazard and risk analysis 14
3.3 Environmental incident management 16
4 Environmental management system 17

4.1 Environmental management manual 17
4.2 Internal audits 17
4.3 Documentation control 17
4.4 Specifications 18
4.5 Record-keeping 18
4.6 Complaint-handling 18
5 Personnel 19
5.1 Training and competence 19
5.2 Access and movement of personnel 19
5.3 Protective clothing 19
ENVIRONMENTAL AWARENESS 1
CONTENTS
PART III AUDIT PROTOCOL

Protocol for the optional Environmental Awareness Module 20
Getting started 20
Self-assessment of compliance with the Module 20
Selection of a certification body 21
Scope of audit 21
Module certification 21
Auditor selection 22
Audit planning 22
Preparation by the company 22
Duration of the audit 23
The on-site audit 23
Non-conformities and corrective action 24
Procedures for handling non-conformities and corrective action 25
Audit reporting 26
Audit pass or fail 26
Certification27
BRC logos 28
The BRC Global Standards Directory 28
Surveillance of certificated companies 28
Ongoing audit frequency and certification 29
Communication with certification bodies 29
Appeals30
APPENDICES
Appendix 1 About the BRC Global Standards 31
Appendix 2 Pollution prevention factors 32
Appendix 3 Registration, qualifications, training and experience requirements for auditors 34
Appendix 4 The waste hierarchy 36
Appendix 5 Glossary 37
Appendix 6 A thank you from the BRC 40
2 ENVIRONMENTAL AWARENESS
PART I
INTRODUCTION
This Module has been developed to provide a framework to enable companies to develop
an awareness of, and a mechanism for improvement in, their environmental awareness
and performance.
Companies may choose to implement and be audited against the requirements of this Module
where they have received requests from their customers, or where they wish to assess and improve
their environmental profile.
HOW THIS PUBLICATION IS ORGANISED

This publication sets out the requirements for the auditing and certification of packaging and
packaging materials manufacturers and converters to enable them to achieve certification to
Voluntary Module 8 – Environmental Awareness for the BRC Global Standard for Packaging and
Packaging Materials (hereafter referred to as the Standard).
The document consists of the following parts:
○○ Part I Introduction Provides an introduction and background to the development, scope

and benefits of the Standard.
○○ Part II Requirements Details the requirements of the Standard with which a company must
comply in order to gain certification.
○○ Part III Audit Protocol Provides information on the audit process and rules for the awarding
of certificates. It also describes marketing support for certificated companies, the logos and the
BRC Directory.
○○ Appendices The appendices provide other useful information including auditor competency
requirements and a glossary of terms.
REQUIREMENTS AND SCOPE

The requirements of the Module are applicable to any type of company that has premises
comprising at least one building and may also include outside areas. Although the requirements
include reference to some packaging materials manufacture and the terminology associated with
it, they can be applied to any type of site.
Companies that meet the requirements of a satisfactory environmental management system –

for example, one conforming to that specified in ISO 14001 – may already meet many of the
requirements of the Module. It is in the interest of the company to bring these points to the attention
of the certification body. The auditor will verify that the procedures are adequate for the purpose of
compliance with this Module.
The Module has a scope which is limited to the activities that take place on the site that is under the
management or control of the certificated company. The site may be wholly owned, rented or
contracted by the certificated company, and all aspects of the site’s activities shall comply with
these requirements.
The Module is intended to allow sites to develop environmental management systems (EMS)
within the same framework and model as for the BRC Global Standards. The requirements for this
Module follow the format of the requirements as set out in the Standard and can be covered in the
same audit for Standard certification or they can be audited separately.
The Module does not cover product safety or quality as these are covered by the parts of the
Standard that are relevant to the company’s activities; neither does the Module cover other
activities such as ethical or financial arrangements which may be covered by other certification
schemes. The Module does not cover finished product sustainability.
PRINCIPLES OF THE MODULE

The Module is intended to assist companies and their customers to develop awareness of the
impact of their processes, products and operations on the environment, and to manage those
impacts on an ongoing basis. In some regions, legislation exists that regulates how a company
must operate with regard to environmental factors in order to comply with the legislation. Where
legal requirements exist, the company shall have systems in place to maintain awareness of and
meet them in order to comply with the requirements of the Module.
The company must have a good understanding of the site covered in the scope, the activities that
occur there, and the inputs and outputs of the site; it must also have systems in place to identify
and control those hazards that are significant to the environment. The Module is based on three
key components: senior management commitment, hazard and risk analysis, and environmental
management systems.
SENIOR MANAGEMENT COMMITMENT

The effective and consistent achievement of environmental management requires it to be
recognised as a shared responsibility for all personnel within the business. Environmental
management systems extend beyond the responsibility of just one department and must involve
commitment from the full management team, including facilities, production, procurement,
logistics and sales.
The starting point for an effective environmental management system is the commitment of senior
management to the development of an all-encompassing policy as a means to guide the activities
that collectively assure effective environmental management. This Module places a high priority on
clear evidence of senior management commitment.
A HAZARD AND RISK ANALYSIS BASED SYSTEM

The Module requires the development of an environmental management system that is based on
the principles of hazard and risk analysis. It should cover all the inputs to and outputs from the site
and the operations that the company is responsible for. The development of such a system requires
the input of all relevant departments and must be supported by senior management.
ENVIRONMENTAL MANAGEMENT SYSTEMS (EMS)

The Module is intended to provide assurance to customers that the environmental aspects and
impacts incurred by the site through its normal operations are being managed effectively. The
company has to follow a risk-based process to ensure that appropriate measures are taken to
minimise, or eliminate where possible, the site’s impact on the environment and to manage those
aspects. This approach also ensures that the company is aware of any environmental incidents that
may occur and is able to put in place effective monitoring and corrective actions.
ABOUT THE AUDIT AND CERTIFICATION PROCESS

This optional Module is a non-accredited certification scheme whereby companies are certificated
upon completion of a satisfactory audit. The audit is performed by an auditor from an independent
third party – the certification body.
In order for a business to receive a valid certificate, the organisation must select a certification body
approved by the BRC. The BRC lays down detailed requirements that a certification body must
satisfy in order to gain approval. Approved certification bodies are listed on the BRC Directory at
www.brcdirectory.com
The full process for certification is detailed in Part III – Audit Protocol.
BENEFITS OF THE MODULE

There are a number of benefits to companies arising from the adoption of the Module alongside the
BRC Global Standard for Packaging and Packaging Materials. These are that the Module:
○○ provides a report and certification that can be accepted by customers in place of their own
audits, thus reducing time and cost
○○ provides a single standard and protocol that allow an audit by third-party certification bodies, thus
giving a credible independent assessment of a company’s environmental management systems
○○ allows certificated companies to state compliance with the Module on the BRC public directory,
thus providing recognition of their achievements and use of a logo for marketing purposes
○○ is comprehensive in scope, covering areas of site-based environmental management, legal
compliance and elimination of harm to the environment
○○ requires ongoing surveillance and confirmation of the follow-up of corrective actions on
non-conformity to the Module, thus ensuring the establishment of a self-improving
environmental management system.
HOW THE REQUIREMENTS ARE SET OUT IN PART II

Each clause of the Module begins with a highlighted paragraph that is the statement of intent (SOI).
Below this statement, in tabular format, are the specific requirements that, if applied appropriately,
will help to achieve the stated objective. The requirements and SOI shall form part of the audit and
must be complied with (where applicable) in order for a certificate to be issued.
NON-APPLICABLE CLAUSES
The majority of the requirements of the Module will apply to all types of business. There are,
however, some requirements that will not apply to some industry sectors or operations. Any such
requirements may be excluded and will be marked as not applicable (N/A) in the final audit report.
The auditor will assess and decide on the validity of any requirements that the company has
requested to be excluded. The final audit report will include comments on any clauses marked as
non-applicable.
The requirements of the Module are based on certificated companies being able to demonstrate to
their customers their commitment to good environmental practice, their adoption of a structured
approach to managing their environmental impacts, and the exertion of a controlling influence over
the environmental profile of the products manufactured by them.
PART II
REQUIREMENTS OF
THE ENVIRONMENTAL
AWARENESS MODULE
1 SENIOR MANAGEMENT COMMITMENT
AND CONTINUAL IMPROVEMENT
1.1 ENVIRONMENTAL MANAGEMENT POLICY
The company’s senior management shall develop and document an environmental management policy which is authorised,
reviewed, signed and dated by an appropriate senior manager.
The policy shall include from this Module: environmental aspect and impact management (clause 2) and pollution and incident
identification and management (clause 3).
CLAUSE REQUIREMENTS
1.1.1 The policy shall state the company’s intention to meet its legal requirements and responsibility to the
environment. This shall include a commitment to pollution prevention, waste reduction, its customers’
requirements and a process of continuous improvement.
1.1.2 The company’s senior management shall ensure that the policy is communicated to all staff.
1.1.3 The company shall maintain a register of relevant environmental laws and standards that are applicable to
their industry, country of manufacture, and use, where known.
The company’s senior management shall have a system in place to ensure that the company is kept
informed of all relevant environmental legislative requirements in the country of manufacture and, where
known, the country in which the packaging material will be sold.
1.2 SENIOR MANAGEMENT COMMITMENT

The company’s senior management shall demonstrate that they are fully committed to the implementation of the requirements of
the Environmental Awareness Module. This shall include the provision of adequate resources, an effective communication policy
and systems of management review to effect continual improvement.
Opportunities for improvement shall be identified, implemented and fully documented.
CLAUSE REQUIREMENTS
1.2.1 The company’s senior management shall determine environmental objectives in line with the company’s
environmental management policy.
The company’s environmental management objectives shall be specific, measurable, established,
time-bound, documented, monitored and reviewed. They shall originate from the significant
environmental impacts that were identified through the environmental hazard and risk management
process.
1.2.2 The company’s senior management shall provide the human and financial resources required to
implement the processes of the environmental management system.
1.2.3 Clear communication and reporting channels shall be in place to report on and monitor compliance with
the Module.
CLAUSE REQUIREMENTS
1.2.4 The company shall ensure that the materials manufactured comply with the relevant environmental legislation
(including any legislation concerning the use of recycled content) in the country of manufacture and in which
the products are intended to be sold and/or ultimately used, where known.
1.2.5 The company’s senior management shall ensure that any non-conformities against the Module identified
at the previous audit are effectively actioned.
1.2.6 The company shall have a current and original copy of the Module available on site.
1.2.7 Where the company is certificated to the Module, it shall ensure that recertification audits occur on or
before the audit due date indicated on the certificate.
1.2.8 All environmental documentation or permits required for legal operation of the site shall be maintained.
1.3 ORGANISATIONAL STRUCTURE, RESPONSIBILITIES

AND MANAGEMENT AUTHORITY
The company shall define the responsibilities, reporting relationships and job functions of those personnel who are involved in
the management of environmental issues.
CLAUSE REQUIREMENTS
1.3.1 Within the management team there shall be a designated adequately trained and competent manager and
deputy with the responsibility for coordinating compliance with the requirements of the Module.
1.3.2 Documented and clearly defined responsibilities shall exist and be communicated to all key staff who are
involved in environmental regulatory compliance and management systems.
1.3.3 There shall be appropriate documented arrangements in place to cover for the absence of key staff.
1.3.4 The company’s senior management shall ensure that a description of general duties or work instructions are
in place and communicated to all those members of staff involved in activities relating to environmental
regulatory compliance and management systems.
1.4 MANAGEMENT REVIEW

The company’s senior management shall ensure that a management review is undertaken to ensure that the environmental
management programme is fully implemented, effective and is achieving the objectives set.
CLAUSE REQUIREMENTS
1.4.1 The review process for the company’s environmental management system shall assess the company’s
performance against its own objectives and continual improvement targets, and shall include the evaluation of:
○○ progress made on targets and objectives set since the implementation or last review of the environmental
management system
○○ environmental incidents (defined in clause 3.3)
○○ customer requirements or changes in customer requirements
○○ changes in circumstances, such as legal or other statutory requirements
○○ additional opportunities for improvement identified since the last review.
The review process shall be undertaken at appropriate planned intervals, as a minimum annually, and
records and action plans documented.
1.4.2 The decisions and actions agreed within the review process shall be effectively communicated to
appropriate staff and actions implemented within agreed timescales.
2 ENVIRONMENTAL ASPECT AND IMPACT MANAGEMENT SYSTEM
2.1 ENERGY USE
All energy sources for production, processing and non-production activities and energy use shall be established and monitored.
CLAUSE REQUIREMENTS
2.1.1 The company shall maintain records of all energy used and identify the energy sources on its site. This may
include, but is not limited to:
○○ electricity
○○ gas or LPG
○○ fuel oil
○○ solar panels
○○ wind turbines
○○ any renewable energy source (e.g. energy produced as a by-product of processing).
2.1.2 Energy used in non-production activities (e.g. offices, staff facilities and warehousing) shall be included in
site totals and be subject to suitable energy-use reduction and switch-off targets.
2.1.3 An effective ‘switch-off’ policy shall be developed where possible for all production and processing
equipment and machinery on site and according to usage.
2.1.4 For equipment, operations or systems that have been identified as major users of energy, the company shall
undertake a documented assessment to identify any potential changes that could reduce energy use.
2.1.5 Where energy-use reduction has been established as feasible, targets for reduction shall be established
and reviewed on an (at least) annual basis.
2.1.6 The company shall identify all powered production or processing equipment and machinery that are major
users of energy and the energy source for each.
2.1.7 The company shall ensure that compressed air systems are maintained to minimise compressed air
leakage.
A condition-based or preventive maintenance programme for compressed air systems and an equipment
failure reporting procedure with a schedule for correction shall be in place.
2.1.8 A planned maintenance programme shall be developed and implemented for additional on-site equipment
to ensure that it is operating at optimal efficiency. This may include, but is not limited to:
○○ on-site boilers
○○ air-conditioning units
○○ emission abatement equipment
○○ refrigerant units.
2.2 RAW MATERIAL USAGE

The company shall maximise the yield of raw materials to ensure that impact on the environment through wastage or
excess material use is minimised.
CLAUSE REQUIREMENTS
2.2.1 The company shall identify and maintain records of all raw materials and intermediate goods that are used
on site:
○○ to make the final product
○○ in the production or processing of the final product or intermediate goods.
2.2.2 Of the raw materials and intermediate goods identified, the company shall determine:
○○ which are from renewable and which are from non-renewable sources
○○ ●the recycled content
○○ whether the raw material is a by-product or an in-process recyclate.
CLAUSE REQUIREMENTS
2.2.3 Where a raw material is comprised of recycled or reused materials, the company shall determine where the
material is sourced.
2.2.4 Through an assessment of possible process improvements, the potential to make a reduction in use of raw
materials shall be evaluated and considered for implementation:
○○ ●in the production and processing of the final product
○○ ●in the layout of the equipment and site.
2.2.5 If a reduction in the use of raw materials is feasible through process improvements, a schedule shall be
developed to implement process and plant changes.
2.2.6 Based on risk assessment, a procedure shall be in place to address potential hazards to the environment
from the raw materials during storage, manufacture and distribution activities, and to implement and
maintain a system that will eliminate or reduce the identified risk.
2.2.7 Cleaning chemicals and materials shall be selected and used to minimise impact on the environment.
2.2.8 Where the company does not sub-contract its pest control programme, all pesticides and any other toxic
pest control materials shall be purchased, used, stored and disposed of in a manner that complies with the
company’s environmental and waste management objectives.
2.3 WATER USE

The company shall monitor and effectively manage its water consumption to use available water sources responsibly,
and to reduce its impact on the environment.
CLAUSE REQUIREMENTS
2.3.1 The company shall maintain records of mains supplied and abstracted water used on the site. Sources of
water may include:
○○ municipal sources (e.g. supplied by a water utility company)
○○ surface or ground water
○○ rainwater collected on the site
○○ recycled ‘grey water’.
Water consumption shall be monitored and compared between appropriately determined periods to
identify volume and patterns of usage.
2.3.2 If water is sourced locally from surface water or ground water, an evaluation shall be made to determine whether
the water body is deemed to be particularly sensitive or vulnerable to such extractions.
2.3.3 A register shall be developed to list any and all equipment that utilises water and the effect that the use has
on the microbiological and chemical quality of the water. The company shall determine any mitigating
activities that could be performed before the water is discharged to minimise any impact on the environment
with regard to the requirements in clause 2.4.
2.3.4 Internal audits shall include an assessment of the water systems to determine whether wastage is occurring,
and a condition-based maintenance programme and/or equipment failure reporting procedure with a
schedule for correction shall be in place.
2.3.5 The company shall identify opportunities for water-use reduction, regardless of source, and appropriate
targets for reduction shall be established and reviewed on an (at least) annual basis.
Water used in non-production activities such as toilets or in non-production equipment and facilities
cleaning shall be subject to appropriate water-use reduction targets.
2.4 EFFLUENT AND WASTE WATER
Effluent and waste-water discharges shall be managed to remove or minimise the risk of harm to the environment or of
accidents or incidents, and to reduce environmental impact.
CLAUSE REQUIREMENTS
2.4.1 The company shall determine and monitor the quantity of effluent and waste water produced on site and its
intended disposition.
This shall include reuse and planned and unplanned discharges associated with production operations.
Domestic sewage shall be included only where no local regulatory or municipal controls exist.
2.4.2 The composition and temperature of the effluent discharge shall be determined and the content of grease,
oils, solvents and any other foreign constituents shall be established and monitored at an appropriate
frequency.
Opportunities to remove process-related contamination and to control water temperature shall be identified
and implemented.
2.4.3 Where the company has on-site water treatment plants, the company shall document what quantity of water
is subject to treatment in this plant, and the purpose of this treatment.
Appropriate controls over the treatment plant and a monitoring programme shall be in place.
On-site treatment plants shall be subject to equipment implementation procedures and be included in the
site’s maintenance and calibration programme.
2.4.4 Effluent discharge points shall be detailed on the site plan with the intended destination of the effluent. This
may include discharge to surface water or municipal drains or sewers.
2.4.5 The company shall determine whether waste-water discharge can be reduced or eliminated (e.g. by reuse).
Where waste-water discharge can be reduced, reused or removed, the company shall set achievable
reduction objectives and review them on a regular basis.
2.5 EMISSIONS TO AIR

Direct emissions (i.e. emissions from sources within the scope of Module certification, such as those from production buildings
and transport) and their sources shall be managed to minimise or remove the risk of harm to the environment.
CLAUSE REQUIREMENTS
2.5.1 The company shall determine the quantity and types of emission produced as a result of processing and
production activity on the site, including transport.
This shall also include any greenhouse gases (GHGs) and ozone-depleting substances (ODSs) that may or
may not be subject to local, national or international legislation or internationally agreed protocols, such as
the Kyoto Protocol.
2.5.2 The assessment shall include the sources of each type of emission, including equipment, operations and
site transport.
CLAUSE REQUIREMENTS
2.5.3 Where any abatement activities occur, these shall be listed and the total emissions affected established
and monitored.
2.5.4 Through an assessment of possible process improvements, the potential to make a reduction in the
production of emissions, including those subject to abatement activity, shall be evaluated and considered
for implementation.
2.5.5 Achievable emissions reduction objectives shall be set and reviewed on a regular basis.
2.5.6 Emission abatement equipment shall be used in accordance with the manufacturer’s instructions and
included in the site’s maintenance and calibration programme.
2.6 TRANSPORT, STORAGE AND DISTRIBUTION

Activity for the movement and storage of raw materials, intermediate goods and finished products shall minimise impact on
the environment.
CLAUSE REQUIREMENTS
2.6.1 Where the company dispatches intermediate or finished product by road, combining loads or groupage
shall be considered where it poses no hazard to the finished product.
2.6.2 Optimal efficiency of company-owned vehicles shall be ensured through a maintenance programme.
Topics to be considered include:
○○ tyre inflation
○○ fuel consumption
○○ journey optimisation
○○ disposal of vehicle oil (if on site).
Driver training and typical mileage of vehicles shall be considered where applicable (e.g. eco-driving
training).
2.6.3 The company shall evaluate its site transport needs to establish the optimal transport type for movement
of raw materials, intermediate products and finished goods.
2.6.4 The company shall consider the potential to reduce dispatches or increase lorry loading (load efficiency) for
all transport of raw materials, intermediate products and finished goods by company-owned and third-party
contracted transport services.
2.7 WASTE MANAGEMENT

All waste produced by production and processing activity on site shall be subject to appropriate controls and monitoring.
CLAUSE REQUIREMENTS
2.7.1 The company shall determine and maintain records of:

○○ production waste volumes
○○ composition of the waste
○○ intended disposition of the waste
○○ local legal requirements that apply to the waste materials.
2.7.2 Consideration shall be given to the waste hierarchy when disposing of production and non- production waste.
The waste hierarchy is shown in Appendix 4.
2.7.3 The company shall minimise, with the intention to reduce to the point of elimination, production and
non-production waste sent to landfill, and an objective (clause 1.2.1) shall be set.
2.7.4 Achievable waste reduction objectives shall be established and reviewed on a regular basis.
CLAUSE REQUIREMENTS
2.7.5 All waste produced at the site (production and non-production) shall be subject to a duty of care (e.g.
containment on site, reduction, elimination, appropriate disposal with consideration for local legislation
where relevant).
2.7.6 Where hazardous waste is produced, any specific legal or regulatory requirements associated with that type
of waste shall be complied with.
2.7.7 Where possible, in-process recycling (such as regrind) shall be established and maintained to minimise
wastage of raw materials or intermediate products.
Where in-process recycling is not possible, the use of waste in other or alternative products, both in-house
or with external sites, shall be evaluated and implemented if appropriate.
2.7.8 Spill waste shall be dealt with according to local legislative requirements, with special reference to
hazardous waste (and shall include excess pest control materials).
2.7.9 The company shall ensure that waste or surplus pest control materials are managed effectively to minimise
or eliminate hazards to the environment.
2.7.10 Where possible, any and all pests killed by ingestion of toxic materials, traps or any other pest control
method shall be disposed of to minimise the risk of contamination to the environment.
2.7.11 Chemicals including cleaning materials, lubricants and adhesives shall be purchased, used, stored and
disposed of in a manner that complies with the company’s environmental and waste management objectives.
2.8 LAND USE

The use of land and the potential impact on the local environment shall be with consideration to the company’s environmental
policy and objectives.
CLAUSE REQUIREMENTS
2.8.1 Where new buildings are being commissioned, the company shall ensure that the build process does not
cause negative impact on the local environment, and the buildings shall comply with the company’s
environmental policy, objectives and local legal requirements.
Where relevant, consideration shall be made for use of sustainable building schemes that incorporate the
use of sustainable design and renewable energy, such as BREEAM (Building Research Establishment
Environmental Assessment Method).
2.8.2 The purchase, installation and commissioning of equipment, and the movement or decommissioning of
old equipment or facilities, shall be conducted with consideration of the company’s environmental policy.
2.9 NUISANCE
The site shall take steps to minimise risk of nuisance.
CLAUSE REQUIREMENTS
2.9.1 A documented assessment of the site’s interaction with its local environment and the potential negative
impacts shall be conducted. This may include, but is not limited to:
○○ noise sources
○○ site activity and hours of operation
○○ staff arrival times
○○ odour
○○ emissions to air, water and land
○○ storage of raw materials, intermediate products and waste materials.
2.9.2 The company shall take steps to eliminate or mitigate the nuisance where significant impact on the local
environment has been identified.
2.9.3 Where external storage of raw materials, intermediate products or finished goods is necessary, the areas
shall be suitably designated and maintained to ensure that the products do not pose a hazard or nuisance to
the local environment. This may include detritus removed by winds or rain, or harbourage of pests.
2.9.4 The company shall ensure that ventilation does not cause environmental impacts on the surrounding area,
such as nuisance from odour, dust or noise.
3 POLLUTION AND INCIDENT IDENTIFICATION AND
MANAGEMENT SYSTEM
3.1 POLLUTION PREVENTION TEAM
A multidisciplinary environmental risk management team shall be in place to develop and manage the pollution and incident
identification and management system and to ensure that it is fully implemented.
CLAUSE REQUIREMENTS
3.1.1 The pollution and incident identification and management system shall be developed, reviewed and
managed by a multidisciplinary team that includes those responsible for facilities management, production,
technical, engineering/maintenance and other relevant functions.
In the event that the company does not have the appropriate expertise in hazard and risk analysis in house,
external expertise shall be sought and used to develop and review the system. However, the day-to-day
management of the system shall remain the responsibility of the company.
3.1.2 The multidisciplinary team shall have a designated team leader who shall be able to demonstrate
competence and experience of hazard and risk analysis and an appropriate understanding of environmental
management.
3.1.3 The team shall be suitably trained in hazard and risk analysis principles and kept up to date with factory and
site changes as they occur.
3.2 POLLUTION AND INCIDENT IDENTIFICATION AND MANAGEMENT THROUGH

HAZARD AND RISK ANALYSIS
A formal environmental hazard and risk analysis system shall be in place to ensure that all potential hazards to the environment
from site activity and operations are identified and that appropriate controls are established.
CLAUSE REQUIREMENTS
3.2.1 The scope of the environmental hazard and risk analysis system shall be clearly defined and cover all activity,
operations and processes that occur on site.
3.2.2 The environmental hazard and risk analysis team shall maintain awareness of and take into account:
○○ historical and known hazards associated with the site
○○ specific processes, raw materials or operations or activities that occur on the site
○○ relevant codes of practice or recognised guidelines
○○ legislative requirements.
3.2.3 A full description of the site shall be developed, which includes all relevant information on the buildings and
activities that occur on site. As a guide this may include:
○○ total size of the site, including external grounds
○○ nature and situation of the site (whether it is in a rural, urban or industrial setting)
○○ number and types of building on site, including any unused outbuildings
○○ all activities that take place in each building
○○ sensitive environmental areas (land, air and water) unique to the site that may be affected by accidental
discharges.
CLAUSE REQUIREMENTS
3.2.4 A site plan listing manufacturing operations, activities, and inputs and outputs to each building or site area
shall be prepared. This shall include:
○○ energy and energy types
○○ water
○○ fuel and fuel types
○○ raw materials.
The accuracy of the plan shall be verified by the hazard and risk analysis team.
3.2.5 The environmental hazard and risk analysis team shall identify and record all potential hazards or incidents
that are reasonably expected to occur on site, including manufacturing, processing and storage areas, and
external areas such as lorry parks. The hazards considered shall include, where relevant:
○○ leakage from damage or wear and tear of systems
○○ accidental release of fluids such as oil, diesel or effluent to the site
○○ compliance with legal requirements.
3.2.6 Where appropriate and permitted by local, national or international legislation, the company shall:
○○ establish monitoring procedures for the identification of hazard occurrence
○○ introduce control measures to minimise the risk of occurrence
○○ set limits for those potential hazards.
3.2.7 Liquid spillages of any type shall not enter surface water drainage. A spill response procedure shall be
available that includes appropriate training, and shall be reflected in the incident management procedures
and log.
3.2.8 Where glass breakage occurs, the responsible person shall ensure that the waste caused by the breakage
of glass or brittle plastic, including materials used in the clean-up operation or any product that has been
contaminated, are disposed of in a method that complies with the company’s environmental and waste
management objectives.
3.2.9 A review of the environmental hazard and risk analysis system shall be carried out at least once a year and/or
following any significant incidents or changes made to the site, activities and processes, or buildings.
The review shall include a verification that the environmental hazard and risk analysis system is effective and
may include consideration of:
○○ complaints (e.g. from neighbours)
○○ incidents (e.g. spillages or accidental discharges to air, land or water)
○○ results of internal audits of environmental programmes
○○ results from external third-party auditors
○○ any third-party actions or investigations and activities or public identifications of issues
○○ results of visits from any regulatory authorities
○○ any environmental initiatives that have been implemented by the site.
3.3 ENVIRONMENTAL INCIDENT MANAGEMENT
The site shall have a plan and systems in place to manage environmental incidents effectively.
CLAUSE REQUIREMENTS
3.3.1 The occurrence of a hazard beyond the limits set in clause 3.2.6 shall constitute an environmental incident.
The occurrence of environmental incidents shall be recorded.
3.3.2 An environmental incident management procedure shall be documented, be practical to implement and
be regularly reviewed. This shall include as a minimum:
○○ identification of the key personnel involved in assessing environmental incidents with clearly
identified responsibilities
○○ a communications plan including methods of informing customers and, where necessary, regulatory
bodies, in a timely manner
○○ corrective action and business recovery
○○ a review of any incidents to implement appropriate improvements as required.
3.3.3 The corrective action that should be taken when the company has identified the occurrence of an
environmental incident shall be established and documented.
This shall include the procedures for managing impacts on the environment where hazards have occurred
and the containment, mitigation and procedures required to minimise the effect or potential effect on the
environment. The documentation shall include the potential impacts on the physical environment in
proximity to the site but not in the company’s control.
3.3.4 The environmental incident management procedure shall be operable at any time.
3.3.5 The environmental hazard and risk management team shall be responsible for ensuring that preventive
action is taken (based on a review of incidents) and that improvements are implemented as necessary.
4 ENVIRONMENTAL MANAGEMENT SYSTEM
4.1 ENVIRONMENTAL MANAGEMENT MANUAL
The company shall have a manual which describes how the requirements of the Module are met.
CLAUSE REQUIREMENTS
4.1.1 These requirements shall be fully implemented, reviewed at appropriate planned intervals and improved
where necessary.
4.1.2 The environmental awareness manual shall contain an outline of working methods and practices or
references to where such an outline is documented.
4.1.3 The manual or relevant components shall be readily available to key staff.
4.2 INTERNAL AUDITS

The company shall audit those systems and procedures which cover the requirements of the Module to ensure that they are in
place, appropriate and complied with.
CLAUSE REQUIREMENTS
4.2.1 Internal audits shall be planned and their scope and frequency shall be established. Audits shall be
scheduled so that all aspects of the Module are audited at least annually.
4.2.2 Internal audits shall be carried out by appropriately trained and competent auditors, who are independent of
the audited activity.
4.2.3 Deficiencies and details of non-conformities shall be notified to the relevant supervisory staff and corrective
action implemented within a specified and appropriate time period.
4.2.4 The company shall identify whether deficiencies and non-conformities have any legal ramifications, and
whether hazards to the environment caused are within the scope of the Module. Where the environment is
or may be compromised, corrective and remedial actions shall be taken to mitigate the impacts on the
environment.
These actions shall be reflected in the environmental aspect and impact management system (requirement
2), and the pollution and incident identification and management system (requirement 3).
4.3 DOCUMENTATION CONTROL

The company’s senior management team shall ensure that documented procedures and recording forms related to the
environmental policy and objectives of the company and the nature of its products are in place and effectively controlled.
CLAUSE REQUIREMENTS
4.3.1 All documents in use shall be properly authorised and be the current version.
4.3.2 Documents shall be clearly legible, unambiguous and sufficiently detailed to enable their correct application
by appropriate personnel. They shall be readily accessible to relevant staff at all times.
4.3.3 All changes and amendments to documents regarding environmental management system procedures
shall be authorised and recorded, and obsolete documentation shall be removed, archived and replaced
with the current version.
4.4 SPECIFICATIONS
The company shall ensure that specifications for the raw materials brought on site contain the source, supplier, constituent
parts and any relevant chain-of-custody information regarding the raw material.
CLAUSE REQUIREMENTS
4.4.1 The company shall ensure that specifications for intermediate and finished products sold to a customer
contain any relevant chain-of-custody information of the raw material.
4.4.2 Specifications shall be suitably detailed, accurate and shall ensure compliance with relevant environmental
legislation in the country of manufacture.
4.4.3 The company shall operate a specification review procedure to ensure that data concerning source,
supplier, constituent parts and any relevant chain-of-custody information for raw materials, and intermediate
and finished products, is accurate and up to date.
4.5 RECORD-KEEPING
The company shall maintain records to demonstrate the effective control of its site with regard to the Environmental
Awareness Module.
CLAUSE REQUIREMENTS
4.5.1 The records shall be legible, genuine, appropriately authorised and retained in good condition for a defined
time period with consideration given to any legal or customer requirements and to the shelf life of the
product or usage of the packaging materials.
Any alterations to records shall be authorised and justification for the alteration shall be recorded.
4.5.2 Where records are in electronic form, these shall be suitably backed up to prevent loss.
4.5.3 The company’s senior management team shall ensure that procedures are operated for the organisation,
review, maintenance, storage and retrieval of all records relating to the Module.
4.6 COMPLAINT-HANDLING
The company shall have a system for the effective capture, recording and management of complaints regarding the
environmental performance of the site.
CLAUSE REQUIREMENTS
4.6.1 All complaints shall be recorded, investigated and the results of the investigation documented.
4.6.2 Actions appropriate to the seriousness and frequency of the problems identified shall be carried out
promptly and effectively by suitably trained staff.
5 PERSONNEL
5.1 TRAINING AND COMPETENCE
All personnel, including temporary personnel, shall be appropriately trained on the company’s environmental objectives prior
to commencing work.
CLAUSE REQUIREMENTS
5.1.1 Personnel shall be trained on the requirements of the Module and the company’s environmental policy.
5.1.2 Records of training on the requirements of the Module shall be kept for all current and recent key employees.
The company shall routinely review the competencies and environmental awareness of staff and provide
refresher training as appropriate.
5.2 ACCESS AND MOVEMENT OF PERSONNEL

The company shall ensure that access and movement of personnel, visitors and contractors shall be in line with the
company’s environmental objectives.
CLAUSE REQUIREMENTS
5.2.1 The company shall document site traffic routes and identify routes that minimise impact on the environment.
This shall include, but is not limited to:
○○ how employees arrive on site
○○ how raw materials and intermediate goods arrive or are dispatched
○○ routes for transport of raw materials and intermediate and finished products around the site (e.g. by hand
or motorised trucks).
Where possible, the company’s objectives with regard to environmental awareness shall include
minimisation of impact on the environment from the above.
5.3 PROTECTIVE CLOTHING

The use and disposal of protective clothing shall not compromise the environmental objectives of the company.
CLAUSE REQUIREMENTS
5.3.1 Where disposable protective clothing is used, the company shall ensure that its disposal is in line with its
environmental objectives and with the waste hierarchy (see Appendix 4).
5.3.2 Where protective clothing is laundered either by a professional laundry service, in-house, or in controlled
laundering facilities, the company shall ensure that the equipment, materials and detergents used are
compliant with its environmental objectives.
Where protective clothing is laundered by self-care, guidance shall be offered to personnel for the
minimisation of impact on the environment.
PART III
AUDIT PROTOCOL
PROTOCOL FOR THE OPTIONAL ENVIRONMENTAL

AWARENESS MODULE
The Environmental Awareness Module is an entirely optional module intended to help those
companies that have no formal environmental management policy or systems and may already be
certificated to a BRC Global Standard.
Manufacturers may be receiving interest in their environmental credentials from their customers,
or wish to initiate an environmental management system in order to ascertain their environmental
impact and take steps to minimise actual or potential adverse impacts, or minimise adverse
impacts of future activities.
Part III describes the specific requirements of auditing and certification to the Environmental
Awareness Module and will be used by the certification bodies during the certification process.
Information on certification to the Standard can be found in Part III of the BRC Global Standard for
Packaging and Packaging Materials, Issue 5. The Standard also provides guidance on the audit
and certification process for companies seeking certification to help them prepare and organise
for the audit.
Every effort has been made to ensure that the content of this protocol is accurate at the time of
publication. However, it may be subject to minor change, and reference should be made to the BRC
Global Standards website (www.brcglobalstandards.com) where changes will be published.
GETTING STARTED
Obtaining BRC certification can be a challenging step for companies, and extending the scope to
include this environmental Module demonstrates their commitment to continual improvement. It is
vital that the company is well prepared for the audit, otherwise substantial unnecessary cost may
be incurred and disappointment will be likely. Some considerations that should be addressed by
companies interested in extending certification are outlined below.
Many of the certification bodies offer optional pre-assessment visits. Certification bodies are not
allowed to act as consultants since this could potentially result in them auditing their own work, but
such a visit can help and allows companies to obtain a clear understanding of where they need to
improve their processes and procedures. A pre-assessment visit is not a part of the certification
process and is not taken into consideration during the certification audit.
If a company is working with a specific customer, it would be advisable to discuss an

implementation programme with the site’s technical team to ensure that the steps being taken are
appropriate with regard to the customer’s requirements and timescales.
SELF-ASSESSMENT OF COMPLIANCE WITH THE MODULE

It is a requirement of BRC certification that the company has an original copy of the current issue of
the Module, available on BRC Participate (www.brcparticipate.com) or from the BRC Bookshop
(www.brcbookshop.com). The Module or self-assessment checklists should be obtained as the
first stage of preparation for certification.
The Module should be read and understood and a preliminary self-assessment should be conducted
by the company against its requirements. Any areas of non-conformity should be addressed by the
company. Further information and guidance to ensure compliance with the Module, including audit
tools and training, are available on the website: www.brcglobalstandards.com
Companies that meet the requirements of a satisfactory environmental management system (for
example, ISO 14001 or the Eco-management and Audit Scheme (EMAS)) may already meet many
of the requirements of the Standard. It is in the interest of the company to bring these points to the
attention of the certification body. The auditor shall, however, verify that all the procedures are
adequate for the purpose of compliance with the Module.
SELECTION OF A CERTIFICATION BODY

Once a self-assessment has been completed and any non-conformity addressed, the company
must select a certification body. The BRC cannot advise on the selection of a specific certification
body, but the BRC Global Standards Directory lists BRC-approved certification bodies.
Visit www.brcdirectory.com
In selecting a certification body, the company should consider the following:
○○ Confirmation that the auditor proposed by the certification body meets the qualification
and training requirements specified by the BRC as documented in Appendix 3.
○○ The scope of accreditation of the certification body. It is essential that the certification
body is accredited to assess companies for the range of products produced.
Company/certification body contractual arrangements

A contract shall exist between the company and the certification body, detailing the scope of the
audit and reporting requirements. This contract will be formulated by the certification body.
Registration fee
A registration fee is collected on behalf of the BRC by the certification body from the site for every
audit undertaken. This fee is to support further development of the scheme and to fund the
maintenance of the BRC Directory.
The certification body shall not issue a certificate or report to the client until the registration fee has
been received, irrespective of the outcome of the certification process.
It is a requirement of the BRC scheme that a copy of every audit report shall be uploaded by the
certification body to the BRC Directory website, irrespective of the audit result. This enables the
BRC to oversee the scheme, monitor the performance of certification bodies, and ensure the
consistency of application of the scheme around the world.
SCOPE OF AUDIT
The scope of the Environmental Awareness Module audit shall reflect the physical environment,
processes and activities that are under the management control of the site seeking certification.
The audit, report and certificate shall be site-specific and a certificate will not normally be issued
which covers more than one site owned by a company. Where several independent sites seek
certification, they shall each be audited separately and the certificate granted accordingly.
All regular processes closely associated with the company’s activities or production processes
would be expected to be included in the audit.
MODULE CERTIFICATION
Where a site is already certificated to a BRC Global Standard, the site will require an audit of only
the requirements associated with the Environmental Awareness Module.
The company should make the certification body aware that it wishes to be audited against the
Module. The Environmental Awareness Module audit may take place at any time during the
certification cycle, or the Module can be audited at the same time as an initial or recertification
audit of the Standard.
Where a Module recertification audit is combined with a Standard recertification audit, the current
Module certificate will be superseded by a new combined certificate issued using the same expiry
date as the Standard certificate. The original Module certificate will therefore have a shorter
duration. However, at subsequent audits, the Standard and the Module shall be a combined audit
with future recertification for both based on the initial audit date of the Standard audit.
AUDITOR SELECTION
It is the responsibility of the company to ensure adequate and accurate information, detailing the
products it manufactures and the process technologies it uses, is given to the certification body to
enable it to select an auditor with the required skills to conduct the audit, including the
Environmental Awareness Module.
The certification body, auditors and the company must be aware of the need to avoid a conflict of
interest when appointing an auditor for the site visit. The company may decline the services of a
particular auditor offered if it believes that there is a potential for conflict of interest. However, the
certification body should ensure that the same auditor does not conduct audits on more than five
consecutive occasions at the same site.
AUDIT PLANNING
PREPARATION BY THE COMPANY
For the initial audit, the company shall agree a mutually convenient date with the auditor, with due
consideration given to the amount of work needed to meet the requirements of the Module. For
subsequent Environmental Awareness Module audits, the audit shall be combined with the site’s
recertification audit for the Standard. This may mean that the validity of the initial Module certificate
is less than one year (see Table 1).
Table 1 Examples of audit dates for certification of the Standard and Module
ACTIVITY DATE
Initial audit for certification of the Standard 09 February 2015
Initial audit for certification of the Module 12 May 2015
Subsequent audit for certification of the Standard and Module 09 February 2016
There is a requirement on the company to plan carefully for the audit, to have appropriate
documentation for the auditor to assess, and to have appropriate staff available at all times during
the on-site audit.
The company shall ensure that the areas to be audited for the Module are accessible at the time of
the audit. This includes production and storage areas, offices and staff facilities, and warehousing
and distribution locations.
The company shall provide the certification body with any information such as risk analysis
documentation, details of recent environmental issues or customer complaints, and other relevant
performance data when requested, to assist the auditor in conducting an effective audit.
Companies are free to change certification bodies at any time, but it is a requirement that the
company shall make the previous BRC Module audit report available to the new auditor and
certification body.
DURATION OF THE AUDIT
The company shall provide the certification body with sufficient and appropriate information to
allow them to assess the duration and the cost of the audit. This should include the size of the site,
the production environment type and any known local environmental impact factors. Requested
information may also include a site plan, the number of employees, and the number of product
lines. The time required to assess all documentation is supplementary to the duration of the audit.
Before the audit takes place, the certification body shall indicate the approximate duration of the
audit. The typical duration of a Packaging Standard audit is one-and-a-half days, where one day
is eight hours.
Where a Module audit takes place at the same time as a Standard audit, the duration is expected
to be extended by no more than one day, with further time allocated for the completion of a
comprehensive audit report.
Where a Module audit takes place independently, the additional requirements to be audited from
the Module are anticipated to be one-and-a-half days, with further time allocated for the
completion of a comprehensive audit report.
However, certain factors can necessitate an increase or decrease in the duration of the audit. These
factors will require careful consideration both on confirmation of the expected duration of the audit
and during the audit itself. Deviation from this timeframe must be specified on the audit report.
The audit may not be completed in the time allocated if the company has not agreed the scope with
the certification body before the audit. Factors that may influence the duration of the audit are:
○○ company staff numbers and functions

○○ site layout – numbers of buildings, separate offices, manufacturing or storage sites
○○ size and age of site and impact on material flow
○○ audit not carried out in first language of the auditor or the company
○○ the number of non-conformities recorded in the previous audit
○○ difficulties experienced during the audit requiring further investigation
○○ quality of company preparation (e.g. documentation, aspect and impact management, pollution
and incident hazard and risk analysis).
To ensure consistency, a calculator has been developed to assess the expected time required to
undertake the audit of any particular site at a Standard certification audit and this shall be used as
the basis for calculating the total audit duration. Full details can be found on the BRC Global
Standards website (www.brcglobalstandards.com).
THE ON-SITE AUDIT

The on-site audit consists of the following six stages:
○○ the opening meeting – to confirm the scope and process of the audit
○○ document review – a review of documentation
○○ site inspection – to review the practical implementation of the environmental management
systems and interview of personnel
○○ review of site inspection – to verify and conduct further documentation checks
○○ final review of findings by the auditor – preparation for the closing meeting
○○ closing meeting – to review the findings of the auditor with the company. Note that non-
conformities and the consequent grade are subject to subsequent independent verification by
the certification body management.
There is no requirement for the auditor to carry out the audit in the order listed above but the audit
must include all these elements.
The company will fully assist the auditor at all times. It is expected that at the opening and closing
meetings, those attending on behalf of the company will be senior managers who have the
appropriate authority to ensure that corrective action can be progressed if non-conformities are
found. The most senior operations manager on site, or their nominated deputy, shall be available at
the audit and attend the opening and closing meetings.
During the audit, detailed notes shall be made regarding the company’s conformance against the
Module and these will be used as the basis for the audit report. The auditor will assess the nature
and severity of any non- conformity.
At the closing meeting, the auditor shall present their findings and discuss all non-conformities that
have been identified during the audit, but shall not make comment on the likely outcome of the
certification process. Information on the process and timescales for the company to provide
evidence to the auditor of the corrective action to close non-conformities must be given. A
summary of any non-conformities discussed at the closing meeting will be documented by the
auditor either at the closing meeting or within one working day of completion of the audit.
The decision to award certification for the Module will be determined independently by the
certification body management and in isolation from the certification decision for the Standard,
following a technical review of the audit report and the closing of non-conformities. The company
will be informed of the certification decision following this review.
Where a site is undertaking a Module audit at a different time from the Standard audit, the outcome of the
Module audit shall not affect the certification of the site audited to the requirements of the Standard.
All information viewed during the audit is regarded as confidential between the auditor and the site,
except as detailed in the audit report. No brand names or similar identifiers of product will be
released in the audit report or certificates, although it will be necessary to describe, in general
terms, the types of material and technology used.
NON-CONFORMITIES AND CORRECTIVE ACTION

The level of non-conformity assigned by an auditor against a requirement of the Module is an
objective judgement with respect to severity and risk, and is based upon evidence collected and
observations made during the audit. This is verified by the certification body management.
Non-conformities
There are three levels of non-conformity:
○○ Critical Where there is a critical failure to comply with an environmental awareness or

legality issue.
○○ Major Where there is a substantial failure to meet the requirements of a statement of intent
or any clause of the Module and/or a situation is identified that would, on the basis of available
objective evidence, raise significant doubt as to the site’s environmental compliance.
○○ Minor Where absolute compliance to the statement of intent has not been met, but on the basis
of objective evidence the site’s environmental compliance is not in doubt and/or a clause has
not been fully met but on the basis of objective evidence, the site’s environmental compliance
is not in doubt.
The objective of the audit is to provide a true reflection of the level of environmental awareness,
how the environmental aspects and impacts of the operation are managed, and the level of
conformity with the Module. Consideration should therefore be given to awarding a single major
non-conformity where minor non-conformities are repeatedly raised against a particular clause of
the Module in the current or previous audits. Clustering of a significant number of minor non-
conformities against a clause and recording this as a single minor non-conformity is not permitted.
Any non-conformity from the previous audit should be checked during the current audit to confirm
that corrective action has been taken and is operating effectively. Where repetition of these same
non- conformities occurs in the current audit, consideration should be given to raising the status of
minor non- conformities to a major.
PROCEDURES FOR HANDLING NON-CONFORMITIES AND CORRECTIVE ACTION
Following identification of any non-conformity during the audit, the company must develop a
corrective action plan. Evidence that corrective action has been completed must be provided by
the company to the certification body prior to a certification decision being made. All identified
non-conformities must be corrected to the satisfaction of the certification body before a certificate
can be issued.
Critical non-conformities
Where a critical non-conformity has been established, the company shall not gain certification.
Existing certificated sites shall have their certification suspended. A further full audit shall be carried
out to verify that appropriate corrective action has taken place and that there is demonstrable
evidence of compliance. In the event that a critical non-conformity has been established by the
certification body, the company shall immediately inform its relevant customers and make them
fully aware of the circumstances. Information on the corrective actions to be taken in order to
achieve certification status will also be provided to customers.
Major non-conformities
No certificate shall be issued until major non-conformities have been corrected. It is normally
expected that major non-conformities will be corrected within 28 calendar days of the audit taking
place, either permanently or temporarily (providing the solution is acceptable to the certification
body), and the certification body can verify that the corrective action has taken place.
Verification can be achieved either by submitting objective evidence to the certification body (such
as updated procedures, records, photographs or invoices for work undertaken etc.) or by the
certification body undertaking a further on-site visit.
For initial audits only, if there is no temporary solution or if there is a justifiable delay to implementing
a permanent solution (e.g. lead time on capital expenditure), then provided that an acceptable
statement of explanation is received by the certification body within 28 calendar days, the company
may remain in the certification programme for up to 90 calendar days. It will, however, remain
uncertificated and will only be certificated following verification of the corrective action. If the major
non-conformity cannot be closed out within the 90-calendar-day period, the process of
certification will commence again (i.e. a full audit).
If no formal commitment to implement the corrective action is received by the certification body
within the 28-calendar-day post-audit period, the company will not be certificated and will require a
further full audit in order to be considered for certification.
Non-conformities identified in relation to the requirements of the optional Module shall not affect
certification to the Standard. However, if non-conformities are identified against the requirements
of the Standard during an Environmental Awareness Module audit, then these shall be notified to
the company but shall have no bearing on the result of the Environmental Awareness Module
audit result.
Minor non-conformities
Certification will only be awarded where minor non-conformities have been addressed, the
corrective action taken, and evidence (e.g. photos, invoices) for work completed has been
provided to the certification body within 28 calendar days of the audit. The certification body may
undertake further visits to verify that action has been taken.
At the subsequent audit, if verification cannot be confirmed, then a non-conformity may be raised
and may be elevated to the status of a major non-conformity.
Documentary evidence
Suitable documentary evidence (e.g. updated procedures, records, photographs, invoices for
work completed) shall be provided to the certification body within the timescales for certification –
i.e. 28 days for certificated sites, and 90 calendar days for major non-conformities at initial audits.
The evidence provided shall clearly demonstrate that adequate corrective actions have been taken
and implemented. If this cannot be effectively demonstrated to the satisfaction of the certification
body, then a revisit may be required before a certificate can be issued.
AUDIT REPORTING
Following each audit, a full written report shall be prepared in the agreed format defined by the
BRC. Those sites who opt into the Module shall receive a BRC Standard audit report and a Module
audit report.
The first section of the report must be available in English. This is to enable the information to be
uploaded to the BRC Directory database. The detailed audit report section must help the reader to
understand how companies have implemented the requirements of the Module.
The report shall accurately reflect the findings of the auditor during the audit. Reports shall be
prepared by the certification body and dispatched to the company within a period typically no
longer than 42 calendar days (104 calendar days for the initial audit where major non-conformities
are identified) after the audit date.
Where a company undertakes an audit to the Environmental Awareness Module after the date of its
Standard audit, the certification body shall add the Module audit report to the company’s record in
the BRC Directory.
Audit reports shall remain the property of the company purchasing the audit and shall not be
released, in whole or part, to a third party unless the company has given prior consent (or otherwise
required by law). This may be by consent form, or may be contained within a contract between the
company and the user or the company and the certification body. The certification body will retain
a copy of the audit report. The audit report and associated documentation shall be stored safely
and securely for a period of five years by the company and certification body.
A copy of the audit report shall be uploaded by the certification body in the required format to the
BRC Directory.
AUDIT PASS OR FAIL

The purpose of the audit pass or fail system is to indicate to the user of the report where a site has
made an appropriate commitment to the implementation of the requirements of the Module.
The pass or fail assessment is dependent on the number and severity of the non-conformities
identified at the audit and verification by a technical review (conducted by the certification body
management) where the number and severity of non-conformities may change.
TABLE 2 CRITERIA FOR PASSING AN ENVIRONMENTAL AWARENESS MODULE
AUDIT INSPECTION
NUMBER AND TYPE OF PROCESS FOR CERTIFICATE ON RE-AUDIT
NON-CONFORMITIES REVIEWING COMPLETION FREQUENCY
CORRECTIVE ONCE CERTIFIED
CRITICAL MAJOR MINOR ACTION
0 0 <30 Provide objective Yes 12 months (or at next
evidence: Standard certification
audit)
0 Up to 1 Up to 20 ○○ within 28 calendar
days where
company is
0 Up to 2 Up to 10 currently certificated
○○ within 90 days
where this is an
initial audit
0 3 or 4 <10 A full re-audit is No certificate issued Dependent on

required subsequent full
audit result
1 or more
0 >4
0 30 or more
The criteria for a pass are summarised in Table 2. The decision to award a certificate will depend on
the number and severity of non-conformities raised and the completion of effective corrective
actions within the stated time limit by the company. Where the number and type of non-conformities
exceed a certain level, a site will not pass the audit and certification will not be granted.
The pass or fail assessment of the Environmental Awareness Module will not affect the certification
status against the requirements of the Packaging Standard for the company.
CERTIFICATION
After a successful review of the audit report and documentary evidence provided in relation to non-
conformities identified, a certification decision shall be made by the designated independent certification
manager and a certification decision shall be made by the designated independent certification manager
and the certification body shall amend or issue the Standard certificate to reflect the inclusion of the
Module, typically within 42 days of the audit. The certificate shall conform to the format shown in
Appendix 4 using BRC logo usage rules:
○○ The certificate shall contain the six-digit BRC registration number of the auditor. This number
refers to a register of qualified auditors kept by the BRC and enables it to cross-check auditor
competence against the audit carried out. This register is not publicly available.
○○ All dates specified on the certificate shall be in the format of day, month, year, e.g. 11 November 2014.
○○ The date of audit specified on the initial certificate shall be the date of the audit relating to the
granting of that certificate (i.e. the date of the initial audit) irrespective of whether further audits
were made to verify corrective action arising from the initial audit.
The users of certificates are advised to verify that the scope of the certificate is clearly stated and
that this information is consistent in both the Standard and Module audit scopes. Whilst the
certificate is issued to the company, it remains the property of the certification body which controls
its ownership, use and display.
BRC LOGOS
Achieving BRC certification is something to be proud of. Companies that achieve certification
following an audit are qualified to use the BRC logo on company stationery and other marketing
materials. Information relating to the BRC logo is available at www.brcdirectory.com
THE BRC GLOBAL STANDARDS DIRECTORY

The BRC Global Standards Directory (www.brcdirectory.com) is an online searchable directory
of certificated packaging, food, consumer products, and storage and distribution companies.
Each entry includes relevant company details and contact and certification information. The
directory also includes details of certification bodies approved by the BRC.
The BRC Global Standards Directory was developed to provide key information to retailers and to
improve the management of the BRC’s Global Standards scheme. It provides a system of data
storage of audit information, both live and archived. Data is centrally managed and controlled to
maintain accuracy and integrity.
Directory functionality
Information about suppliers certificated to a BRC Global Standard is provided to the BRC by
certification bodies. The directory provides the following publicly available facilities:
○○ a searchable list of certificated companies including contact details, the Global Standard
against which they are certified, their scope and website links
○○ a searchable list of approved certification bodies, including local offices and contact details.
Companies that implement and are certificated against the optional Environmental Awareness
Module must also be certificated to a BRC Global Standard, and their entry in the directory will also
include reference to their certification status for the Module.
The BRC Global Standards Directory provides additional functionality to key user groups, including
companies, customers and certification bodies. This includes user-specific access to certification
information, audit reports and management reporting, further enhancing the value of BRC certification.
SURVEILLANCE OF CERTIFICATED COMPANIES

For certificated companies, where deemed appropriate, the certification body or the BRC may carry
out further audits or question activities to validate continued certification at any time. These visits may
take the form of announced or unannounced visits to undertake either a full or partial audit.
Any non-conformities identified at a visit must be corrected and closed out within the normal
protocol (i.e. within 28 days of the visit, reviewed and accepted by the certification body). If there is
no intention on behalf of the company to take appropriate corrective actions or the corrective
actions are deemed inappropriate by the company, certification shall be withdrawn. The ultimate
decision to suspend or withdraw certification remains with the certification body. Any change in
certification status shall be notified to the BRC by the certification body and the status in the BRC
Global Standards Directory amended accordingly.
In the event of certification being withdrawn or suspended by the certification body, the company
shall immediately inform its customers and make them fully aware of the circumstances relating to
the withdrawal or suspension. Information on the corrective actions to be taken in order to reinstate
certification status will also be provided to customers.
ONGOING AUDIT FREQUENCY AND CERTIFICATION
Scheduling re-audit dates
The ongoing audit schedule shall be agreed between the company and the certification body.
The frequency of audits will be once every 12 months.
The due date of the subsequent audit of the Module shall be calculated from the date of the initial audit
for Standard certification, irrespective of whether further site visits were made to verify corrective
action. This may mean that the original Module certificate has a shorter duration than 12 months.
The subsequent audit shall be scheduled to occur within a 28-day time period up to the next audit
due date. This allows sufficient time for corrective action to take place in the event of any non-
conformities being raised, without jeopardising continued certification.
It is the responsibility of the company to maintain certification. Where an audit is delayed beyond
the due date, except in justifiable circumstances, this shall result in a major non-conformity being
awarded at the next audit. Justifiable circumstances shall be documented in the audit report.
Delayed audits – justifiable circumstances

There will be some circumstances where the certificate cannot be renewed on the 12-month basis
due to the inability of the certification body to conduct an audit. The justifiable circumstances that
would not result in the assigning of a major non-conformity (refer to clause 1.2.7) can include when
the company is:
○○ situated in a specific country or an area within a specific country where there is government
advice not to visit and there is no suitable local auditor
○○ in an area that has suffered a natural or unnatural disaster, rendering the auditor unable to visit.
Moving the audit date to a more ‘acceptable’ later date (for reasons of combining audits, lack of
personnel etc.) is not acceptable.
If the renewal of the certificate is prevented due to the exceptional circumstances listed above, the
customer may still decide to take products from that company for an agreed time, as the company
may be able to demonstrate legal compliance by other means such as risk assessment and
complaints records (until another audit can be arranged).
Audits undertaken prior to due dates

The due date of renewal audits occurs within a 28-day window prior to the 12-month anniversary
of the initial audit.
In some circumstances it is possible to undertake the audit earlier than these due dates, for
example to reset the audit dates to allow combined audits with another scheme. Where an audit
date is brought forward, the following rules shall apply:
○○ The audit report will detail the reasons why an audit has been brought forward
○○ The audit due date will be ‘reset’ to be 12 months from this ‘new’ audit date
○○ The certificate should be issued with an expiry date of 12 months + 42 days from the ‘new’ audit date.
COMMUNICATION WITH CERTIFICATION BODIES

In the event that any circumstances change within the company that may affect the validity of continuing
certification, the company must immediately notify the certification body. This may include:
○○ a significant environmental incident

○○ legal proceedings
○○ product recall
○○ change of ownership.
The certification body in turn shall take appropriate steps to assess the situation and any
implications for the certification, and shall take any appropriate action.
Information shall be provided by the company to the certification body on request so that an
assessment can be made as to the effect on the validity of the current certificate.
The certification body may, as appropriate:
○○ confirm that the validity of the certificate is not affected

○○ suspend the certificate pending further investigation
○○ require further details of corrective action to be taken by the company
○○ arrange a visit to verify the control of processes and confirm continued certification
○○ withdraw the certificate
○○ issue a new certificate in the new owner’s details.
Changes to the certificate or certification status of a company shall be recorded in the BRC Global
Standards Directory.
APPEALS
The company has the right to appeal against the certification decision made by the certification
body, and any appeal should be made in writing to the certification body within seven calendar
days of receipt of the decision.
The certification body shall have a documented procedure for the consideration and resolution
of appeals against the certification decision. These investigative procedures shall be independent
of the individual auditor and certification manager. Documented appeals procedures of individual
certification bodies will be made available to the company on request. Appeals will be finalised
within 30 calendar days of receipt. A full written response will be given after the completion of a
full and thorough investigation into the appeal.
In the event of an unsuccessful appeal, the certification body has the right to charge costs for
conducting the appeal.
WITHDRAWAL FROM THE SCHEME

While it is generally incompatible with the successful implementation of the scheme, it may be
necessary for a company to withdraw a site from the scheme. Should this occur, then a minimum
of six months shall pass before a site can begin the certification process again. The site shall
be required to undergo an initial audit and the date of certification shall not be related to any
previous certification.
APPENDIX 1
ABOUT THE BRC
GLOBAL STANDARDS
The BRC Global Standard for Packaging and Packaging Materials is a GFSI-benchmarked
certification standard that lays down the requirements for the manufacture of packaging materials
used for food and consumer products. Food and non-food businesses may request this from their
suppliers of packaging. The Standard is GFSI-benchmarked.
This Module is entirely optional and sites that have implemented the requirements of, and gained
certification against, the Packaging Standard may choose not to use this optional Module.
The BRC has a range of Global Standards which set out the requirements for the manufacture of
food and consumer products, the storage and distribution, and the sale and brokerage of these
products.
The BRC’s Global Standard for Food Safety is a certification standard for the manufacture
and packing of food and drink products. It sets out requirements based on HACCP, good
manufacturing practice and supporting quality management systems. The Food Safety Standard
is GFSI-benchmarked.
The BRC’s Global Standard for Storage and Distribution is a certification standard that sets out the
requirements for the storage, distribution, wholesaling and contracted services for packaged food
products, packaging materials and consumer goods. The Storage and Distribution Standard is not
applicable to storage facilities under the direct control of the production facility management,
which is covered by the relevant manufacturing standard (e.g. the Food Safety Standard).
The BRC’s Global Standard for Consumer Products is a certification standard applicable to the
manufacture and assembly of consumer products. It specifically excludes food-associated
products such as vitamins, minerals and herbal supplements which fall within the scope of the
BRC’s Global Standard for Food Safety.
The BRC’s Global Standard for Agents and Brokers is a certification standard that complements
the other standards. It provides a framework for businesses in the food and packaging industries
to manage product safety, quality and legality, and is applicable to companies that buy, sell or
facilitate the trade of food, packaging and consumer products.
APPENDIX 2
POLLUTION PREVENTION
FACTORS
AIR
○○ Gas emissions (e.g. VOCs, CO2, SO2, NOx etc.)
○○ Particulates (e.g. dusts and smuts)
WATER
○○ Water discharge (discharge to sewer or river)
LAND
○○ Land occupation (e.g. soil erosion, disturbance)
○○ Land contamination
EMISSIONS TO AIR
○○ Fumes, smoke, output from extraction fans, drying (solvents), CO2 from electricity use
○○ Deterioration of air quality, effect on climate change, ozone depletion, odours, nuisance
(to others)
EMISSIONS TO WATER
○○ Trade effluent, site run-off, spillage of oils, chemicals etc.
○○ Contamination of surface water systems, aquifers, waterways, sea, damage to flora and fauna
EMISSIONS TO LAND
○○ Waste to landfill, seepage of spillage of oils, chemicals etc.
○○ Contamination of aquifers, damage to flora and fauna, nuisance (to others)
WHAT TO CONSIDER
○○ Main activities, products and services at the site
○○ Potential aspects and impacts
○○ Site plan
○○ Site drainage
○○ Any environmental history
○○ Views of interested parties
○○ Other activities that may enable or impede environmental protection or performance
○○ Previous complaints
○○ All activities, products and services that the company may be expected to have a control
or influence upon
OTHER FACTORS TO CONSIDER AROUND PRODUCTION

○○ Procurement
○○ Material and waste storage
○○ Research
○○ Design
○○ Maintenance
○○ Office activities
○○ Warehousing
○○ Contractors
○○ Use and end of life of products
○○ Transport and distribution
RAW MATERIAL AND RESOURCE USE
○○ Energy (e.g. consumption of electricity, fuels, gas, oils and coal – not forgetting compressed air)
○○ Process raw materials or auxiliary materials (e.g. lubricating oils)
○○ Packaging materials
○○ Water consumption (e.g. extracted water or mains water)
○○ Fuels for transport
○○ Storage and handling of materials
WASTES
○○ Hazardous or non-hazardous
○○ Storage and handling of wastes
○○ Nuisance
○○ Noise vibration
○○ Traffic and parking
○○ Visual appearance/housekeeping
○○ Odour
APPENDIX 3
REGISTRATION, QUALIFICATIONS,
TRAINING AND EXPERIENCE
REQUIREMENTS FOR AUDITORS
All auditors conducting audits against the BRC’s optional Environmental Awareness Module are
required to be registered with the BRC. The registration process ensures that auditors have
undergone the required training and identifies the fields in which they have expertise. Evidence of
an auditor’s qualifications, experience and training has to be submitted to the BRC prior to them
carrying out audits. All registered auditors receive a unique registration number, which is included
on the audit report and is automatically cross-checked against their competence before the
certification is accepted on the BRC Global Standards Directory.
The verification of competence to carry out a specific audit shall be conducted by the certification
body. It is the responsibility of the certification body to ensure that processes are in place to monitor
and maintain the competence of the auditor to the level required by the Module.
The BRC publishes a detailed guide for registered certification bodies on auditor competency
requirements; expectations of the initial assessment of auditor competence; ongoing training; and
assessment procedures. This is reviewed and updated periodically by the Technical Advisory
Committee. The following sections outline the requirements of auditors who are registered to audit
against the Module.
EDUCATION
Auditors will be drawn generally from two distinct disciplines: those with expertise and a
qualification in food or biosciences, and those with expertise and a qualification in packaging
technology. This main qualification will be supported by a minimum secondary qualification in the
other discipline as appropriate. Where equivalence of qualification is unclear, this shall be referred
to the BRC for review.
The auditor shall have:
○○ a degree or diploma in packaging and have successfully completed a food safety/hygiene

qualification that is at least equivalent to a UK Level 3 qualification
(see www.brcglobalstandards.com for information), or
○○ a degree or diploma in a food or bioscience-related discipline and have successfully completed
the PIABC EQIPT examination in packaging.
WORK EXPERIENCE
The auditor shall have a minimum of three years’ post-qualification experience related to their main
qualification discipline. This shall involve work in quality assurance, technical management or risk
management functions within manufacture, retailing, inspection or enforcement, and the auditor
shall be able to demonstrate an understanding and knowledge of the specific fields of packaging
for which they are approved. The verification to carry out work within their specific fields of
packaging will be carried out by the certification body.
QUALIFICATIONS
The auditor must have:
○○ passed a registered management system lead assessor course (e.g. IRCA) or the BRC third-
party auditor course delivered by a BRC-approved trainer
○○ completed a training course in HACCP, based on the principles of Codex Alimentarius, of at least
two days’ duration, or be able to demonstrate competence in the understanding and application
of HACCP principles. It is essential that the HACCP course is recognised by the industry as
being appropriate and relevant.
AUDITOR TRAINING
Auditors must have successfully completed a period of supervised training in practical
assessment, including a witnessed assessment of one audit against the Module. Certification
bodies must be able to demonstrate that every auditor has appropriate training and experience.
Auditor competence shall be recorded at the level of each field of audit as indicated in Appendix 4
of the BRC Global Standard for Packaging and Packaging Materials, Issue 5.
Certification bodies must establish a training programme for new auditors, which will incorporate:
○○ a BRC optional Environmental Awareness Module course delivered by a BRC-approved trainer

○○ a period of supervised training to cover management systems, audit techniques and specific
fields of audit knowledge
○○ documented sign-off on the satisfactory completion of the training programme.
Each auditor’s training programme shall be managed and approved by an assessor who can
demonstrate that they are technically competent in environmental management systems.
Full detailed training records of the individual must be maintained by the certification body
throughout the term of employment, and retained for a minimum period of five years after leaving
the employment of the certification body.
Existing BRC auditors for the Packaging Standard who have completed the required number of
audits in the previous 12 months shall have attended and gained a merit pass in the exam for the
BRC’s combined Understanding the Requirements and EMS (environmental management system)
course for the Environmental Awareness Module.
Auditors who are current auditors of EMAS II or ISO 14001 are exempt from the EMS portion of the
training but shall gain a merit pass in the Understanding the Requirements exam.
APPENDIX 4
THE WASTE HIERARCHY
The figure shows the hierarchy of options for how waste should be managed and disposed.
Best option
Prevention
Try to avoid the creation of waste
Minimisation
Reduce the amount of waste created,
where waste cannot be avoided
Reuse
Identify opportunities to reuse
materials, if you can
Recycling
Many materials can be recycled or
used for other applications
Energy recovery
(incineration)
If reuse or recycling isn’t possible,
then the energy in the material may
be recovered through incineration
Disposal
(landfill)
Disposal of waste should be
considered the last resort and
avoiding it may save you money
Worst option
APPENDIX 5
GLOSSARY
Accreditation Procedure by which an authoritative body gives formal recognition of the competence
of a certification body to provide certification services against a specified standard.
Audit A systematic examination to measure compliance of practices with a predetermined system,
whether the system is implemented effectively and is suitable to achieve objectives, carried out
by certified bodies.
Brand owner The owner of a brand logo or name who places the said logo or name onto retail products.
Branded product Products bearing the logo, copyright or address of a company that is not a retailer.
Calibration Set of operations that establish, under specified conditions, the relationship between values of
quantities indicated by measuring instruments or measuring systems, or values represented by
a material or reference material, and corresponding values realised by standards.
Certificate suspension Where certification is revoked for a given period, pending remedial action on the part of the company.
Certificate withdrawal Where certification is revoked indefinitely.
Certification Procedure by which accredited certification bodies provide written assurance that a company conforms
to a Standard’s requirement, based upon an audit and assessment of a company’s competence.
Clause A group of requirements and statement of intent that a site must comply with in order to
achieve certification.
Company The business name and the site seeking certification against the BRC Global Standard for Packaging
and Packaging Materials.
Consumer The end user of an item, commodity or service.
Contamination The action of making impure or hazardous. (Contaminant – that which contaminates; usually physical,
chemical or microbiological in nature.)
Contractor or supplier A person or organisation providing services or materials.
Control To manage the conditions of an operation to maintain compliance with established criteria, and/or the
state wherein correct procedures are being followed and criteria are being met.
Corrective action Procedure to be followed when a system requirement is not met.
Customer/client A person or organisation that acquires, or intends to acquire, ownership of the product.
Environmental aspect The element of an organisation’s activities or products that can interact with the environment.
Environmental impact Any change to the environment, whether adverse or beneficial, that wholly or partially results from an
organisation’s activities, goods or services.
Exemption A requirement that may not be applicable to a product, or product sector, and verified by hazard and
risk analysis.
Good hygiene practice The combination of process, personnel and/or service control procedures intended to ensure
that product and/or services consistently achieve appropriate levels of hygiene.
Good manufacturing practice The combination of manufacturing and quality control procedures aimed at ensuring that
products are consistently manufactured to their specifications.
Hazard The potential to cause harm; may be a biological, chemical or physical entity.
High-risk product Those products intended for human consumption or that will come into close contact with the body,
such as application to the skin, or are intended for infants.
Hygiene All measures necessary to ensure the wholesomeness, quality and safety of an entity that might
otherwise be hazardous.
Hygiene-sensitive product Those products intended for human consumption or that will come into close contact with the body,
such as application to the skin, or are intended for infants.
Incident An event that has occurred that may result in the production or supply of unsafe, illegal or non-
conforming products.
Initial audit The first BRC Global Standard for Packaging and Packaging Materials audit at a company/ site.
Inspection A systematic examination involving professional judgement to determine acceptability against
a specified standard.
Internal audit General process of audit, for all the activity of the company. Conducted by or on behalf of the
company for internal purposes.
Legality Meeting all relevant legislation in the country (or countries) where the product(s) is/ are intended
to be sold.
Non-conformity The non-fulfilment of specified product quality, legal or safety requirements or a variation from
a procedure, practice or performance standard.
Positive release Ensuring a product or material is of an acceptable standard prior to release for use.
Post-consumer recyclate Material generated by households or by commercial, industrial and institutional facilities in their
role as end-users of the goods or service which can no longer be used for its intended purpose.
This includes returns of material from the distribution chain.
Post-consumer waste (PCW) Waste collected after the consumer has used and disposed of it.
Post-industrial waste (PIW) Waste collected before the consumer has used and disposed of it.
Primary packaging That packaging which constitutes the unit of sale, used and disposed of by the consumer,
e.g. bottle, closure.
Product integrity The ability of the packaging material to provide an effective protective barrier for the product it is
designed to contain.
Product recall The removal of unsafe, out-of-specification or illegal products from the supply chain. This includes
products in the possession of the consumer.
Product withdrawal Any measures aimed at achieving the return of out-of-specification or unfit products from customers,
but not from final consumers.
Quarantine The status given to any material or product set aside while awaiting confirmation of its suitability
for intended use or sale.
Raw material Any base material or semi-finished material used by the organisation for the manufacture of a product.
Recycled material Material that has been reprocessed from recovered (reclaimed) material by means of a manufacturing
process and made into a final product or into a component for incorporation into goods or services.
Requirement Those statements comprising a clause with which compliance will allow sites to be certificated.
Retailer A business selling products to the public by retail.
Retailer-branded product Products bearing a retailer’s logo, copyright, address, or products that are legally regarded as
the responsibility of the retailer.
Reuse Cleaning and/or refurbishing an old product to be used again.
Risk The likelihood of occurrence of harm from a hazard.
Safety Freedom from unacceptable risk or harm.
Schedule A tabulated statement giving details of actions and/or timings.
Secondary packaging Packaging that is used to collate and transport sales units to the retail environment,
e.g. corrugated case.
Senior management Those with strategic/high-level operational responsibility for the company.
Shall Is a requirement to comply with the contents of the clause.
Site The area (and its boundaries) containing the activity being audited.
Specification An explicit or detailed description of a material, product or service.
Specifier A retailer, food service company, agent, wholesaler or direct customer of the packaging manufacturer
who may specify compliance to this Standard.
Standard, the BRC Global Standard for Packaging and Packaging Materials, Issue 5.
Subcontractor A firm, company or individual carrying out a process on products on behalf of the site being
certificated to this Standard.
Tertiary packaging Also known as transport packaging, used to facilitate the handling and transport of products,
e.g. pallets and stretchwrap.
Testing A technical operation that consists of the determination of one or more characteristics of a given
product, process or service according to a specific procedure.
Traceability Ability to trace and follow raw material intended, or expected, to be incorporated into packaging
through all stages of production, processing and distribution, including from the supplier and on
to the intended customer.
User The person or organisation who requests information from the company regarding certification.
Validation Confirmation through the provision of objective evidence that the requirements for the specific
intended use or application have been fulfilled.
Verification Confirmation through the provision of objective evidence that specified requirements have
been fulfilled.
Waste Anything for which the generator or holder has no further use and which is discarded or is released
to the environment.
APPENDIX 6
A THANK YOU FROM
THE BRC
The BRC wishes to acknowledge all those industry experts who have contributed to the preparation of the optional Environmental
Awareness Module. In particular, the BRC is grateful to the following members of the BRC Working Group:
Mark Armstrong Asda

John Bentham Printpack
Mark Caul Tesco
Henry Emblem The Packaging Society
Joanna Griffiths BRC
Matthew Kensall Sainbury’s
John Kukoly BRC Americas
Elizabeth Wilks APP
The BRC is also pleased to acknowledge the helpful contributions provided by individuals and organisations from across the globe:
Dagmar Engel QAI

Brian Fowler QAI
Phil Knight Knight International Inspectorate
Eugenio Monti AEB Srl
Michelle Muldoon Americk Packaging
Reinhard Pichler QCE
Yulia Shabrina Ruscam Glass Packaging
BRC Global Standards
21 Dartmouth Street
London SW1H 9BP
Tel: +44 (0)20 7854 8900
Fax: +44 (0)20 7854 8901
Email: enquiries@brcglobalstandards.com
To learn more about the BRC Global Standards

certification programme please visit
WWW.BRCGLOBALSTANDARDS.COM
To learn more about the BRC Global Standards
online subscription service please visit
WWW.BRCPARTICIPATE.COM
To purchase printed copies or PDFs from its full range
of BRC Global Standards publications please visit
WWW.BRCBOOKSHOP.COM

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BRC GLOBAL STANDARD

PACKAGING AND PACKAGING

For more information about BRC, contact:

British Retail Consortium

Tel: +44 (0) 20 7854 8900

PART II REQUIREMENTS OF THE

2 Environmental aspect and impact management system 8

3 Pollution and incident identification and management system 14

4 Environmental management system 17

PART III AUDIT PROTOCOL

HOW THIS PUBLICATION IS ORGANISED

The document consists of the following parts:

○○ Part I Introduction Provides an introduction and background to the development, scope

REQUIREMENTS AND SCOPE

Companies that meet the requirements of a satisfactory environmental management system –

PRINCIPLES OF THE MODULE

SENIOR MANAGEMENT COMMITMENT

A HAZARD AND RISK ANALYSIS BASED SYSTEM

ENVIRONMENTAL MANAGEMENT SYSTEMS (EMS)

ABOUT THE AUDIT AND CERTIFICATION PROCESS

BENEFITS OF THE MODULE

HOW THE REQUIREMENTS ARE SET OUT IN PART II

1.2 SENIOR MANAGEMENT COMMITMENT

Opportunities for improvement shall be identified, implemented and fully documented.

1.3 ORGANISATIONAL STRUCTURE, RESPONSIBILITIES

1.4 MANAGEMENT REVIEW

2.2 RAW MATERIAL USAGE

2.3 WATER USE

2.5 EMISSIONS TO AIR

2.6 TRANSPORT, STORAGE AND DISTRIBUTION

2.7 WASTE MANAGEMENT

2.7.1 The company shall determine and maintain records of:

2.8 LAND USE

3.2 POLLUTION AND INCIDENT IDENTIFICATION AND MANAGEMENT THROUGH

4.2 INTERNAL AUDITS

4.3 DOCUMENTATION CONTROL

5.2 ACCESS AND MOVEMENT OF PERSONNEL

5.3 PROTECTIVE CLOTHING

PROTOCOL FOR THE OPTIONAL ENVIRONMENTAL

If a company is working with a specific customer, it would be advisable to discuss an

SELF-ASSESSMENT OF COMPLIANCE WITH THE MODULE

SELECTION OF A CERTIFICATION BODY

In selecting a certification body, the company should consider the following:

Company/certification body contractual arrangements

○○ company staff numbers and functions

THE ON-SITE AUDIT

NON-CONFORMITIES AND CORRECTIVE ACTION

○○ Critical Where there is a critical failure to comply with an environmental awareness or

AUDIT PASS OR FAIL

0 3 or 4 <10 A full re-audit is No certificate issued Dependent on

THE BRC GLOBAL STANDARDS DIRECTORY

SURVEILLANCE OF CERTIFICATED COMPANIES

Delayed audits – justifiable circumstances

Audits undertaken prior to due dates

COMMUNICATION WITH CERTIFICATION BODIES

○○ a significant environmental incident

The certification body may, as appropriate:

○○ confirm that the validity of the certificate is not affected

WITHDRAWAL FROM THE SCHEME

OTHER FACTORS TO CONSIDER AROUND PRODUCTION

The auditor shall have:

○○ a degree or diploma in packaging and have successfully completed a food safety/hygiene

○○ a BRC optional Environmental Awareness Module course delivered by a BRC-approved trainer

PART II REQUIREMENTS OF THE

2 Environmental aspect and impact management system 8

3 Pollution and incident identification and management system 14

4 Environmental management system 17

PART III AUDIT PROTOCOL