BRCGS Consumer Products Issue 4 Contamination Control and Foreign Body Detection (Section 6 Part 2)

By Robert Low, Director, Lead Auditor & BRCGS Approved Trainer

The 6.3 block of Issue 4 is all about risk and foreign bodies: chemical and biological control, metal control, glass, brittle plastic, ceramic and wood, and then the detection and removal equipment, filters and sieves, metal detection and X-ray, magnets and optical sorting. It gets its own post because it generates more audit findings per clause than almost anywhere else in the standard, and because the whole block only makes sense when it hangs off your risk assessment rather than existing as a set of rituals.

Risk Assessment First, Equipment Second

The decision about which controls and which detection equipment you need is an output of your process risk assessment, not a shopping list. What can realistically contaminate the product at each step, and what combination of exclusion, control and detection reduces it to acceptable? A site that cannot connect its metal detector to its risk assessment has a machine, not a control. Equally, an assessment that concludes no detection is needed must actually justify it, because the auditor will ask.

Chemical, Metal, Glass and Brittle Materials

Chemical control means an approved register, labelled containers, no decanting into anonymous bottles, controlled storage and trained users, and in scented product environments, taint awareness. Metal control means governed sharps: issued knives, no snap-off blades, broken needle procedures where needles exist, and staples and drawing pins kept away from exposed product. Glass and brittle materials demand a register with locations and conditions, checked at a risk-based frequency, plus a breakage procedure that contains the incident. The findings write themselves: the register that has not noticed a broken light diffuser, the unlabelled spray bottle, the engineer’s snap-off knife. Small things, but each one is the system failing at exactly the point it exists for.

Detection Equipment That Would Actually Catch Something

For filters, sieves, metal detection, X-ray, magnets and optical sorters, the pattern is identical: specify the capability (mesh size, sensitivity, strength) from risk and best practice, test at a frequency that reflects how much product you would have to quarantine if the test failed, record everything, and investigate what the equipment catches rather than binning it. The two classic failures: test frequency copied from somewhere with no link to hold-and-release capability, and rejects treated as waste instead of trend data. And when a detector fails its check, everything since the last good check gets re-inspected, which is exactly why the frequency question matters. Findings from this block also deserve proper root cause rather than a retest and a shrug, the CAPAVA discipline applies here more than anywhere.

What Changes Under Issue 5

Issue 5, as per the public draft, moves this block into site standards, splits contamination control and foreign body detection into separate sub-sections, adds container cleaning equipment, and introduces allergen and sensitising materials management alongside. The logic is unchanged: risk first, equipment second. Full detail in the Issue 5 breakdown. Back to the series hub, or on to Section 7.