Packaging

Materials

ISSUE 6
PACKAGING
MATERIALS

Additional Module 10

Plastic Pellet Loss Prevention

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PACKAGING MATERIALS ISSUE 6
ADDITIONAL MODULE 10
PLASTIC PELLET LOSS PREVENTION

Liability

BRCGS 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 BRCGS 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
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excluded.

Nothing excludes or limits the liability of BRCGS 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 Global Standard for Packaging Materials Issue 6: Additional Module 10 – Plastic Pellet Loss Prevention 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.

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© BRCGS 2020

All rights reserved. No part of this publication may be transmitted or reproduced in any form (including photocopying
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BRCGS is a trading name of BRC Trading Ltd.

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Contents
Part I Introduction 03

Part II Requirements 05
10 Pellet, flake and powder control in the plastics industry 06
10.1.1 Senior management commitment and continual improvement 06
10.2.2 Hazard analysis and risk assessment 06
10.3.5 Internal audits 07
10.3.6 Corrective and preventive action 07
10.3.13 Management of incidents 07
10.4.2 Building fabric and interiors: raw materials handling, preparation, processing,
packing and storage areas 08
10.4.4 Site security
10.4.5 Layout 08
10.4.8 Housekeeping and cleaning 09
10.4.10 Waste and waste disposal 09
10.5.8 Incoming goods 10
10.6.1 Personnel: Training and competence 10

Part II Audit Protocol 12

Appendix 1 16
Reducing Plastic Pellet Loss to the Environment 16

Acknowledgements 17

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PLASTIC PELLET LOSS PREVENTION

Part I
Introduction
Scope 03
Benefits of certification to the module 03
How the requirements are set out 03
Non-applicable clauses 03
Relationship of the module to the Standard 04
How the module is arranged 04
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Part I
Introduction
The pellet loss prevention module focuses on the containment of primarily pre-production plastic waste that potentially
ends up in the environment, particularly the waterways in the form of pellets, granules, flakes, powders, dust and offcuts.
These materials often have an adverse effect on the wildlife that inadvertently swallow them.

BRCGS has developed this module to provide a framework for companies to develop an awareness of, and a mechanism
for improvement in the containment of, plastic pellet loss which is detrimental to the environment. There are a number of
industry initiatives, including Operation Clean Sweep (see Appendix 1), and this module is designed to be complementary
to these initiatives by providing the means for sites to be externally audited and certificated. The aim of the module is
to expand the scope of the audit against the Global Standard for Packaging Materials. The module can also be used with
the Global Standard for Consumer Products where pre-production plastic raw materials are manufactured into finished
products.

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 management of pellet loss.

This publication sets out the requirements for the auditing of manufacturers and converters of packaging materials
to enable them to achieve certification to Additional Module 10 – Pellet Loss Prevention for the Global Standard for
Packaging Materials (hereafter referred to as the Standard).

Scope
The use of the module is voluntary but subject to the customer mandate. It is applicable to companies that manage
primarily plastic or polymer-based packaging materials. Such materials are also used in the manufacture of finished
consumer products.

Benefits of certification to the module

The following are some of the benefits to be derived from this additional module:
• Sites can be audited against this module as part of their annual audit.
• Successful audits help to demonstrate the site’s commitment to sustainable practices in the management and control of
plastic pellet, granules, flakes, powders, dust and offcuts loss.
• Sites can display a certificate to confirm that they meet the requirements of the module.
• Certification helps to demonstrate a commitment to the many sustainability initiatives within the industry to reduce
pellet loss.

How the requirements are set out

Each clause of the module begins with a highlighted paragraph that is the statement of intent.

Below this statement, in tabular format, are the specific requirements that, if applied appropriately, will help to achieve
the stated objective. The requirements and the statement of intent 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 requirements of the module will apply to all types of business involved in the manufacture of plastic packaging
materials and products.

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The auditor will assess and decide on the validity of any clauses that the company has requested to be excluded because
they do not apply. The final audit report will include comments on those clauses marked as non-applicable.

The requirements are based on certificated companies being able to demonstrate their commitment to sustainable
practices for the prevention of plastic pellet, granules, flakes, powders, dust and offcuts loss, their use of the effective
controls, and the provision of a product safety and quality culture in the work force.

Relationship of the module to the Standard

Certification to this module can only be achieved if the site is fully compliant with the requirements of the relevant
Standard. All applicable clauses of the Standard shall include provision for the site to achieve certification to the module.
Some examples of applicable clauses include:
1.1 Senior management commitment and continual improvement
2.2 Hazard analysis and risk assessment
3.2 Document control
3.5 Internal audits
3.6 Corrective and preventive action
4.8 Housekeeping and cleaning
4.10 Waste and waste disposal
5.7 Control of non-conforming product
5.9 Storage of all materials and intermediate and finished products
6.1 Training and competence: raw materials handling, preparation, processing, packing and storage areas

How the module is arranged

The scope of the module is closely aligned with the requirements of the Standard. Where the requirements extend beyond
those of the clause in the Standard, the numbering of the module reflects the clause number in the Standard, but is
preceded by the module number (10).

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Part II
Requirements
10 Pellet, flake and powder control in the
plastics industry 06
10.1.1 Senior management commitment and
continual improvement 06
10.2.2 Hazard analysis and risk assessment 06
10.3.5 Internal audits 07
10.3.6 Corrective and preventive action 07
10.3.13 Management of incidents 07
10.4.2 Building fabric and interiors: raw materials
handling, preparation, processing,
packing and storage areas 08
10.4.4 Site security
10.4.5 Layout 08
10.4.8 Housekeeping and cleaning 09
10.4.10 Waste and waste disposal 09
10.5.8 Incoming goods 10
10.6.1 Personnel: Training and competence 10
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10 Pellet, granules, flakes, powders, dust and offcuts control in the plastics
industry
10.1.1 Senior management commitment and continual improvement
The site’s senior management shall demonstrate that they are fully committed to sustainable practices in the prevention of
loss of pre-production plastic materials.

Clause Requirements
10.1.1.11 The site shall have a documented policy that states its intention to control and prevent the loss of
pre-production plastic materials. These include pellets, granules, flakes, powder, dust and offcuts.

10.1.1.12 The site’s senior management shall have a system in place to ensure that the site is kept informed
of and reviews industry codes of practice and that it meets the minimum legal requirements in
pellet loss prevention and recycling targets.

10.1.1.13 The site shall establish systems to ensure that raw materials are appropriately managed and that
the risk of loss of pellets, granules, flakes, powder, dust and offcuts to the environment and
subsequent contamination is minimised.

10.1.1.14 The site’s senior management shall establish clear objectives and targets that demonstrate
commitment towards zero loss of pre-production plastic materials to the environment. The
objectives shall be:
• documented and include targets or clear measures of success
• clearly communicated to staff
• monitored and the results reported at a suitable predetermined frequency to the site’s senior
management.

10.2.2 Hazard analysis and risk assessment

A documented risk assessment shall be in place to identify hazards and ensure that effective controls exist to prevent the
loss of pre-production plastic material to the environment.

Clause Requirements
10.2.2.13 There shall be a risk assessment of the process from intake to dispatch to assess where loss or
spillage of raw materials might occur. This shall include as a minimum:
• product ingredients
• additives
• processing aids
• internal and external storage locations
• connection points
• transfer points.

10.2.2.14 A review of the risk assessment shall be carried out at least once a year and following any
significant incidents.

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10.3.5 Internal audits

The internal audit programme shall include inspection of the procedures and measures that have been put in place and
whether they have been successful in the control and prevention of pre-production plastic loss to the environment.

Clause Requirements
10.3.5.6 Loss prevention procedures and containment measures shall be included in the internal audit
programme.

10.3.5.8 Internal audits shall record evidence of a review of:

• procedures, containment measures and record-keeping
• activities related to the containment and recovery of pre-production plastic from devices such
as catch trays, drains and connection valves
• the state of repair of containment measures and clean-up equipment.

10.3.5.6 Internal audits shall include inspection of the state of repair of the containment measures and
clean-up equipment.

10.3.6 Corrective and preventive action

The site shall demonstrate that it uses the information from failures in containment and pellet , granules, flakes, powders,
dust and offcuts loss prevention to take corrective and preventive action.

Clause Requirements
10.3.6.3 Incidents resulting in the loss of pre-production plastic to the environment shall be recorded and
investigated to include all areas affected. This includes:
• informing regulatory bodies (where permits require it)
• identifying the root cause
• developing steps to prevent recurrence
• measuring the success of preventive action.

10.3.13 Management of incidents

The site shall have a documented procedure and systems in place to effectively manage any incidents to minimise
pre-production loss of plastic that would have an adverse impact on the environment.

Clause Requirements
10.3.13.8 The site shall determine what constitutes a spillage or loss incident. The documented spillage/loss
incident procedures shall include, as appropriate:
• inspection, clean up and disposal to prevent impact to the environment
• handling heavy rain and flooding incidents.

10.3.13.9 There shall be an annual test of the system for managing spillage/loss incidents.

10.3.13.10 In the event of an incident, the appropriate regulatory bodies shall be informed within a
reasonable, agreed timeframe and a record kept.

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10.4.2 Building fabric and interiors: raw materials handling, preparation,

processing, packing and storage areas
The site shall be maintained to an appropriate standard to reduce the risk of the loss of pre-production plastic to the
environment.

Clause Requirements
10.4.2.9 Pre-production plastic materials delivered in plastic bags shall be stored in appropriate containers
and locations to prevent tears, damage and leakage.

10.4.2.9 External silos, pipework or other access points for pre-production plastic materials shall be
appropriately sealed and secured.

10.4.2.9 Tanks, silos and containers shall be kept in good condition.

10.4 Site security

The layout of the site shall be appropriate to reduce the risk of the loss of pre-production plastic to the environment.

Clause Requirements
10.4.4.4 The site shall establish security systems to prevent the exposure of pre-production plastic to
malicious actions

10.4.5 Layout
The layout of the site shall be appropriate to reduce the risk of the loss of pre-production plastic to the environment.

Clause Requirements
10.4.5.8 There shall be a plan of the site that includes, where relevant:
• the site boundary
• drain locations, discharge locations and types at the site boundary
• loading and unloading bays/points
• raw material storage locations.

10.4.5.9 The site shall have a plan and systems in place to effectively manage any potential loss or spillage
of raw materials to ensure that the risk of contamination of the environment is minimised.
10.4.5.10 The site shall implement containment measures as identified by the risk assessment.
The assessment shall include consideration of:
• drain covers
• drain sieves
• buckets at transfer points
• collection trays at unloading valves
• connection points
• enclosures
• bunding.

10.4.5.11 The site shall establish security systems to prevent the exposure of pre-production plastic to
malicious actions.

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10.4.8 Housekeeping and cleaning

A good standard of housekeeping shall be maintained to minimise the loss of pre-production plastic to the environment.

Clause Requirements
10.4.8.6 Documented cleaning procedures shall be in place for the effective containment and recovery
of pre-production plastic materials to prevent loss to the environment through accumulation or
spillage:
• into drains
• onto the site floor at transfer and connection points
• onto the ground at goods-in or other delivery points such as external valves.

10.4.8.7 Suitable clean-up materials and equipment shall be used and validated for cleaning effectiveness
on a regular basis.

10.4.8.8 Spills shall be cleaned up on a timely basis to prevent the dispersion of pellets, flakes, dusts and
powders.

10.4.8.9 Procedures detailing the action to be taken in the event of a spillage shall be implemented and
include the following:
• cleaning the area
• checking of footwear and protective clothing
• recording of the incident
• checking of equipment used in clean-up operations.
Staff shall be trained in the correct procedures.

10.4.8.10 Equipment designated for use in clean-up operations shall be maintained and checked
periodically. Where filters and sieves are used these shall be kept clean and replaced as necessary.

10.4.10 Waste and waste disposal

Waste disposal shall be managed in accordance with legal requirements and to minimise the loss of pre-production plastic
to the environment.

Clause Requirements
10.4.10.8 The site shall provide dedicated covered waste containers for pre-production plastic waste
material. This material includes:
• recyclable or resalable pellets and flakes
• non-recyclable pellets and flakes
• offcuts
• dust.
Waste containers shall be emptied at appropriate frequencies and maintained in an adequately
clean condition.

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10.5.8 Incoming goods

The site shall ensure that incoming goods are checked for packaging integrity and contamination.

Clause Requirements
10.5.8.6 The site shall ensure that incoming goods are checked for packaging integrity to prevent the loss
of pellets and flakes.

10.5.8.7 pre-production plastic material that is not suitable for direct use shall be clearly labelled and
traceable, segregated and protected against contamination.

10.6.1 Personnel: Training and competence

The company shall ensure that all staff performing the work to contain and prevent pre-production plastic loss shall be
adequately trained.

Clause Requirements
10.6.1.7 The site shall ensure that staff have been trained and are following the relevant procedures for the
containment and loss prevention of pre-production plastic materials.

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Part III
Audit Protocol
Audit planning 12
The on-site audit 12
Standalone audit to the module 12
Non-conformities and corrective action 13
Grading 13
Audit reporting 14
Certification 14
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Part III
Audit Protocol
Audit planning

Preparation by the company

The certification body shall be notified in advance of the audit of the intention to add the module to the scope of the
audit. This ensures that sufficient additional time can be scheduled and that an auditor with the appropriate qualifications
for the additional module is selected.

Information to be provided to the certification body

The company shall supply the certification body with any additional background information requested prior to the audit
to ensure that the auditor is fully prepared to audit against the module. This is likely to include information on the:
• types of raw materials to be included within the scope
• number of suppliers used to source the products.

Audit duration
In order for the module to be included within the audit programme, additional time will be needed. The amount of
additional time will depend upon the:
• size of the site and the extent of the plastic handling operation
• number of raw materials included
• number of suppliers.
Typically the additional time will be 2–4 hours. The certification body shall indicate the expected additional time
requirements when planning the audit.

The on-site audit

Compliance with the requirements of the module is normally assessed as part of the audit against the Standard and is
expected to be integrated into the audit programme as appropriate.

During the audit, detailed notes shall be made regarding the site’s conformities and non-conformities against the
requirements of the additional module, and these will be used as the basis for an addendum to the audit report. The
auditor(s) shall assess the nature and severity of any non-conformities.

At the closing meeting, the auditor shall present their findings and discuss all non-conformities identified against the
module. A written summary of the non-conformities discussed at the closing meeting will be documented by the auditor
either at the closing meeting or within 1 working day after completion of the audit.

The decision to award certification for the module will be determined independently by the certification body
management, following a technical review of the audit report and the closing out of non-conformities in the appropriate
timeframe. The company will be informed of the certification decision following this review.

The module can be audited as part of an announced or unannounced audit.

Standalone audit to the module

By exception, where it is not possible to undertake the audit for the module at the same time as the audit for the Standard,
a return visit to the site, not in combination with the Standard audit, may be made by the same auditor who undertook the
audit for the Standard.

In this case, it is recommended that the audit should be planned for a duration of 3.5 hours (half a day), and that the auditor
should assess not only the module requirements but also re-assess the relevant requirements of the Standard where needed.

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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 on evidence collected and observations made during the audit. The level of non-
conformity shall be verified by the certification body management.

Non-conformities
Non-conformities against requirements of the module shall be graded in the same way as non-conformities against
requirements of the Standard, namely:
• Critical Where there is a critical failure to comply with a legal issue or evidence of plastic loss resulting in a significant
environmental impact within the scope of the module.
• Major Where there is a substantial failure to comply with the statement of intent or any clause of the module, or
where a situation is identified which would, on the basis of available objective evidence, raise significant doubt as to the
compliance of the site with the requirements of the module.
• Minor Where a clause of the module has not been fully met but, on the basis of objective evidence, there is no
significant environmental impact within the scope of the module.

Procedures for handling non-conformities and corrective action

Following identification of any non-conformities against the module during the audit, the company must undertake
corrective action to remedy the immediate issue (correction). The process for closing out non-conformities depends upon
the level of non-conformity and the number of non-conformities identified.

Critical non-conformities
If a critical non-conformity is identified against the module, then the site cannot be certificated without a further full audit
of the module.

Where this occurs at a site that already holds certification for the module, certification must be immediately withdrawn.

If it is a requirement of customers that they shall be informed when their suppliers have a critical non-conformity or fail to
gain certification against a module, the supplier shall immediately inform its customers.

Note that a critical non-conformity against a requirement of the module does not necessarily prevent certification against
the Standard or other additional modules.

Major and minor non-conformities

The module cannot be included on a certificate until major and minor non-conformities have been demonstrated as having
been corrected, either permanently or via a temporary solution that is acceptable to the certification body.

Close-out of non-conformities can be achieved either by objective evidence being submitted to the certification body,
such as updated procedures, records, photographs or invoices for work undertaken, or by the certification body undertaking
a further on-site visit.

If satisfactory evidence is not provided within the 28-calendar-day period allowed for submission following the audit,
certification for the module will not be granted. The site will then require a further full audit in order to be considered for
certification of the module.

The certification body will review the objective evidence of corrective action having been completed prior to awarding a
certificate.

Grading
There will be no grading of the Plastic Pellet Loss Prevention module. The module will either be certificated or not.

Any non-conformities identified when assessing the module shall not be taken into account when deciding the grade for
certification against the Standard.
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Audit reporting
Following each audit against the module, a written report shall be prepared in the agreed format which will form an
addendum to the Standard audit report. The addendum report shall be produced in English or in another language,
dependent upon user needs. Where the report is produced in a language other than English, the applicable audit summary
sections shall, in addition, always be reported in English.

The report addendum shall be prepared and dispatched to the company following the same rules as the report for the
Standard (Issue 6, Part III, sections 2.4 and 2.6). Where the audit has been completed as a standalone audit rather than in
conjunction with the audit of the Standard, the module shall be reported using the standalone module report.

The full audit report, together with the addendum for the Plastic Pellet Loss Prevention module, shall be uploaded to
the BRCGS Directory in a timely manner irrespective of whether a certificate is issued. The owner of the audit report may
allocate access to the audit report with the addendum to customers or other parties in the directory.

The audit report and associated documentation, including the auditor’s notes, shall be stored safely and securely for a
period of 5 years by the certification body.

Certification
After a review of the audit report for the module and documentary evidence provided in relation to the non-conformities
identified, a certification decision shall be made by the certification body management.

Note that the modules are certificated separately from the Standard; however, where certification to the Standard is not
achieved, certification for the module cannot be awarded, irrespective of whether the requirements of the module have
been met.

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Appendicies
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Appendix 1
Reducing Plastic Pellet Loss to the Environment
All parts of the supply chain have a responsibility for ensuring that plastic pellets, flakes, powders and offcuts are
contained and do not escape to the environment. 

Operation Clean Sweep is an international initiative developed by the US Plastics Industry Association (PLASTICS). In the
UK, for example it is led by the British Plastics Federation (BPF).

By signing up to Operation Clean Sweep, companies make a commitment to adhere to best practice and implement
systems to prevent plastic pellet loss.

The Operation Clean Sweep Plastic Pellet Loss Prevention Manual contains best practice measures for all types of plastic
handling and transporting operations on how to prevent, contain and clean up plastic pellet spills. 

For additional information, please visit the global website of Operation Clean Sweep at: https://www.opcleansweep.org/
Stakeholder cooperation throughout the supply chain is important to ensure effective measures are put in place for pellet
loss containment.

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Acknowledgements
BRCGS is grateful to the following people who helped to develop the additional module, Plastic Pellet Loss Prevention.

Grace Abamba BRCGS

John Bentham BPF
Marco Berruti PTCG (Italy)
David Brackston BRCGS
Robert Broughton BPF
Roy Dixon IOM3
Lesley Hemson LAH Consultants
Adela Putinelu BPF
Gary Whatmore NSF

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Materials

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