The Role of Process Water in the New BRCGS Guidelines

In October 2024, BRCGS published the latest version of the Packaging Materials Standard - Issue 7. As of 28 April 2025, this version will be mandatory for all BRC-certified companies. The revised standard tightens requirements in areas such as risk management, traceability, supplier monitoring, documentation, and - most notably - food safety culture.

A striking change in this edition is the explicit focus on process water quality as part of product safety and hygiene. While water was previously often taken for granted, the new BRCGS version makes it clear: water is a critical factor in every quality and safety management system.

Process Water as a Risk Factor

The new standard requires a risk-based assessment of how process water is used. This means that companies must demonstrate an understanding of where and how water is applied - whether in direct contact with products, during the cleaning of packaging lines, or in indirect process steps.

In addition, an annual verification of water quality is now mandatory. Parameters such as microbiological load, conductivity, and chemical composition must be monitored, and any deviations must be addressed immediately. This helps prevent unnoticed contamination, which could have significant consequences for product safety and brand reputation.

From Risk Assessment to Validation

BRCGS Issue 7 calls for an enhanced Hazard and Risk Assessment (HARA), including annual validation of process flows. For water, this means organizations must be able to prove that their control measures are effective.

In previous versions, such as BRCGS Packaging Materials Issue 6, process water was only briefly mentioned in the section on “Utilities.” Companies merely had to show that water was “suitable for use,” without clear guidance on monitoring frequency, risk assessment, or validation. This has now changed.

Culture and Compliance

Beyond technology and data, food safety culture plays a greater role. The standard encourages organizations to foster a culture in which employees act with hygiene awareness and feel empowered to report deviations through whistleblowing systems. Actively monitoring water quality is part of this mindset - it is a shared responsibility within the production environment.

What Does This Mean for QA and Production?

For QA managers, process technologists, and plant managers, BRCGS 2025 means that process water monitoring must become a structural part of daily operations - not only to comply with the standard but to ensure continuous microbiological safety.

The Watter system supports this by generating a powerful and safe disinfectant (HOCl) on site. This keeps process water continuously free from pathogens and biofilm - without the use of hazardous chemicals. It makes demonstrating water safety during audits both easier and more sustainable.

Proven better.

Summary

• New BRCGS version mandatory from 28 April 2025
• Process water quality now explicitly part of risk assessment
• Annual water quality testing and immediate action on deviations required
• Integration of water management into HARA and validation processes

Watter offers a proven and sustainable solution for water disinfection