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SQF 2000 and Migration Testing in US


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#1 Jim Eisenhower

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Posted 26 February 2010 - 04:07 PM

I am new to this forum but found the topics very relavent to our company.

In an effort to become SQF 2000 compliant, our QA staff has requested several documents from our suppliers. One of these is Test and Analysis for packaging as noted in Section 4.3.3.2 ii.

After several queries to my suppliers for this information, I am finding that most are not aware of this 'requirement'.

Can anyone tell me if Migration Testing is commonly requested for packaging in the US? I've seen tests from the EU but nothing from the US.

Would someone tell me if this is true: While Compliance Testing to be FDA certifed for food grade packaging is the responsability of the supplier, is Migration Testing also the suppliers responsability or does it fall to the end user to make sure the products being packaged have no migration?

Thank you in advance for your feedback,
Jim


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#2 Simon

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Posted 27 February 2010 - 04:14 PM

I am new to this forum but found the topics very relavent to our company.

In an effort to become SQF 2000 compliant, our QA staff has requested several documents from our suppliers. One of these is Test and Analysis for packaging as noted in Section 4.3.3.2 ii.

After several queries to my suppliers for this information, I am finding that most are not aware of this 'requirement'.

Can anyone tell me if Migration Testing is commonly requested for packaging in the US? I've seen tests from the EU but nothing from the US.

Would someone tell me if this is true: While Compliance Testing to be FDA certifed for food grade packaging is the responsability of the supplier, is Migration Testing also the suppliers responsability or does it fall to the end user to make sure the products being packaged have no migration?

Thank you in advance for your feedback,
Jim

Hi Jim,

In the UK/EU the food producer would need assurance/evidence that the food packaging was approved for food contact, but it is unlikely they would do the migration testing for themselves. They would normally ask for certification and sometimes actual test results from their direct suppliers.

Their direct suppliers would be packaging converters and printers and they would buy in their packaging materials fit for direct food contact. They themselves don’t often do the migration testing, but usually go back to their suppliers of raw materials for confirmation. However there are recent laws that require the converter to have robust quality and GMP systems in place to prevent chemicals such as uncured inks being transferred to the food contact side of the material during production.

Most often the migration testing is undertaken by the primary packaging supplier or the ones who make, mix, apply the coatings to the food contact surface of the packaging materials. There are still open questions on how often this should be carried out, which we have debated on here in the past.

In the US I have no idea of the regulations. I find Keller & Heckman a useful and trusted resource. There is a very long article here that may help:
Food Packaging Regulation in the United States and the European Union

Also: Full list of articles

And:
Frequently Asked Questions on Food Contact Notifications

Be aware the information may be a little old.

Sorry I cannot be of more help; let us know what you find out for future reference.

Regards,
Simon
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#3 cazyncymru

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Posted 27 February 2010 - 11:12 PM

Hi Jim,

In the UK/EU the food producer would need assurance/evidence that the food packaging was approved for food contact, but it is unlikely they would do the migration testing for themselves. They would normally ask for certification and sometimes actual test results from their direct suppliers.

Their direct suppliers would be packaging converters and printers and they would buy in their packaging materials fit for direct food contact. They themselves don’t often do the migration testing, but usually go back to their suppliers of raw materials fro confirmation. However there are recent laws that require the converter to have robust quality and GMP systems in place to prevent chemicals such as uncured inks being transferred to the food contact side of the material during production.

Most often the migration testing is undertaken by the primary packaging supplier or the ones who make, mix, apply the coatings to the food contact surface of the packaging materials. There are still open questions on how often this should be carried out, which we have debated on here in the past.

In the US I have no idea of the regulations. I find Keller & Heckman a useful and trusted resource. There is a very long article here that may help:
Food Packaging Regulation in the United States and the European Union

Also: Full list of articles

And:
Frequently Asked Questions on Food Contact Notifications

Be aware the information may be a little old.

Sorry I cannot be of more help; let us know what you find out for future reference.

Regards,
Simon



You should also test your product AFTER its been in contact with primary packaging to ensure that there is no leaching. can't remember the number at mo, i'll look when i get to work on Monday.

caz x
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#4 Cathy

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Posted 01 March 2010 - 01:40 AM

I have not heard of a lot of pressure on this point from the SQF auditors. If there is a low risk or likelihood of an issue - write up a risk assessment and you may be okwithout testing. For example - high acid products that may be reheated or stored for long periods in plastics are a higher risk than other foods. Also - refer to the SQF Guidance material for egg farms / processors - the language in there may be helpful to you to use in developing your own risk assessment document. Don't bother printing the whole egg guidance - there isn't much that is different in it from the basic SQF 2000 Guidance. Just find the section on packaging...


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#5 Tony-C

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Posted 01 March 2010 - 03:20 AM

I am new to this forum but found the topics very relavent to our company.

In an effort to become SQF 2000 compliant, our QA staff has requested several documents from our suppliers. One of these is Test and Analysis for packaging as noted in Section 4.3.3.2 ii.

After several queries to my suppliers for this information, I am finding that most are not aware of this 'requirement'.

Can anyone tell me if Migration Testing is commonly requested for packaging in the US? I've seen tests from the EU but nothing from the US.

Would someone tell me if this is true: While Compliance Testing to be FDA certifed for food grade packaging is the responsability of the supplier, is Migration Testing also the suppliers responsability or does it fall to the end user to make sure the products being packaged have no migration?

Thank you in advance for your feedback,
Jim


The SQF guidance is quite clear - 4.3.3.3 Validations should include tests and analyses to confirm the absence of potential chemical migrations from the packaging to the food.

Normally I would expect my packaging suppliers to provide periodic migration certificates and a certificate of conformity with every delivery.

Regards,

Tony
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#6 RICKG

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Posted 29 December 2010 - 06:21 PM

Tony,

I also have some concerns over "chemical migration testing". How critical is it that this verification is performed on the sheet stock/raw material, or performed on the finished/thermoformed product? Is it your own experience that the raw material (rolled thermoforming sheet in our case) manufacturer performs this validation, or does the finished packaging product manufactuirer submit sample packaging items to be tested?


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#7 Tony-C

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Posted 04 January 2011 - 04:33 AM

Tony,

I also have some concerns over "chemical migration testing". How critical is it that this verification is performed on the sheet stock/raw material, or performed on the finished/thermoformed product? Is it your own experience that the raw material (rolled thermoforming sheet in our case) manufacturer performs this validation, or does the finished packaging product manufactuirer submit sample packaging items to be tested?



It is normally on the finished packaging (thermoformed product in your case). As Caz has has pointed out there should also be some testing on product but the onus for this is usually on the food manufacturer.

Regards,

Tony
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#8 Cathy

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Posted 12 January 2011 - 12:50 AM

I have seen both types of testing being done - a certificate from the packaging manufacturer and a test done by the end user to show that the specific use is not having an impact. This is particularly important if product is of a high or low pH or if the package is hot-filled.


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#9 midnytbloo

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Posted 16 July 2012 - 07:30 AM

Hi Jim,

In the UK/EU the food producer would need assurance/evidence that the food packaging was approved for food contact, but it is unlikely they would do the migration testing for themselves. They would normally ask for certification and sometimes actual test results from their direct suppliers.

Their direct suppliers would be packaging converters and printers and they would buy in their packaging materials fit for direct food contact. They themselves don’t often do the migration testing, but usually go back to their suppliers of raw materials for confirmation. However there are recent laws that require the converter to have robust quality and GMP systems in place to prevent chemicals such as uncured inks being transferred to the food contact side of the material during production.

Most often the migration testing is undertaken by the primary packaging supplier or the ones who make, mix, apply the coatings to the food contact surface of the packaging materials. There are still open questions on how often this should be carried out, which we have debated on here in the past.

In the US I have no idea of the regulations. I find Keller & Heckman a useful and trusted resource. There is a very long article here that may help:
Food Packaging Regulation in the United States and the European Union

Also: Full list of articles

And:
Frequently Asked Questions on Food Contact Notifications

Be aware the information may be a little old.

Sorry I cannot be of more help; let us know what you find out for future reference.

Regards,
Simon


Our company is also requiring primary packaging suppliers to submit migration test results. As I am not familiar with migration test methods, I've searched the net and found only laboratory facilities which offers those analysis.

One of our suppliers of submitted third-party result of their polyethylene (PE) bags. Shows that there is UV Examination under various solvents (not sure though, but as I've read in one of the article above), Residue on Evaporation, again, under the same solvents, Potassium Permangate Consumption, Lead, and Cadmium.

I am confused as to why would they include lead and cadmium in their analysis though they have certified that the material is food-grade.

Hope I make sense and all. :D Thanks very much in advance.


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#10 Cathy

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Posted 16 July 2012 - 12:47 PM

The requirements for migration testing have been clarified under the SQF Code, edition 7. A test is not always required. Comanies should document their decision when they develop a packaging material specification as to what they will accept and why (based on risk !)


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Cathy Crawford, HACCP Consulting Group
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