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Our material suppliers do supply us with certification letters to the correct FDA CFR's, but this does not really provide and information relating to shelf life food in a package. I believe the migration to be a different issue, although the amount of barrier and type of material both will affect migration as well as shelf life on a particular product. My question is strictly in relation to 4.3.1.2 of the SQF Code which states the following: Product formulation, manufacturing processes and the fulfillment of product requirements shall be validated by facility trials, shelf life trials and product testing.
4.3.1.3 Shelf life trials where necessary shall be conducted to establish and validate a products:
i. Handling, storage requirements including the establishment of “use by” or “best before dates”;
ii. Microbiological criteria; and
iii. Consumer preparation, storage and handling requirements.
We initially had it stated in our procedure that Shelf life trials where never necessary for our product. When we had our desk audit, the auditor would not except this, so we had to add the "where necessary" back into our procedure which then required us to add more definition as to how we would test and document shelf life testing when it was needed. We still feel that for the product we sell "Paper Trays" there is no requirement for us do do shelf life testing, because our customers would not be able to use our results for their products. The cost and time that would be required for us to test every possible formulation that our customers might use our product for is not feasible.
I feel there is still a very big disconnect in the SQF code and the manufacturing of food packaging. The code still needs to have a more customized section specifically for food packaging manufacturing, because the environment is so different than food production.
Thanks for your comments
Jason
Somebody (you or your raw material supplier) needs to conduct migration testing on the range of food contact packing materials you supply. Migration testing can be carried out using various food simulants at various time/temperature combinations. This migration testing determines which food groups the materials are suitable for use with and under what conditions. Once you have established this you can create a certificate of compliance for each material and this can be provided to customers with the initial delivery or during product realization (sampling / specification phase).
The best solution would be if you could ask customers for details about their product and process so that you could check which of your materials is most suitable from a functional and migration point of view. Ultimately it’s your customers responsibility to ensure legal compliance of the packed product for filling, storage and shelf life conditions and they may have to conduct their own migration testing to be certain. It is an absolute minefield and will make consultants and laboratory’s big bucks in the coming years.
Regards,
Simon
