11 replies to this topic

[Peter Snopko]

Our vendor audit programme now has a requirement for our packaging vendors to have a Contaminants Surveillane Programme, to monitor for chemical or other contaminants which may be introduced via raw materials or duint the manufacturing process.

I am having a problem getting an example of a programme and hope that someone on the forum maybe able to share a copy of theirs with me, so that I can understand the format and all the key elements. Not exactly easy to find in any text books. Dont need the theory, just a practical working example.

A HACCP programme is good for deciding where the CCPs are using the big 3 (chemical/physical/Bioogical), but I understand the the surveillance programme is a seperate programme to HACCP.

Looking forward to any responses.
Cheers
Peter

[Charles.C]

Our vendor audit programme now has a requirement for our packaging vendors to have a Contaminants Surveillane Programme, to monitor for chemical or other contaminants which may be introduced via raw materials or duint the manufacturing process.

I am having a problem getting an example of a programme and hope that someone on the forum maybe able to share a copy of theirs with me, so that I can understand the format and all the key elements. Not exactly easy to find in any text books. Dont need the theory, just a practical working example.

A HACCP programme is good for deciding where the CCPs are using the big 3 (chemical/physical/Bioogical), but I understand the the surveillance programme is a seperate programme to HACCP.

Looking forward to any responses.
Cheers
Peter

Dear Peter Snopko,

It looks to me that someone is getting over-creative on you.

It surely depends on the system you are talking about but i attach a published jumbo CSP relating to fish. (Just search the document for "Contaminant" to localise the specific item).

Rgds / Charles.C

Attached Files

•  Great Lake Contaminat Surveillance Program - 2006GLBTS_en.pdf   12.55MB   73 downloads

[Simon]

Hi Peter / Charles,

I'm aware of the requirement for testing food contact packaging to ensure compliance with legislation and specifically migration testing. Is this what you mean by "Contaminants Surveillance Programme" - somehow I don't think so...

Regards,
Simon

[Peter Snopko]

Hi Charles
thank you for the Great Lakes document, it looks very interesting but is not what I am looking for.

Packaging manufacturing sites need to monitor the chemical risks to the packaging item, whch may be in the form of incorrect raw materials, or from lubricants and cleaning chemicals used on the manufacturing equipment, or from residual solvent levels left after laminating or printing film/foil etc.

I guess alot of this is going to need a risk assessment and an then a monitoring programme based on the outcomes of the risk assessment. Hence my reference to a programme similar to HACCP.

Simon - you mentioned migration testing, which is normally conducted when setting up and approving a new packaging structure. Not sure this would form part of an ongoing monitoring Chemical Contaminants Surveillance programme.

So if anyone has a model, then love to see it, otherwise will need to build something from scratch.

Appreciate the time you have taken to respond to my question.
Cheers
Peter

[shea quay]

If you are just looking at HACCP from the big three, then you may be missing something.
Take, for example, the Beatles, aka the Fab Three. There was Ringo, the voice of Thomas the tank engine, possibly the largest chemical contaminant of our time, blurting out his dioxins that contaminate our food products. Then there was John Lennon, a strong example of the danger of physical hazards, lead in particular. Then there was George, who went on to form the Travelling Wilburys, no doubt a reference to the dangers of the vehicles for microbiological contamination, along with "supergroups" and the death of Tom Petty as a believable artist. Finally, there was the other guy. He married a vegetarian, who lost her leg due to a lack of protein, an example of an intrinsic hazard.
An intrinsic hazard may be something along the lines of what you are thinking of. At each stage of your haccp plan, introduce the "other beatle" intrinsic hazard concept. Introduce your recipe/bill of materials pre-requisite, introduce your maintenance pre-requisite, introduce your product changeover training procedure. Once you have your pre-reqs and show that you have considered these things, the relax, have a mull of kintyre, play the pipes of peace, and you'll soon find that your safety and quality plan is completely bom, bom bom, ai-a, bom, bom, bom, ai-a.
Hope this helps, Peter. Just remember, we all stand together.

[Charles.C]

Dear Peter Snopko,

Presumably one pragmatic approach would be to work backwards from the most detailed specs. available for yr specific packaging to see why the specific contaminants were chosen. This can then (hopefully) be correlated to yr inputs (if any). Then compare the results to the specs. for the inputs and expand where necessary. Causes are surely discussed in packaging textbooks. May well be available to any reasonable level in the standard US tables for food contact packaging contaminants which do often contain the data references. I guess NZ may hv equivalent databases.

I think some of the 3-6 (?) generic haccp plans already posted here for packaging do go a partial way (eg prioritised scope/well- known problems) to matching yr request. Other (slightly more esoteric) threads here also go into various of the finer details, eg printing ink compositions, labelling gums, but a fair bit of searching will be required.

How much of any conclusions are amenable to yr own monitoring is probably going to be (rapidly) financially limited. (for example just look at the tables on pgs 96,102 of my previous attachment). Somehow I suspect yr knowledge will soon surpass that of yr requester so as to enable satisfaction of the (unknown) reason for the original request. Or the precise reason (probably a lot less complex) will hv to be more specifically stated.

Rgds / Charles.C

[Peter Snopko]

Hello Charles
The packaging environment is quickly trying to catchup with the standards and systems that are typical in the food safety area.

I am still trying to get packaging vendors around the world to get a robust HACCP programme in place. I have assessed a few of these and still find holes in their risk assessments, which is why the contaminants surveillance programme has become of interest.

Food Safety compliance for various banded chemicals is a good starting point for the programme and I like your suggest to use this to work backwards to the cause of the contamination.

I think it will work itself out in the end as I now dont believe there are any models around that I can use as a bench mark.

Thank you for all the pointers
Cheers
Peter

PS: Beautiful cold sunny morning here...we are sliding into winter.....hope your spring/summer weather is treating you well.

[Simon]

I think I get you now Peter.

Let’s assume a packaging raw material specification meets all regulations for a food contact packaging material and it has been tested and proven to do so and has undergone further in depth migration studies to establish for what products and processing conditions it is suitable for use.

What you don’t want is subsequent chemical contamination of the material during printing, conversion etc. by printing inks, processing aids, lubricants, cleaning agents etc.

So we need to control the manufacturing - here are a few layers to control that:

1. Chemicals control program including: inventory, risk assessment, substitution or removal of bad stuff, control of use etc.
2. Printing inks are compliant with for example EUPIA guidelines
3. Robust GMP and Quality control on print press to ensure inks and dried/cured and do not transfer
4. Plus standard GMP throughout manufacture, storage and distribution
5. All of the above apply to suppliers who are involved in the manufacture

Finally program of lab tests of finished product to confirm no chemical contamination, maybe conducted very 3-5 years or following change to product / process.

This is just my ideas on the subject for discussion I’ve not seen this written down anywhere.

Feel free to add/edit/delete - for discussion.

Regards,
Simon

[Peter Snopko]

Hi Simon
You are up late?

Yes you are onto what I am trying to achieve.

Its all about what contamination can happen either directly or indirectly....including what the packaging manufacturer is checking with their vendors too.
Thought you maybe interested in seeing alist of the top nasties list that need to be monitored, either via documentation or actual testing.

a. BHA/BHT/TBHQb. Phthalates DEHPDBPDINPDIDPBBPDIBP c. Nonyl phenol ethoxylates d. Di methyl fumarate e. BPA f. BADGE, NOGE, BFDGE g. VCM h. Acrylonitrile i. Halogenated flame retardants j. Polycyclic aromatic hydrocarbons (PAHs)
Cheers
Peter

[Simon]

Night time is the only time I get any peace Peter.

What is the source of the chemicals list?

Do you have a picture of a chemical control and contaminants surveillance program?

Regards,
Simon

[Peter Snopko]

Hi Simon
The banned chemicals list is made up of all the banned chemicals in the USFDA, EU and other country regulations. We are subject to most countries regs as we export to so many o f them.

Dont have a picture of a programme, as thats what I am trying to get myself. Looking for a model so I can fully understand the practical scope of such a programme.
Cheers
Peter

[Gita]

Hi Peter,

 

i know i'm three year late.., and Simon was spot on

 

 

I also need to draft a surveillance plan in this regard, and am looking for ideas on how to documnet this,  specifically for the Lithographic printed cartons for food packaging. Hoping you can asssit.

 

Additionally, i also need some qualified laboratories doing these migartion test on cartons.

 

regards

Gita