8 replies to this topic

[ElaineMcM]

Hi everyone

 

Just a question about the documentation needed for ongoing supplier monitoring. I am wondering if annual migration reports are necessary from all suppliers providing packaging materials (e.g. cardboard outers, boxes, labels) or are they only needed for primary or plastic materials such as cling film, plastic containers?

 

Thanks in advance

 

Elaine

[maara91]

Primarily  for Product Contact packaging

[Simon]

Primary packaging only and not required to update annually.

 

Migration tests would only be updated if change to:

 

• packaging product formulation
• inks or varnishes
• manufacturing process
• food contact regulations
• to extend the permitted use of packaging e.g. high fat & hot fill to a time/temperature combination not previously tested for

 

I'm sure I forgot one.

[Tony-C]

Primary packaging only and not required to update annually.

 

Migration tests would only be updated if change to:

 

• packaging product formulation
• inks or varnishes
• manufacturing process
• food contact regulations
• to extend the permitted use of packaging e.g. high fat & hot fill to a time/temperature combination not previously tested for

 

I'm sure I forgot one.

 

BRC (Food) Guidance also mentions pH under food characteristics so also changes leading to low or high product pH will mean migration tests will need to be revisited.

 

As you have indicated changes to process as well, but also customer usage (microwave, cook in pack or freezing are referred to in guidance).

 

Regards,

 

Tony

[moskito]

Hi all,

 

yes it is the general understanding that risk analysis for primary packaging has to include migration tests no only form the packaging, but also from packed food at the end of shelf life.

But what's about mineral oil (from recycled paper and board) or ITX or others from secondary or tertiary packaging passing the primary packaging (e.g. by diffusion or by gas transfer) and can be detected in food at the end of shelf life? In Germany it will be deduced from EC law (regulation 1935/2004) that other has to be included even if the title is refering to food contact materials.

 

Rgds

Moskito

[Simon]

Hi Moskito, do you mean for example in cereals.  

Like the mineral oils in the board passing through the plastic bag to the cereals?

But if thee food contact material has a natural barrier e.g. it is alu foil then we don't have to worry.

 

Thanks,
Simon

[Snookie]

Primary packaging only and not required to update annually.

 

Migration tests would only be updated if change to:

 

• packaging product formulation
• inks or varnishes
• manufacturing process
• food contact regulations
• to extend the permitted use of packaging e.g. high fat & hot fill to a time/temperature combination not previously tested for

 

I'm sure I forgot one.

I am fairly new to the packaging industry as I have always been on the food side.  So I am seeing packaging in a whole new light, I am struggling with some of these regulations.  I see where the testing criteria is spelled out fairly plainly.....but don't see the frequency.    Can you tell me where to find what you said above. 

 

But I also saw on a white paper discussing the new regulations by the Plastics Europe, Association of Plastic Manufacturers, that in the issue of compliance, they say,"...it is the responsibility of the downstream users to check compliance of the final article." 

 

 I am getting plastic that is pre-made and now I am making it into a container that will contain food.  This is not unusual many companies buy their plastic already formulated. So based on what I read above it is my responsibility to confirm the product at least as far as the migration testing.  Having talked with more than a few producers of these food grade plastics, they are leaving it to their customers to do the testing.  Since most of these plastic blends are proprietary, I won't know when a formulation might change.  I can only control my processes.  Therefore I would think that annually would be the minimum unless I am specifically informed of a change.

 

Also

 

 

 

...But what's about mineral oil (from recycled paper and board) or ITX or others from secondary or tertiary packaging passing the primary packaging (e.g. by diffusion or by gas transfer) and can be detected in food at the end of shelf life? In Germany it will be deduced from EC law (regulation 1935/2004) that other has to be included even if the title is refering to food contact materials.

 

 

Mineral oil use is not restricted to recycled paper and board.  It is a common material used when pressing or handling many types of paper, board and plastics, especially in a high speed environment. 

 

It is a conundrum.  It looks to me like the onus is placed on the company forming the packaging or perhaps even on the company putting the food in the container.  When it should be on plastic/paper or other material manufacturer.   That being said, I would always verify what I am being sent in some way.  However, looks like our testing bill is going up.....a lot!  The labs got to be loving this

[moskito]

Hi Simon.

 

not only cereals, but many other products with no or low barrierer efficiency. PP is better than PE, but less effective than PET and alu (alu with a minimum thickness). Plactic foil with a very thin alu layer is able to reduce the migration by gas phase transfer.

In Germany there is a legislation in development a) for printing inks b) for mineral oil.

Focus is on product contamination end of shelf life, i.e. declaration of conformity and migration test is not sufficient, even contamination is not comming from primary packaging (=food contact material).

For mineral oil in addition examinations has started looking for contamination during the food chain (e.g. jute bags in chocolade (-> batching oils), dust reduction agents (-> rice)). So we see the major entrance by recycled fibre, which we could overcome using a "product safe", but there is in some products a "raw material input".

With mineral oil analytics are difficult - in in special not the analytic itself, but the evaluation/calculation/interpretation of chromatograms. There is no clear separation between MOSH, MOAH, POSH and NOSH (and some others). But these or to much details for a post. Some more information here http://www.bfr.bund....uffs-60836.html

 

Rgds

moskito

[moskito]

Hi Snookie,

 

pls see me former post. POSH is PE-derived components which look like (MOSH) in the chromatogram.

Plastic is - for all migrating components like ink, mineral oil etc - a more or less effective barrier. Be even you are using minreal oil free ink for your products does not mean that all problems solved. The number of components used in packaging are hugh - you can create a new scandal every few week - beginning with ITX, 4-MBP and any other substance (not known yet) with a "X" in the name.

The former layer-based differentiation in primary, secondary or tertiery packaging doesn't help in future if you are looking from the food, because the substances in question should not be in the product end of shelf life. The pure definition as before does not help.

To change this thinking is a very hugh and cost intensive problem, because you have to included news papers, recyceled fibre industry and its collection strategy, the politics and their recycling quote, foreign countries, in many cases Third World or developin countries etc etc etc.

For me this means: Create a Safe for your product and avoid, what's possible, because you don't know, what's coming tomorrow. But then your are in the cost discussion - a scissor between sales, margins, prevention and risk minimization etc.etc.

That means: All this will not happen in near future, but I think within the next ten years the world will have changed in this topic.

I am not a packaging specialist, but I am sure this will become a broader topic like e.g. microbiology, allergens etc., in which more than packaging specialist has to be included.

 

Rgds

moskito