9 replies to this topic

[blinky]

Hello everybody,

I’m new here and I want to ask you something about BRC/IOP standard that I’m in a dilemma.

‘’2.2.4. The hazard and risk analysis shall include microbiological, foreign objects and chemical (e.g. taint, odour, ALLERGEN, component transfer from inks, varnishes & glues) contamination, any problems arising from the use of recycled materials, legality and defects critical to consumer safety as well as those hazards that may have an impact on the functional integrity and performance of the final product taking into account the customer requirements.’’

I looked some regulations and one regulation mentions about soya, milk etc. about allergen list.

Maybe milk packaging producers should do the allergen risk assessments cause milk is an allergen material, however we produce chewing gum packaging which direct contact with gums.

You know gums have the layer (name xylett or something else) nowadays; can we suppose that layer a shield? And the important thing that I’m curious about, have to I make allergen tests or assesments? How can I do it for the board that direct contact with gums?

I hope I could explain my problem

Thank you everybody.

[Bag man]

Hi Blinky

I don't pretend to be the font of all knowledge on the subject, But as regards to the layer (Xylett) If this is consumed then its not a shield. If you were producing eggs or bananas that have a skin or shell which is not consumed it would work then.

There is an accepted list of food allergens and if any of these are present you should declare it along with any controls you have in place to keep the production line free if producing allergen free products too.

The hazard and risk analysis can take the form of a score card and include in column 1 the risk, column 2, the likelyhood, column 3 the severity. Score columns 2 & 3. then multiply them to achieve a score. High scores have to be investigated.

As far as the packaging board is concerned, Can the board producer not provide a certificate of conformance to warrant that their product is suitable for direct contact with foodstuffs and contains no recycled content? I would think that a packaging supplier should be able to provide detailed information about the inks and varnishes and any other components used.
If they hold BRC certification they will probably have done it already so this should be easy enough.

As far as the critical defects clause is concerned, If you have read it and considered it and found no defects in your product or processes that would cause harm to the consumer, and have evidence of a meeting where it was considered, then that might be all you need.
If there was a defect that may cause harm to a consumer that is a different matter and will require some investigation.

hope this helps a bit

Good luck

[blinky]

Dear Bag Ban,

Thank you very much for your reply.We're packaging firm and we provide a certificate of conformance from our board suppliers. Also we have HACCP plans and we make risk analysis like you write. I just have not enough knowledge about allergen risk assesments, therefore i have asked.

We implement our Haccp plan for packaging
I mean, should we do any extra special thing for the product which been placed in the packaging? Let's give an example from us;should we do anything special for chewing gum. (on account of allergen tests)

[Charles.C]

Dear blinky,

I’m not a packaging person but I can appreciate yr motivation in trying to go further than a mere requirement to acquire a blank cheque certificate of raw material conformance. The food producer has the same quandary when he surveys his packaging in that as the last stage, the buck really does stop with him/her.

This type of packaging conundrum is not new here, for example can see this sort of (non-allergenic) parallel thread, ca 2005 –

http://www.ifsqn.com...ndpost__p__6330

Maybe appropriate links are on this forum already (too lazy to look) but I would expect that the most probable allergenic risks associated with packaging (if any) are by now well-documented ? Surprisingly, when I tried googling on this topic, didn’t see any immediate links to nice Codex lists. The only visible readable, up-to-date link of some depth which had any (limited) direct allergenic refs to packaging was this SA document –

 guidelines for foodlabelling.pdf   207.34KB   154 downloads
(See Guideline 2 et seq, does some packaging really have wheat origins, section 4.1 ? )

There are of course numerous other food driven allergy manuals / procedures on this site which may hv packaging sections. I recall that the model Kraft HACCP packaging plans here also had allergenic considerations discussed within the text.

Somewhat surprisingly to me, this, I presume, very well known packaging resource did not appear to mention the intrinsic allegen/packaging aspect in their semi-flyer.

 PACsecure_Food_Safety_for_Packaging_Materials_PACsecure_HACCP_summit_2010.pdf   934.46KB   272 downloads

(Maybe the intrinsic risk is usually accepted as uniformly low though I doubt it in these highly-scutinised times. ??)

Hope these uninformed comments hv some relevance. No problem if peer-assessed otherwise .

Rgds / Charles.C

PS Sorry but I know nothing about chewing gum

[blinky]

Thank you Charles,

The links that you take will stand me in good stead.

[Foodworker]

Good Morning Blinky,

There are essentially two aspects in dealing with the allergen requirements of the BRC/Iop Standard.

The first relates to printing of any allergen information on packaging. If the consumer can't read any allergen warnings because of poor printing, a sufferer may inadvertantly consume something that they shouldn't. You should include print quality anyway in your Hazard Analysis under the general heading of functional integrity. (I don't know which part of the chewing gum packaging that you manufacture)

The second is to determine whether there are any allergens in your raw materials and your own operation. Different countries have their own lists of defined allergens, in the EU they are found within Directive 2003/89/EC but you will need to get a list related to your own country.

Generally there are not many that I have found in packaging, but they are sometimes not obvious. Some examples of where to look are:

adhesives, some are based on wheat starch of which gluten is an allergen (I have found this being used in the fluting of corrugated cases)
food grade lubricants (I have seen ground nut oil being used!)
anti set off powders used in printing, again sometimes a fine wheat based starch
food brought into the building by staff.

Once you have identified what allergens may or may not be on your site, you need to assess the risk to your customers and their consumers. Evaluate the likelihood of contamination and the severity of the consequences of contamination.

Although you have to do a systematic risk assessment it is unlikely that there will be any critical risks from allergens within your factory and you should not need to carry out any allegen testing yourself.

[Charles.C]

Dear Foodworker,

(Blinky, hope you don’t mind me responding first)

Many thks yr input.

As far as I can see, the EC directive you refer basically lists ingredients within foodstuffs which are to be considered allergenically labelable but does not discuss packaging material aspects as such.

The allergenic substances / packaging examples you quote are perceptive and interesting (in retrospect I can see the possible relevance of glue! ).

Subsequently i did a little more googling and found this link which seemed quite informative -

http://www.khlaw.com....aspx?Show=1349

and, via the above, this general one also - http://www.packaginglaw.com/ which has a search option.
(I daresay these links are already well-known to packaging people)

@Foodworker, If you can suggest any more relevant links, would no doubt be appreciated (including yr concluding paragraph).

I should add that in my first post, i didn't mention the possibility of simple contamination within the packaging process since i assumed that this aspect would usually be well-covered by the producer. Now I'm not quite so sure.

Personally, as a food producer, the two (specialised) packaging items which hv given me the most (knowing) trouble are getting confirmation regarding the identity/safety of printing inks plus the nature of the coating material applied to food-contact/non-contact box-bag surfaces (customers-retailers do like nice, shiny colours! ).

Rgds / Charles.C

[Foodworker]

Good Afternoon Charles,

I have not found anything really helpful which is specific to allergens in packaging (with the exception of latex which is a slightly different issue)

You are right, the Directive essentially lists the allergens of concern which may need labelling in a food. This at least gives a starting point. If you know what you are looking for, it helps you ask the right questions of your suppliers and colleagues. For many people allergens simply mean peanuts.

I have found this document useful when putting allergen management systems into food factories. It is heavy going in some areas but there are good sections on the background to allergens and risk assessments. It is clearly targeted at a food audience rather than a packaging audience but it may be helpful.

http://www.food.gov....ontainguide.pdf

Your comments about inks are unfortunately very familiar to me as well. Suppliers are often reluctant to give you anything definitive and intersperse their documents with all sorts of disclaimers. There is a European Printing Ink Association document which is quite good, but I can't lay my hands on it at the moment.

[Charles.C]

Dear Foodworker (and Blinky),

Thks yr response.

Getting a bit off-topic however in the primarily food-driven area, I agree yr link is a very fine document indeed. It is one of the, perhaps 3-5 major manuals mentioned several times here particularly ca. 2008 when this topic seemed to suddenly boom on this forum (although a lot of the US / EC trigger publications appear to be around 2005-6.). The major thrust seemed to be from USA / EC / Australasia but I daresay there were others. At that time I recall a sequence of heavy official / industry discussions seemingly starting up in UK particularly regarding labelling protocols / appropriate HACCP procedures / the unsatisfactory nature of the “may contain traces blabla” escape route. Funnily enough, this discourse seems more (officially) muted these days although the rate of recalls remains (curiously unexplainably) prodigious as far as I can see (another topic which understandably keeps coming up here ). Almost like there is some measure of resigned acceptance that the sheer chemical complexity / number of directions from which allergenic labelling failures can originate is uncontrollable in a generic sense so companies are unwilling to put in really heavy-duty control schemes. The only obvious comment is that the rate of listed recalls in UK, for example, must be costing a small fortune somewhere. Perhaps I’m wrong about the attitude, certainly hope so.

I suspect the widest scoped / interactive (food) allergen resource so far mentioned on this site is an Australian / NZ (?) website which (maybe) Simon first put up here. Might be worth Blinky's hunting for this one out and using their search option.

To illustrate the allergenic scope in a (relatively) non-technical albeit wide-ranging way, here are 2 more links –

http://allergycases....-avoidance.html
(first time I hv noticed sexual allergenic references, placed at the bottom of course! )

and, specifically food oriented -
http://www.kintera.o...LjP7E&b=1630585

Sorry for extended diversion, coming back to present thread, I couldn’t find any mention of specific packaging possibilities in the 2008 UK manual other than latex which, as you said, is a somewhat side issue. Could be that US are more focussed on this specific issue although my initial post does seem to concur yr opinion that the overall risk is currently regarded as very, very low, as one would certainly hope (!).

@Blinky, again apologies for rather hijacking yr thread, I hope the discussion is at least illustrating the issues involved regarding yr original posting. I still feel there must be a suitable (up-to-date) summarising risk assessment article laying around for the overall packaging scenario. So far, seems EC hv missed out on this one .

Rgds / Charles.C

[BBrandDesign]

Food packaging materials should be stored in designated areas to avoid allergen cross-contamination. Packaging materials should be suitable for allergen-free food products. An allergen management/control program is an effective tool to avoid unintentional allergen cross-contamination of food products, to prevent food recalls and to protect consumers. An allergen management/control program is an effective tool to avoid unintentional allergen cross-contamination of food products, to prevent food recalls and to protect consumers. The implementation of a control program will depend on the size and specific factors of your facility.