5 replies to this topic

[jcri]

Dear All,
I am implementing the ISO22000 system in my company from scratch. I am working particularly on collecting our supplier specifications for raw materials and food contact materials (EU/UK legislation).
I think this will be one of the major problems because the large number of suppliers. In particular for the engineering department they have never really kept any information (company positon statements) about food contact materials and they have hundreds of different pieces (plastic, rubber, composite) from numerous suppliers.
This has created a bit of panic and the chief engineers refused to even start the work of collecting all the food grade material statements. Of course I didn’t agree but for be honest is real huge amount of information’s to collect.
Do you have any advice about this issue? How much all this documentation is important in the PRP's programme?
Thank you in advance for your help.

Jcri

[PaulM]

Regarding food contact components:

 

Without respect to the scale of this process accounted for in the hundreds of different pieces from numerous suppliers.

 

If you approach the task from what must be done in any single component, I recommend the following:

 

• Identify and confirm that the component is food contact
• Identify the source(s) from which the component(s) is/are obtained
• Make contact through the appropriate channels (Supplier Control, Regulatory Control, Quality Assurance, etc.) to identify the material constituents of the component
• Require documentation of the specific material's regulatory compliance status for each
• Confirm that the regulatory citations within each regulatory compliance document provided for each resin, polymeric or elastomeric material contained therein are, in actuality, references to the legal and/or regulatory subsections that are pertinent to your use of the component
• Consider Conditions of Use requirements for each material with respect to holding or cooking of food, temperature, aqueous or olefinic contact, or product acidity limitations
• It is all to easy for a minor supplier of a critical food contact component to "pencil whip" a reference to regulatory compliance without ever having researched the actual material or the Conditions of Use limitations.  

You must do that research in the regulations if you have doubts. Keep in mind that food safety legislation of product contact materials and approval of compliance are not usually granted on a per item basis; although there may be provisions for approval in this manner.  

 

Most regulatory compliance approvals of polymeric materials are by means of Generally Recognized as Safe (GRAS).  The legislation may list those substances that are considered GRAS with specific limitations of amounts of chemicals present or detectable.  Certification statements from the material manufacturer, even under GRAS, is usually wholly acceptable in the control scheme.

 

Good luck with this project.

PaulM

[jcri]

Thank you for your advice and i will need a lot of luck :)

Cheers

[Simon]

Great advice Paul.

Thanks.

[GMO]

One thing I did in a site which had a lot of old equipment is audit the equipment myself and keep a record of it.  It's pretty obvious if things are stainless steel vs aluminium for example.  Even if you can't tell if plastics are suitable for food contact it's a step in the right direction and proof you've considered it.   If you then keep a record of all the manufacturers you've contacted for info, if the auditor raises something, at least you can prove you've tried.

What I'd do as well is put in place some kind of simple procedure for equipment purchase which includes the instruction "obtain certification that the equipment is food safe and complies with applicable legislation" then you can prove to the auditor you will be compliant going forward.

[Simon]

Good idea GMO, close the gate to new issues by considering food contact materials on new equipment and then review existing equipment and materials. You should have a procedure for new equipment purchase that includes considerations for the specifying of equipment (including food safety and healh and safety criteria) as well as Factory Acceptance Test (FAT) and Site Acceptance Test (SAT).