10 replies to this topic

[skredsfan]

I'd love to hear from anyone with some knowledge of the packaging industry as it relates to Food Contact Surfaces. Quick rundown of our process and future goals. We're a Paperboard Packaging Company that mainly produce food & beverage cartons. However all of our products are secondary (Non-Direct Contact). Our goal is to produce Primary (Direct Food Contact) Packaging in the near future Our equipment ranges from sheeters, printing presses, cutters and gluers. I'm currently writing our Food Safety Management system and I've got some questions regarding Food Contact Surfaces. It's my understanding that anything made of stainless steel is acceptable? Some of our machine surfaces and rollers that come in contact with the paperboard are made of stainless steel but many are not. Some are made from aluminum, rubber, etc. What does this mean for us moving forward? Will we be forced to change out numerous rollers, etc on any machine that we wish to use to produce primary packaing materials? Management wants the flexibility to produce primary packaging materials on various machines, but I'm not so sure that's a realistic. I think this could be very costly. If rebuilding machines to make them FDA approved is the only option then perhaps I should reccommend only using specific machines to produce Primary Packaging Materials. Any help with this would be greatly appreciated!

[Charles.C]

I'd love to hear from anyone with some knowledge of the packaging industry as it relates to Food Contact Surfaces. Quick rundown of our process and future goals. We're a Paperboard Packaging Company that mainly produce food & beverage cartons. However all of our products are secondary (Non-Direct Contact). Our goal is to produce Primary (Direct Food Contact) Packaging in the near future Our equipment ranges from sheeters, printing presses, cutters and gluers. I'm currently writing our Food Safety Management system and I've got some questions regarding Food Contact Surfaces. It's my understanding that anything made of stainless steel is acceptable? Some of our machine surfaces and rollers that come in contact with the paperboard are made of stainless steel but many are not. Some are made from aluminum, rubber, etc. What does this mean for us moving forward? Will we be forced to change out numerous rollers, etc on any machine that we wish to use to produce primary packaing materials? Management wants the flexibility to produce primary packaging materials on various machines, but I'm not so sure that's a realistic. I think this could be very costly. If rebuilding machines to make them FDA approved is the only option then perhaps I should reccommend only using specific machines to produce Primary Packaging Materials. Any help with this would be greatly appreciated!

Dear skredsfan,

Yr query is rather wide scope.

Fot food applications, the usual (glib) answer to yr surface compatibility question is that the item should be constructed from appropriate Food Grade materials. Packaging not my direct area but I'm guessing that same logic may hold although various operational contraints are clearly different, eg food processes are often wet.

For yr stainless steel query, here is a presumably authoritative UK answer -

http://www.bssa.org.....php?article=45

As you can see, the answer is multi-faceted.

From US viewpoint, i noticed this quite detailed survey over a range of materials.

http://edis.ifas.ufl.edu/fs119

I would hv thought most of yr subsidiary questions, eg rollers etc are most readily answered by the machine suppliers but maybe this no longer an option.

Maybe if you are specific over individual items, packaging people here may have some (general) ideas.

Rgds / Charles.C

[john123]

I know nothing of food manufacturing equipment, so one question I have right off the bat is regarding the stainless steel surfaces and rollers you're looking into: are any of them made to be "food grade", or are any even availabe? If not, your best case scenario might be to validate they can be sterilized via your cleaning methods.

Regarding food grade vs non-food grade: I think you could go back and forth between the two on the same machine, but you're going to need a verified sanitation and cleaning program that proves, via testing, and no residue(s) is/are left over from the non-food grade before you start production on the food grade. Especially if you're doing any sort of inks or dyes in the packaging (first thing that came to mind regarding cartons). Ideally, you have one area that works on food grade, one that doesn't, and they never cross paths.

Also, when shipping out food grade cartons, how will you ensure they don't get contaminated in their shipping container? I'll give you one example our consultant discussed with us in our many food safety discussions. He was helping a facility set up for an SQF audit: a bakery that produces pies. They have proof from their manufacturer that the pie tins are food grade and intended for use in pies, but the manufacturer ships the pie tins in non-food grade boxes with no barrier (or at least the manufacturer had no documentation that the pie tin box was food grade). In his mind, that bakery can't prove the pie tins didn't get contaminated on the way to the facility. They resolved it, but it was a gap they had to address.

Hope that helps, just food for thought.

[Simon]

In my experience it is not necessary to change all of your rollers. Packaging material is usually in contact with rollers for a short time, so migration is not a serious issue. I have seen all sorts of rollers in packaging manufacturing such as steel, hardened rubber, plastic, teflon coated etc. Good condition and cleanliness of rollers is very important, so procedures need to be based around this, vitally important is the choice of chemicals used to clean the rollers e.g. does not transfer and cause taint. To validate this you could carry out periodic micro swabbing and you should also be conducting periodic end product migration testing.

Regards,
Simon

[Sharon (Dewsbury)]

Hi ,

we print, cut/crease, fold/glue cartons and sleeves for primary & secondary food contact. We list the below and comment on the relevance to our company. i.e N010/2011 is not relevant as it is for plastic not board.

For the machine surfaces we just record them as being cleaned, maintained and inspected on a regular basis. We use blue rubber where possible ( belts etc) and the blankets come with a declaration from the supplier.

I'd be interested to see your list too lease in case I have missed anything.

Sharon (Dewsbury)

 

Food Safety

Materials & Articles in Contact with Food Regs (EC) no.1935/2004

 

The Packaging (Essential Requirements) (with amendments) regs 2009

 

REACH (EC No 1907/2006)

EU-Regulation (EC) 2023/2006 GMP

EuPIA European Printing Association guidelines 2005

EU regs N0.10/2011 Migration

 

[skredsfan]

^{Equipment compliance is still proving to be a bit more difficult than verifying compliance of raw materials, and other materials such as belting. Compliance letters were provided by our suppliers for many other materials & services, however in the case of equipment surfaces (rollers, rails, etc.), it's very difficult to determine the composition of them. Our parts manuals don't give a detailed description of the composition of the surface. It simply states what the part is, a part #, and the manufacturer. This seems like a very time consuming process that could lead to a lot of dead ends! I've attempted to contact one of our printing press suppliers ,to verify if the machine is suitable for use in production of direct food contact packaging. I received no response! I hope I discover a smoother process for determining this information soon!}

[Simon]

Hi Skredsfan,

What are the rollers made from in the print press, steel or plastic?

Are they impervious or not?

Are they cleanable or not?

 

Are they cleaned regularly? hopefully so.

What are they cleaned with? Can it contaminate and taint product?

 

Do you carry out periodic micro tests on rollers and product that has been through the print press?

Have you ever carried out migration testing to see if any chemical contamination of product that has been through the print press?

 

It would be helpful to know the material of the rollers, but in the end you need to have a robust roller (food contact surface) cleaning program in place and you can validate its effectiveness by undertaking the micro and migration tests.

 

Regards,

Simon

[skredsfan]

Simon,

 

The rollers are made of different materials ranging from steel, aluminum, rubber, etc. In some cases the rollers have ceramic and/or chrome coatings. The surfaces are impervious & cleanable. We use a basic cleaner that's common in the printing industry because of it's ability to dissolve ink. We have never carried out any migration testing, however we have performed microbiological testing on our equipment. We have a good cleaning program in place and it's validated with our swabbing. However, determining the regulatory status (FDA) of a food contact article must be performed through a letter of guarantee, or consulting 21 CFR parts 174-186. In addition to that clause 8.3 of PAS 223 (FSSC 22000) states that Food Packaging contact surfaces shall be constructed from materials suitable for the intended use (direct food contact packaging), to prevent contamination. I'm not sure how much focus will be on equipment material composition during certification audits? During our recent FSSC 22000 audit, there was virtually zero focus on equipment material composition because we're not currently producing direct food contact packaging. I suspect that when the auditor returns next year, there will be more focus on this particular area, assuming that we've began producing direct food contact packaging. I've reached out to multiple suppliers and some have been  more helpful than others! I hope I can gather all of the information that I need in a timely manner!

[Simon]

Based on what you say I think you will be fine, e.g. rollers are cleanable, subject to cleaning schedule, cleaning materials cannot taint and you do swabbing.  The rollers are not food contact articles, they are articles that come into contact with food contact packaging (well they will do).  There is a difference.

 

Regarding migration testing I would forget about this for now, until it becomes a requirement in the US (I don't think it is yet).  Otherwise your head may spontaneously explode.

 

Regards,

Simon

[skredsfan]

Based on what you say I think you will be fine, e.g. rollers are cleanable, subject to cleaning schedule, cleaning materials cannot taint and you do swabbing.  The rollers are not food contact articles, they are articles that come into contact with food contact packaging (well they will do).  There is a difference.

 

Regarding migration testing I would forget about this for now, until it becomes a requirement in the US (I don't think it is yet).  Otherwise your head may spontaneously explode.

 

Regards,

Simon

 

Simon,

 

You were right on the money with everything you stated! I actually spoke with someone directly from the FDA today. (Office of Food Additive Safety/Division of Food Contact Notifications). He basically explained to me the same things that you've mentioned in this post. As long as the surfaces are non-toxic, non-absorbent, easily cleanable, durable & resistant to chipping, pitting. etc. then we'll be fine from a compliance standpoint. If we have a customer request to perform different forms of migration testing, then we'll certainly do so. As for now we'll continue to stick to our cleaning schedule & microbiological swabbing as validation. Thanks very much for your input!

 

Shane

[Simon]

Simon,

 

You were right on the money with everything you stated! I actually spoke with someone directly from the FDA today. (Office of Food Additive Safety/Division of Food Contact Notifications). He basically explained to me the same things that you've mentioned in this post. As long as the surfaces are non-toxic, non-absorbent, easily cleanable, durable & resistant to chipping, pitting. etc. then we'll be fine from a compliance standpoint. If we have a customer request to perform different forms of migration testing, then we'll certainly do so. As for now we'll continue to stick to our cleaning schedule & microbiological swabbing as validation. Thanks very much for your input!

 

Shane

 

Thanks for the feedback Shane, I think I know some stuff, but it's nice to get validation on my knowledge.

 

Regards,

Simon