Control of Foreign Materials

Hello everyone - Food packaging materials printer here - We manufacture packaging for chips, bars, snacks etc.. The product is supplied in roll form to packaging companies - I'm looking for input on how other printers are handling splices that must be made in the slitting/finishing process. We found a US FDA CFR Title 21 175.105 compliant tape to use to splice rolls together however the CFR states that the tape must be separated by a functional barrier and other limitations......- The tape isn't the issue because the packagers throw away the bag or pouch that contains the splice - we're wondering about the underside of the roll that is in contact with the tape from the previous wrap - Has anyone been questioned about that in an audit or how do you deal with splicing tape that is widely used in our industry?

Any input would be greatly appreciated as always.

Tony Z

Hi Tony, like you say the tape join and some material either side is removed and disposed of.  So what you are talking about is adhesive, chemicals, dirt, foreign bodies etc. transferring from the tape to the material underneath the joint.  If in the unlikely event there was transfer the tape is in contact with the non-food contact side (printed side) of the material underneath - I think this is correct?  Doing a likelihood v's severity risk assessment of this to me comes out as very insignificant indeed.  Using a standard tape from an approved supplier would be enough for me, if you had sourced an FDA CFR Title 21 175.105 compliant tape I'd be like "wow".  I'm not arguing with CFR, but if they are saying "that the tape must be separated by a functional barrier" then it seems like overkill..if they mean using tape in the above described context. 

SQF, BRC etc. are very heavy and detailed audits and so on the day there are usually far bigger fish to fry than this.

Regards,
Simon