Answers to posted questions by the presenter: .
How do you determine if food packaging is compliant with the EU food packaging legislation?
Compliance with EU food packaging legislation involves at least 5 checks;
- Overall compliance with the EU “framework legislation” (i.e. (EC) No 1935/2004)
- Conforming to relevant material-specific implementing measures regarding composition (e.g. Plastics Implementation Measure EU No 10/2011)
- Conforming to article migration limits established by such measures (using either simulated migration protocols or worst case calculations)
- Production using good manufacturing practices according to regulation (EC) No 2023/2006
- Conforming to relevant member-state packaging regulations in areas for which harmonized EU regulations are presently not in force.
In each case, take care to determine the current status of all such regulations. (The GFSI-benchmarked standards require monitoring of ongoing regulatory issues as part of a certified management system)
Hi Tom, What would you say were the top 3 most severe hazards for food packaging?
My informal response (based not on any statistically-valid data, but on anecdotal experience from gap analyses and pre-audits) would be:
- Lax behavioral procedures (e.g. no hand-washing requirements or food on the production floor) that can lead to allergen contamination. (Biological hazard)
- Absence of verified GMPs that assure proper curing of reactive (2- or more part) chemicals, such as adhesives and coatings. Improper curing can leave hazardous by-products to migrate into food. (Chemical hazard)
- An “out-of-sight, out-of-mind” mentality regarding storage that allows accumulation of dirt and other contaminants on materials. (Biological, chemical, and physical hazards!)
Apart from chemical contamination what about missing print or unreadable text on printed ingredients e.g. especially on allergens. Is this critical and how would you mitigate the risk in the facility?
Food packaging manufacturers must have graphics-tracking systems (both physical and digital) to insure that the printed messages planned for—produced with—the physical packaging article correspond to customer’s requirements as well as materials handling systems to insure that printed articles are properly labeled, inventoried, and manifested (for shipping).
Food processing facilities should confirm the agreement of printed package ingredient declarations with real-time ingredient usage with respect to accuracy, completeness, and legibility.
At a guess how many food packaging companies have GFSI Certification in the USA?
My guess is that less than 10% OF for food packaging manufacturing facilities have GFSI certification in the USA. On the other hand, the largest manufacturers have been convinced by their (large) customers to gain certification. As a result, my guestimate is the about 50% of the food packaging articles in the USA ar produced by certified facilities
Sometimes it is totally impossible for the food producer to find a packaging supplier that has some kind of GMP for his/her materials. Therefore you should design some kind of process or instrument to avoid any possible risk to your foodstuff. Is it an acceptable approach in terms of food safety assurance?
If I understand the question properly, “you” here reflects a food processor recognizing that food packaging materials can pose a hazard to his/her product.
- Basic manufacturing management principles place responsibility for mitigating the hazard back with the packaging supplier. The food processor’s “supplier management” GMP procedures can require that they audit the suppliers and require verified corrective actions for identified deficiencies.
- In lieu of supplier audits and GMP programs, the frequency of hazards from packaging articles is higher. The food processor must add monitoring systems (e.g. metal detectors; container cleaning) in packaging operations, institute statistically valid sampling and testing efforts to assure packaging material safety and cleanliness, or other appropriate GMPs. The analytical ability to “reverse engineer” a packaging article to positively confirm its conformance with legal compositional requirements is difficult if not impossible. Contractual guarantee and/or indemnification from the supplier as part of purchase order conditions handles this best.