Heavy Metal Warranty

I have a current customer who requested a Heavy Metal Warranty statement as part of their supplier approval process.  We are a food packaging supplier currently working on SQF level 2 implementation, and I wasn't able to find anything on a Heavy Metal Warranty requirement in the SQF standard.  Some research led me to some information on declarations for the heavy metals cadmium and its compounds, hexavalent chromium compounts, lead and its compounds, and mercury and its compounds being below 100 ppm.  

I was able to obtain this information from our raw material suppliers and submitted the requested warranty, however they came back requesting we also include arsenic, barium, selenium, and silver.  So anyways, in asking for additional information from our customer on this request they provided an Sept/Oct 2014 AIB update document on evaluating and approving suppliers.

This AIB document states:

“Packaging material suppliers need to certify that heavy metals are not intentionally introduced to the materials and that the combined incidental level of heavy metals does not exceed 100 ppm.

Heavy metals to include in the warranty are: arsenic, barium, cadmium, hexavalent chromium, lead, mercury, selenium, and silver.  Heavy metals are typically associated with recycled packaging materials and some inks.

Food-contact packaging material includes nonfood items that directly touch food/beverage, including containers, caps, adhesives, labels, inks, dyes, corrugated, stabilizers, and coupons.  Glass jar suppliers do not need to provide a warranty since potentially present heavy metals are bound, and leaching to the product is unlikely.”

Does anyone have any experience with this type of request or requirement?  Am I missing this requirement from within the SQF standard or is it strictly and AIB requirement?

Thank you in advance for your help,

Neil

Dear pyro,

You're lucky it doesn't include the transuranics.

Unfortunately, or perhaps fortunately, i have never used AIB.

I can only surmise that yr unmentioned "Packaging" is rather "special". And/or the customer. And/or the customer's location.

Hopefully some packaging poster may recognize yr problem.

Rgds / Charles.C

Thanks for the response Charles, unfortunately however there isn't really anything unique about our packaging or the customer's application... we flexo print and convert labels as well as flexible plastic packaging.  As far as I am aware, SQF is considered a step up from AIB so I was a little shocked to see this was an AIB requirement. 

Anyways, I hope someone has some knowledge on this that they can share.

Regards,

Neil

I am rather surprised to see the AIB standard.  In the US, for plastic and paperboard generally speaking the requirements for testing are mechanical, flammable, heavy metals often called Toxics in Packaging, or CONEG.  Heavy metals tested is usually, Cadmium, Chromium VI, Lead and Mercury.  The EU tests for Chromium VI, Hafnium, Vanadium, Zirconium, Barium, Cobalt, Copper, Iron, Lithium, Manganese, and Zinc.   

I have not seen testing for arsenic, selenium, and silver. 

Dear pyro,

Is the "Sept/Oct 2014 AIB update document" linkable, postable or accessible.

Might assist further comments.

Is this a regulatory issue ? If so,  "Canada" normally supercedes  "All". :smile: (unless maybe it's for export, [or perhaps re-export]).

Rgds / Charles.C

PS - added - OK, i've found it -

ApprovingSuppliers.pdf   533.42KB   86 downloads

from a quick look, no mention of local regulations.

And no mention as to source of list (presumably USA[somewhere] from the surrounding text ?). >>> Question No.1 :biggrin:

Ah.... you found it and beat me posting Charles.  As you stated, there aren't any mention of sources or regulations in the document so I'm stumped as to where this requirement is coming from.  Everything else I've stumbled across only list the major heavy metals; this goes much further.

I'll keep digging and see what I can come up with and I'll keep this post updated.  Hopefully others will also have info to add.

Is your customer selling goods in California?

I know I have to ask for this for our food contact packaging as well as our ingredients - not because of national regulation or AIB, but because of Prop 65 & articles like this  -

http://www.asyousow....admium-in-food/

Our product has naturally occurring levels of some heavy metals, and in the state of California it is illegal to have any detectable level of these in your product with carrying a warning label.   Even levels lower than EPA harmful levels.

Obviously, chocolate makers don't want a label that says "MAY CAUSE CANCER" on their product, and it would be misleading to label it as such, because the levels are far below the harmful limits the EPA has set.  It doesn't really matter if your product is chocolate, or grain, or beer.  The list of prohibited chemicals is huge - roughly 1000.  

Neil, there is no way that is economically feasible for you to guarantee what they are asking. But you must answer anyway!

Here are the applicalble regulations taken from our letter:

 We hereby guarantee that our products are not adulterated or misbranded within the meaning of the Federal Food, Drug & Cosmetic Act, as amended, or any applicable regulations promulgated thereunder, or be an article that may not, under the provisions of Sections 404, 505, and 512 of the Act, be introduced into interstate commerce.

Our products meet CONEG, Toxics in Packaging Prevention Act, ASTM F963 and 16 CFR 1303 requirements for heavy metals content. They are not manufactured with any natural latex. They are not manufactured with PFOA or BPA.

Our products do not contain any substance listed pursuant to the California Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65) in an amount that would require a warning to buyer’s employees or others using the product.

I would suggest that you you go through your paper, ink and if applicable your adhesive supplier. Get them to supply you letters and from their responses make up your own.

This is where the term 'do not intentionally add' has all of its importance, it must be in your letter as you do not intentional add heavy metals to your labels. I was doing this for a long time for a paper mill and can assure you that it is not complicated. Your paper supplier will gladly help, your ink supplier will also, although if there is an issue it will be with the ink!  

Tamale

Thank you for the input and explanation Tamale!

Dear pyro,

For a possible explanation of the appearance of As,Ba,Se,Ag (et al?) I suggest you have a look at the example I attached here ** -

http://www.ifsqn.com...ing/#entry86377

Rgds / Charles.C

** PS - added - also see post  #12

Dear Pyro,

I had our largest customer request a similar statement of guarantee. It cites some particular USA legislation; the search term may help in your research. It became item number 20 in my request for documents to my packaging suppliers.

20. Statement/letter from your company officer regarding Restriction of Hazardous  Substances, specifically polybrominated biphenyl ethers (PBDE) and  polybrominated biphenyls (PBB), also addressing compliance with COALITION  OF NORTHEASTERN GOVERNORS legislation limiting lead, mercury,  cadmium and hexavalent chromium in packaging and packaging inks and  confirm that your plastics supplied to us do NOT contain Bisphenol-A often  used in clear polycarbonate and other plastic packaging.