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Food Contact vs not for Fruit Packing

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heatherm

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Posted 05 May 2015 - 01:40 AM

My company makes equipment for the fruit-packing industry. A lot of the standard conveyor belt materials are not completely FDA or EN certified but our industry is late to the party. According to one belt supplier their belts, "are designed to be used in horticultural and agricultural applications for handling harvesting products prior to peeling and cooking, such as apples, kiwifruit, potatoes, onions, cabbages, carrots and other green leaf and other crops as well. In this respect they meet the FDA requirements for handling unpeeled and uncooked foodstuffs in the pre-processing stages and for the FDA requirements for fully packaged products."

 

By looking at the FDA and EN regulations, I could not find a distinction between an unpeeled apple and any other food product. Does anyone know how far we need to go in ensuring our food contact surfaces are certified?

 

Thanks for any help



xylough

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Posted 05 May 2015 - 07:49 AM

Hi heatherm,

 

Welcome to the forum. Let me begin by confessing I cannot place the "EN" regulation you reference; maybe spell it out and the many forum members may better aid you in your request.

 

With respect to FDA expectations for food contact substances used in food processing equipment, there are no less than 5 different ways to comply depending on the specific circumstances.

 

Rather than parroting the complex language for these paths to compliance I am providing 3 FDA links with their corresponding titles below each link. 

 

These should provide hours of exciting reading material, references, tables, additional links, regulations, etc., for understanding how to get where you want to be.

 

Please understand that the FDA does not certify food contact materials in the usual sense of providing a certificate for a given substance. They simply find you in compliance or not.

 

http://www.fda.gov/F...ial/default.htm

Determining the Regulatory Status of Components of a Food Contact Material

http://www.fda.gov/F...s/ucm115333.htm

List of Indirect Additives Used in Food Contact Substances

http://www.fda.gov/F...S/ucm064161.htm

Regulatory Report: FDA's Food Contact Substance Notification Program

 

Kind regards



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heatherm

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Posted 05 May 2015 - 08:12 PM

Hi, Thanks for your reply. I am thinking of EN1186, but a better reference is the EU regulation which specifies it (EU) No 10/2011:

http://eur-lex.europ...1R0010-20140324

 

I will have a look at those FDA links



heatherm

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Posted 05 May 2015 - 08:21 PM

I realise as well that I need to be more specific. For plastics as an example, for some materials I am able to get certs from the manufacturer that they meet (EU)No 10/2011 and US FDA code of Federal Regulations 21 CFR, part 177, paragraph 1520

 

The question is whether, for materials where we cannot get this certification (such as agricultural spec conveyor belts) we need to change materials and come into compliance with these regulations, or are we ok because we are dealing with, "harvesting products prior to peeling and cooking"



Charles.C

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Posted 05 May 2015 - 09:28 PM

I have not noticed any mention of  intended location of the usage of referenced equipment.?

 

This will probably define the majority of yr requirements.


Kind Regards,

 

Charles.C


heatherm

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Posted 05 May 2015 - 10:09 PM

Our equipment goes into fruit packhouses. We tip fruit out of bins, convey them, sort them, wash them, and put them pack into bins or pack them into bags or boxes.



Charles.C

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Posted 06 May 2015 - 06:45 AM

Our equipment goes into fruit packhouses. We tip fruit out of bins, convey them, sort them, wash them, and put them pack into bins or pack them into bags or boxes.

Hi Heather,

 

Apologies lack of clarity.

 

I meant geographical location, ie export to ? (or perhaps local supply only?). If the latter I suspect yr query may be answered but will require some local knowledge.


Kind Regards,

 

Charles.C




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