5.1.1 - Migration & Studies

Afternoon All,

is anyone certified under BRC Packaging Issue 5, doing migration studies on their finished product? 

I'm having an issue doing these test because i have different end users utilizing my products.   

Any thoughts on how I should approach section 5.1.1 - Adding/identify testing requirements (including migration) per the GAP Analysis?

thanks,

DNQMGR

Hi, you would need a competent lab to conduct the migration testing and they would also help you to establish the range of testing required so that it covered all possible types of products and end uses of your customers.  

For example some customers may have acidic products, others oily, some may hot fill, some may cold fill and cook or pasteurize.  First you need to gather information and understand your current customers products and processes and then work with the lab for what may reasonable be expected to occur.  

Once complete whenever you get a new customer or existing customer with a new product you can ask them about their product and processes and specify the most suitable product from your portfolio based on the usual criteria such as price, functionality, aesthetics etc. plus what is best from a migration point of view.  

If a customer comes along and say's I'm hot filling at 100C and boiling for an hour and this is outside what you have tested for then you tell the customer what the material is tested to and tell them they need to conduct their own end product testing.

You need a competent lab that specializes in migration testing.

Hope this helps.

By the way if you have a lot of products it can become costly.  Oh and you must ensure that you are not introducing any chemical contamination during your manufacturing process such as inks, processing aids, cleaning chemicals etc.

Regards,

Simon

Yes we do test, however not specifically for BRC Packaging Issue 5 but to comply with European food contact packaging legislation. The legislation, which includes information on testing regimens, allows us to make statements either based on calculation using supplier generated data or on actual migration tests. We have chosen to do both with the consent of the competent authorities and to the satisfaction of our BRC auditors.

We have about 11,000 different bespoke products going to 1000 customers each of whom have different applications and in many cases multiple applications. Since the base materials are similar across all the products we primarily base migration compliance on calculated information, but test representative samples on a triennial basis to confirm compliance. Due to the broad range of possible appilcations and as we have no control over how or where our customers will use our products we carry out overall migration tests that cover the majority of applications and then detail the limits in our Declarations of Compliance. For customers who then require compliance outside this standard range, which typically means the application is questionable, any testing is done at their expense. 

Simon,

Thank you for answering! 

Batchoy,

Thank you for your thorough description of what your company has accomplished with migration test.

We are BRC and with the new issue 5,  I'm trying to wrap my arms around away to have an inexpensive test.

We've been using a migration study from about 8 years ago and so much has changed in legislation and technology of extruding poly. 

I just have to sit down with my team and at least attempt to run migration test on a liquid and solid type products. 

thanks again and have a great day!

DNQAMGR

Hi Simon or anyone, 

Do you have any competent labs that you would recommend to test for Migration (Overall Migration Limits or Specific Migration Limits) in the United States? 

I've reached out several times to INTERTEK and can not seem to get any quotes or even followup. Any recommendations? 

thanks,

DNQAMGR

We have the material tested for overall migration only. The test conditions used allow us to cover the majority of customers' products (e.g. bakery, fish).

We use Smithers PIRA in the UK and it appears they do have some presence also in the US. May be worth doing a search to find out their specific capabilities.

The legislation in the EU makes it pretty difficult to get away without doing migration testing.  However, in the US if you can suitably argue that you are posing no risks (i.e. all of our raw materials are FDA approved, etc.) then you can avoid the expensive testing.