2 replies to this topic

[classic]

3.5.1.1. has had 'any risks associated  with raw materials which are subject to legislative control' added to the requirements.

 

Can anyone point me in the right direction as to where I can find a list of such materials.

 

Also as primary packaging is now classed as a raw material how does legislative control apply.  Migration risks have been already covered in my RA under the chemical contamination section.

 

Any help appreciated

 

Thanks

 

Classic

 

[pHruit]

Hi Classic,
There is further detail on how this should potentially be considered within the Guidance Notes document.

As you're in the UK I'm assuming this is for UK/EU market?

It will depend on the products to an extent, but as a guide for our raw materials we've started with 1881/2006 and 396/2005 for specific contaminants, plus 2073/2005 on micro. For meat etc you may also want to consider the limits for veterinary residues.

 

For the packaging the guidance mentions contamination, malicious intervention and inappropriate materials - depending on the type of packaging and the product/process some of these may not be applicable, so I'd just document that so it's covered if challenged at audit. Don't see any issue with including migration within chemical contamination, but again I'd spell it out clearly that you're considering the food-contact packaging and the regulatory side here (e.g. 10/2011 for plastics), as it's always easiest to deal with the more pedantic auditors if you can clearly spoon-feed them the answers that they need

[ilonar]

Hello Classic,

 

I think you have to start from the type of product you are producing and check what the legislative requirements are for them. I see that you are in the UK, so until the 29th of March you must comply with the EU legislation, after that depends on what the brexit deal will make compulsory for your sector. Besides this, you might have in UK extra legislation besides the EU one, with more complex requirements. It is also very important from where you get the raw material and where your final product is being sold. You might additionally have to comply with other legislation or have to make sure that your raw material imported from another continent will comply with EU legislation. We have a list with all the applicable legislation for our activities, so I assume that you might also have one and that you can pick out some risks from it.

 

What concerns the packaging material, you have to comply with the entire EU package of legislation,   https://ec.europa.eu.../legislation_en.  We are assessing the risk of migration from packaging materials in our HACCP study. All manufacturers of packaging material are providing us with declaration of conformity for food contact in which they mention that they comply with the above mentioned  legislations (what is applicable for them) and they also give results of migration tests performed on their products.