Letter of Continuing Guarantee Help

Good morning,

Just a short background: i started working at a packaging manufacturer company 2 months ago as a Quality Control/Compliance Manager. I am new to this industry, but in the short amount of time, I have got a lot done. Back in 2016, someone created a "General" letter of continuing Guarantee for our company. Since this is 2019, I'd like to update it. Any input would be greatly appreciated. Our company manufactures plastic for food, pillows, etc.  I copied and pasted what we currently use (I took out my companies name for privacy)

A GENERAL AND CONTINUING GUARANTEE

(OUR COMPANY). certifies that all of the products that our company supplies are in compliance with FDA regulations under Code 21 CFR 177.1350, 177.1520, 188.24, 178.2010, and 175.105 and the Coalition of Northeast Governors (Coneg) and California Proposition 65. Our films do not contain synthetic fungicides, preservatives or fumigants and as such are suitable for Organic Certification.  

No additional substances such as heavy metals (i.e., antimony, arsenic, barium, cadmium, chromium, lead, mercury, selenium, or silver) are intentionally added to the polyethylene resins or films.

Accordingly, all of our materials are approved for use in non-alcoholic food packaging and food contact including use in articles used for packing and holding food during cooking. Our materials are also free from any kinds of odors and are safe for all packaging applications.

Additionally, all our films are proudly made here in the U.S.A.

(COMPANY) certifies that our films are not formulated with compounds such as bisphenol A, octyl and nonyl phenols and their ethoxylates, butyl benzyl phthalates, dibutyl phthalates and diethyl hexyl phthalates which have been linked to affecting endocrine. 

Looking at other letters of guarantees from our packaging providers - I would add an allergen statement in there as well.

Chemical migration statement? (that could be separate from your letter of guarantee, though)

Add allergen statement and take out the marketing slug - Additionally, all our films are proudly made here in the U.S.A.

Hi Glenn,

Our company does not package any food here, we have an allergen control program though, this is what it says:

(OUR COMPANY)is a manufacturer and distributor of various types of packaging products; and we are under the regulatory control of the FDA.  (OUR COMPANY)  does not manufacture any products containing any of the big 8 allergen types.

Employee foods is our only mean for allergen cross-contamination. Therefore, we have provided a lunch room equipped with refrigerators and annual allergen awareness training to all employees in order to prevent any cross-contamination from foods brought into the facility.

All non-food grade materials are used under (never above) the food contact surfaces and are located separately from the food grade materials. All bottles are properly labeled. Any spills involving allergenic foods or non-food grade materials are cleaned up immediately by a designated employee with designated cleaning tools.

Would it be too wordy if I add all of that in my letter?

Clean up the language and address advantages, but I would only add elements where there is a compelling reason to do so, or a customer has asked for it.

Not too wordy for a Letter of Continuing Guarantee.

I would also clean up the statements (as previously suggested), get rid of the advertising language and add the allergen portion (also previously suggested) to your LOCG with the "big 8" allergens listed (we include 11) and a section specifically outlining the measures to keep them separate. "Lunchroom facilities are separated from manufacturing and our GMP & Food Safety policy and procedures allow no foods in production areas at any time."

We also add hand washing specifically as a preventive measure to control allergens.

I think that should cover everything you need, the length shouldn't be an issue, the important thing is to include everything your customers require also and make the LOCG as succinct as possible.

For the allergen statement I would just say as you had it above - Our company does not manufacture any products containing any of the big 8 allergen types.

A "our films are made in the USA" could function as a country of origin statement.

I would add a statement about Condition of Use such as "room temperature or below".

3560lynne: what do you mean by a chemical migration statement.  Stating FDA compliance implies no harmful chemical migration per FDA regulations.  To determine chemical migration, you would likely have to do testing.  The FDA does not require chemical migration tests.

We have a statement saying as much, that's all.

  ...raw materials used to formulate food packaging products are cleared for food contact applications by US-FDA regulations and meet the required extraction specifications, no additional migration testing is required.