Organic Compliant Drum Liners

Hi All,

I'm hoping someone can help me find plastic drum liners that are compliant for use in packaging bulk organic products. Specifically, they need to be B(2) below, free from synthetic fungicide, preservatives and/or fumigants.

§205.272   Commingling and contact with prohibited substance prevention practice standard.

(a) The handler of an organic handling operation must implement measures necessary to prevent the commingling of organic and nonorganic products and protect organic products from contact with prohibited substances.

(b) The following are prohibited for use in the handling of any organically produced agricultural product or ingredient labeled in accordance with subpart D of this part:

(1) Packaging materials, and storage containers, or bins that contain a synthetic fungicide, preservative, or fumigant;

(2) The use or reuse of any bag or container that has been in contact with any substance in such a manner as to compromise the organic integrity of any organically produced product or ingredient placed in those containers, unless such reusable bag or container has been thoroughly cleaned and poses no risk of contact of the organically produced product or ingredient with the substance used.

I've contacted several drum liner manufacturers on this. And while they can provide verification the bags are food safe, no one can give me verification of the above statement.

We manufacture Organic coffee and tea mixes and need 55 gallon bags to hold and move product from the blending to packaging areas.

Thanks in advance for any advice! 

Perhaps you can go back to a liner manufacturer and ask for a statement that they do not add any "synthetic fungicide, preservative, or fumigants" to the drum liners during the manufacture of them.

Thanks Ryan, I've tried this to no avail with several manufacturers. 

Anytime I try to look up "Organic Drum Liners", I get compostable ones, not what I need!

I will look around, but this may be a much more suitable option

https://www.google.c...550236843816797

Vmeg stainless steel bins with wheels  (not cheap but you never have to replace them)

I don't know if the company would spring for stainless steel....that is quite the expense.  Surely you can find FDA compliant hard plastic bins, drums, totes to use.  The caveat is they would have to be on a sanitation and inspection program.  But, you kind of need that anyhow even if drums are used as secondary containment beyond the liner.

What I've done in the past with some primary packaging suppliers is have a letter pre-written regarding the organic compliance and have the supplier sign off on the letter.  Do you think you can get someone to do this?

Ryan,

Thanks for the suggestion, it would probably be easier to just get a letter signed. 

Hi,

I'm a Quality Manager at a direct food contact packaging manufacturer. We produce many different types of packaging for different parts of the food industry. 

I agree with Ryan, to create a letter and have the manufacturer sign it. 

As the manufacturer and being certified under BRC, I've investigated our process and I do not see why no one can provide you that documentation you are requesting for.

My question would be, why would a packaging manufacturer of poly even have synthetic fungicide, preservatives and/or fumigants in their process for direct food contact, that doesn't make sense to me. 

Feel free and let me know if you have any questions about the process, and maybe I can help.

Good Luck,

DN

There is no "rule" from preventing the use of pesticides/fumigants within a building (following manufacturers recs of course) 

The issue from an organic standpoint is cross contamination..............so while no one should be using those during manufacturing.........perhaps the place where the plastic pellets were made is not the most sanitary and those pellets are carrying residue.........

The organic folks have a lot of extra's we have to deal with in order to maintain and the burden of proof is much higher

For instance............i had to find a detergent that was 

A) food safe approved

B) had performed biodegradability tests to prove there would be nothing left of that chemical after 30 days

C) not toxic to fish

I can assure you, that AFAIK none of the big guys are going to spend that kind of money to prove that about their cleaning chemicals

This is just an example of the extra hurdles organic manufacturers have to deal/comply with

Scampi is right, the hurdles for organic are difficult. I would imagine that eventually we might have certificates for packaging facilities, which would make it easier for the food facilities to be compliant. 

Thank you all for your thoughts!

Hi, 

Scampi is right from having a supplier that is not certified under a GFSI recognized scheme (i.e. SQF or BRC). 

Under BRC, I am required to assure my chemicals (Cleaning Chemicals) are separated from my process. I ensure this by auditing my facility once a month. Additionally, there are requirements on chemicals I use (can be found under BRC 4.8.3). 

I highly recommend that you find packaging manufacturers that are certified a GFSI scheme. 

I've also worked at facilities that I've certified organic, and found that as long as I have a detailed Supplier Approval program with my requirements, I can ensure this by auditing them frequently. 

Unfortunately, most of us don't have time for this, but to satisfy documentation, I would established clear guidelines that your supplier must abide by and have it signed.

Additionally, even have plastic resin pellets contaminated by a chemical residue, the process of extrusion would heat the product above 350^oF (dependent on the manufacturer's process). In this case, I looked into my SDS and the flash point of the approved chemicals. Also, any pesticides either have to be stored with a licensed PCO (Pest Control Operator) or in a contained area.  

I disagree larger companies do not look into this, because there is too much risk if we contaminate the finished product.   

I am only speaking for my company, but with experience at food companies in my past, I've had these situations but was able to find packaging manufacturers that meet these quality expectations we all go through. 

Hopefully this would bring some ideas for you to create for your packaging suppliers. Good luck again!

DN, thank you for the thoughts.

Is there a database you know of for certified packaging manufacturers? We receive liners right now through a large distributor and they are of no help in getting the information to me. 

Some certifying bodies have lists of companies they certify, others will not share anything (which defeats the point IMHO) , but I would start with your CB and organic association and go from there