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BRC - Packaging, High Hygiene

BRC Packaging High Hygiene migration testing formulation review customer letter

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#1 CartonQM

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Posted 15 May 2019 - 05:41 PM

Hi Everyone,

 

We are a paperboard packaging company that is working towards the BRC registraton for High Hygiene packaging. Most of our food manufacturing customers are indirect/secondary contact with a very few that are direct/primary contact. We are stuck on a few items:

 

1. We have looked into formulation reviews (a certain cost per item per supplier) and migration testing.  Did you do one, the other or both and why?   If you did migration testing did you do the harshest test?  We are located in Ontario, Canada, and are there any testing companies that you recommend? 

 

2. We are trying to develop a form letter to give to existing/potential customers that will cover: discouraging the use of UV inks/coating, recommended no inside printing, and using a functional barrier.  The inks/coatings we use are not food grade.  Has anyone created something like this?  Did you involve a lawyer for any liability issues?  A lot of education from us to our smaller customers seems to be the norm and we wanted to make sure we are covering all the info needed when it comes to Food Safety. 

 

We have info from our material suppliers regarding heavy metals (CONEG), EU regulations, Prop 65, Directive 94/62/EC, etc. so that part seems to be okay.

 

Thanks in advance!



#2 beautiophile

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Posted 16 May 2019 - 01:51 AM

First to say, I don't work with paper materials and just want to share my small knowledge.

1. I don't know about Canada, but the EU requires the migration test as a fundamental criterion. Scientifically, it is to assure that no "harmful" chemicals (inks, excessive raw ingredients, additives, etc.) diffuse to the food through the interface, during the shelf-life. You can look at EU Resolution ResAP (2002) for information. 

2. Again with EU guideline Resolution ResAP (2005)2, 'cuz I have to deal with European customers. Bear in mind that, your inks/coats must comply the safety for "unintended direct food contact". Just in case people unpack your paperboard and use it as a dish.



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#3 CartonQM

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Posted 17 May 2019 - 05:28 PM

Thank you!



#4 Hoosiersmoker

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Posted 21 May 2019 - 03:35 PM

Food grade paper, ink and aqueous coating technology is such that you should really look at changing everything over as soon as possible. Many of your issues would be eliminated if you did. We are a food contact packaging manufacturer and have been using all food grade products for over a decade. This will become more and more of issue as time goes on, better to be ahead of it if possible.



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#5 dgt39

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Posted 22 May 2019 - 08:27 AM

We manufacture cartonboard direct contact food packaging. Suggest you change to 'Low migration' inks and coatings and use cartonboard approved for contact with the type of food being packed (dry, greasy, fatty, wet).

Providing you employ Good Manufacturing Practice there should be no issues. We encourage our customers (the food manufacturer / packer) to carry out migration testing where their risk assessment indicates a need. It would be cost prohibitive for us to carry out migration testing for all the different products we produce and feel it is more focused and relative for the end process (packer / filler) to do this. Interested in your 'discouraging the use of UV inks/coating'. Providing lamps and cure are checked regularly (part of GMP) and the UV inks and coating are 'low migration then they can be used.



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#6 CartonQM

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Posted 23 May 2019 - 06:06 PM

Thank you, Hoosiersmoker and dgt39.  Some valuable comments.



#7 Hoosiersmoker

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Posted 23 May 2019 - 06:19 PM

It might also be important to relate that our suppliers perform the migration testing on the materials they provide to ensure adequacy for their purpose.







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