Migration and any other testing for bottle manufacturer
Hello all: I'm starting in a new role for quality for a blown molding of PET bottles for food contact (we use the bottles for pills and capsules which we are qualified as only food contact), I have so many question since all of this process is brand new to me, first of all, I'm trying to create a form for vendor approval, pretty standard nothing out of the ordinary but now I'm confronted with the migration testing topic, and here is where the questions starts:
I see a lot about this migration testing but it seems more like is applied to certain liquid contents (alcohol, olive oil, acetone, etc), does this type of testing applies for our type of product and its intended use? (Pills and capsules)
Should be requested as part of our vendor approval questionnaire? we are currently receiving COC and letters of guarantee and as part of it a declaration that is food grade and approved by FDA and audited by ISO, none of our clients had asked for migration testing so far.
Please let me know your thoughts on this, it would be greatly appreciated.
Brenda
Migration testing is a tricky one, mainly because I believe people (auditors, etc.) are aware of it and think they know about it, but they don't. During one of my audits while being in packaging the auditor called out on our HACCP Plan how we do not include migration as a risk for our raw material. I explained to him that there was no risk as with the type of packaging we did, there was no migration of chemicals if our customer used the film in the correct application as intended. The only risk came with the inks, which were imbedded in between layers so the risk was minimal. (We did have the inks called out as a risk on the HACCP Plan) The auditor fought back and still gave us minor NC. Rather that arguing with the CB on it, I added it to the HACCP Plan and wrote out why we felt there was no risk.
Anyway, work with your raw material suppliers on this. If they are not testing for it, they would have a good reason why and then you can document that. Most structures out there, PET, OPP, etc. there is no real adherent risk of chemical migration, the risk comes from a customer and their intended application. It is then up to your company to inform your customer what your product is good for and if they (the customer) wish to use it for something outside your recommended intended use, I would inform them it is up to them to perform the testing in order to make sure it is safe and offer to at least work with them to build up a good relationship.
As far as what I have normally asked for while working in Packaging from suppliers, the standard : LOG, 3rd party audit certificate, COA or COC, Supplier name and address, specifications/TDS for material being supplied and contact person. I have also asked for an Allergen Statement, CONEG Certification, Country of Origin and SDS. I also send out a Questionnaire for new suppliers and every 3 years for approved suppliers to get a better idea of their programs and policies. Hope this helps answer your question and please note I only have experience in flexible packaging.
I see a lot about this migration testing but it seems more like is applied to certain liquid contents (alcohol, olive oil, acetone, etc), does this type of testing applies for our type of product and its intended use? (Pills and capsules)
This doc might be old but hopefully it's still helpful for you.
https://www.pac.gr/b...august-2015.pdf
TLDR: There is a simulant (and method) for migration test according to food type.