Migration Test for Paper Towels

Good day!

I am from an RTE manufacturing facility. Currently, we are using paper towel to wipe excess water from our fish products (fish loins for further cutting into smaller slices such as sushi, sashimi etc.). We also use nitrile gloves in handling our products (sushi). 

We only conduct microbial test as verification for the suitability of the paper towel and nitrile gloves to be used in direct contact with our products. 

Do we need to conduct migration test for these two materials?

Currently, we only conduct migration test for our primary packaging materials.

Can you help me cite relevant regulations for this?  Thank you in advance for your knowledge and help.  

Hello, 

My first thought is that testing the other two materials wouldn't be necessary. Mainly because I don't think paper towel is made with any harmful substances that could hurt you even if you ate it. I'm not so sure about the gloves but I imagine that migration would only occur if the gloves were left to sit directly on the fish for a period of time, long enough for any kind of substance to leak out of the gloves.