5 replies to this topic

[MEM]

Hey all,

We manufacture plastic food packaging.  we are using recycled plastic in the process.  We have done a chemical migration test to show that using recycled plastic is acceptable.  Auditor is stating that I need to do this annually, but my argument is the materials haven't changed, so the test should remain valid.  If we changed the materials I could see it, but we are not.

 

Thoughts?

[kconf]

You just have to do it. 

 

I ask the same thing every year I have to renew vehicle registration and inspection. Same car, same driver, nothing changes. haha

 

Or even Driver's license for that matter  

Edited by kconf, 24 October 2024 - 07:21 PM.

[beautiophile]

Hey all,

We manufacture plastic food packaging.  we are using recycled plastic in the process.  We have done a chemical migration test to show that using recycled plastic is acceptable.  Auditor is stating that I need to do this annually, but my argument is the materials haven't changed, so the test should remain valid.  If we changed the materials I could see it, but we are not.

 

Thoughts?

 

The material names haven't changed

- FTFY -

However their compositions vary from batch to batch, especially because of fast changing waste sources for recycling. The older the last test is, the more outdated its information represents the current compositions, a.k.a. less confidence about its safety.

[kconf]

Material names - what if it is a single ingredient? Sugar will be C6H12O6 regardless of its source. How has the composition changed? 

[beautiophile]

Material names - what if it is a single ingredient? Sugar will be C6H12O6 regardless of its source. How has the composition changed? 

 

Purification process and final purity.

[Tony-C]

Hi MEM,

 

I would expect my food contact packaging suppliers to provide chemical migration certificates annually.

 

If you are using ‘recycled plastic’ how are you ensure this is consistent? If it isn’t or you don’t know then I would expect more frequent testing.

 

Besides the above chemical migration isn’t mentioned in the SQF Food Safety Code: Manufacture of Food Packaging, which clause did the auditor cite?

I presume that it was 2.3.2.6:

‘Raw and auxiliary packaging materials shall be verified to ensure food safety is not compromised and the material is fit for its intended purpose. Verification of raw and packaging materials’ conformance to food safety specifications shall include a letter of guarantee and a certificate of conformance, certificate of analysis, inspection, sampling, or testing.’

 

Kind regards,

 

Tony