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#26 Charles.C

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Posted 26 March 2007 - 09:24 PM

Dear Simon,

Trust you to stay on-topic.
(Don’t forget that my posts were primarily focused on the gum, didn’t include the label material)

Using the American viewpoint, assuming that Sankara wishes to know if his label adhesive is approved or not seems to require –

(a) Knowledge of adhesive composition and
(b) How it is used, eg direct or indirect contact and
© Checking if the components involved are in the appropriate approved FDA lists / approved sub-sections. As a shortcut the penultimate link of my previous post offers 2 lists with some further explanation but I am not 100% sure if these are totally comprehensive.( I guess you could ask the FDA directly if you wished to be really famous.)

(As example of complexity, here is a list of inter-related sub-sections -

• 170 Food additives
• 171 Food additive petitions
• 172 Food additives permitted for direct addition to food for human consumption
• 173 Secondary direct food additives permitted in food for human consumption
• 174 Indirect food additives: General
• 175 Indirect food additives: Adhesives and components of coatings
• 176 Indirect food additives: Paper and paperboard components
• 177 Indirect food additives: Polymers
• 178 Indirect food additives: Adjuvants, production aids, and sanitizers
• 179 Irradiation in the production, processing and handling of food
• 180 Food additives permitted in food or in contact with food on an interim basis pending additional study
• 181 Prior-sanctioned food ingredients
• 182 Substances generally recognized as safe
• 184 Direct food substances affirmed as generally recognized as safe
• 186 Indirect food substances affirmed as generally recognized as safe
• 189 Substances prohibited from use in human food)

Using the EU viewpoint seems to either involve the services of BfR (who have a somewhat different classification system) or the lists in the EU Directive(s). I haven’t ploughed through all the latter's details because of the number of possible Directives involved however I “think” the best assessment is via the data in 2002 /72 / EC Directive. Unfortunately, this is not “complete” as discussed in previous post so existing local regulations are still relevant as illustrated last link of my previous post. Hence the targeted Harmonisation.

Regretttably, I suspect the crucial step (a) above may not be so easy (does Sankara know what’s in the gum??) (and maybe for inks too ?– I remember trying to work my way through the specs of an ink used for a laser printer, included everything except its relevance with respect to food packaging safety).


Rgds / Charles.C


Edited by Charles.C, 26 March 2007 - 09:41 PM.

Kind Regards,

 

Charles.C


#27 Simon

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Posted 28 March 2007 - 08:17 PM

Dear Simon,

Trust you to stay on-topic.
(Don’t forget that my posts were primarily focused on the gum, didn’t include the label material)

Using the American viewpoint, assuming that Sankara wishes to know if his label adhesive is approved or not seems to require –

(a) Knowledge of adhesive composition and
(b) How it is used, eg direct or indirect contact and
© Checking if the components involved are in the appropriate approved FDA lists / approved sub-sections. As a shortcut the penultimate link of my previous post offers 2 lists with some further explanation but I am not 100% sure if these are totally comprehensive.( I guess you could ask the FDA directly if you wished to be really famous.)

(As example of complexity, here is a list of inter-related sub-sections -

• 170 Food additives
• 171 Food additive petitions
• 172 Food additives permitted for direct addition to food for human consumption
• 173 Secondary direct food additives permitted in food for human consumption
• 174 Indirect food additives: General
• 175 Indirect food additives: Adhesives and components of coatings
• 176 Indirect food additives: Paper and paperboard components
• 177 Indirect food additives: Polymers
• 178 Indirect food additives: Adjuvants, production aids, and sanitizers
• 179 Irradiation in the production, processing and handling of food
• 180 Food additives permitted in food or in contact with food on an interim basis pending additional study
• 181 Prior-sanctioned food ingredients
• 182 Substances generally recognized as safe
• 184 Direct food substances affirmed as generally recognized as safe
• 186 Indirect food substances affirmed as generally recognized as safe
• 189 Substances prohibited from use in human food)

Using the EU viewpoint seems to either involve the services of BfR (who have a somewhat different classification system) or the lists in the EU Directive(s). I haven’t ploughed through all the latter's details because of the number of possible Directives involved however I “think” the best assessment is via the data in 2002 /72 / EC Directive. Unfortunately, this is not “complete” as discussed in previous post so existing local regulations are still relevant as illustrated last link of my previous post. Hence the targeted Harmonisation.

Regretttably, I suspect the crucial step (a) above may not be so easy (does Sankara know what’s in the gum??) (and maybe for inks too ?– I remember trying to work my way through the specs of an ink used for a laser printer, included everything except its relevance with respect to food packaging safety).
Rgds / Charles.C

It really is a minefield; thanks for your sterling work and a great summary Charles. As the original question poster are you satisfied Sankara?

Simon

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