Product Analysis on Migration - BRC Packaging

Hi
I am Charmeen from Mauritius and work as quality Assistant in a food packing plant. We are already BRC certified for food and now are looking towards Packaging. membership to this forum has proved very useful through sharing of ideas and points of view and i have benefited loads from it. i am now working on Packaging.

We use flexible film packaging which we received flat and printed. It is formed then formed in to bags before filling. In BRC, Clause 4.13 of product Analysis, quote: " a company is required to undertake analyses...." is it mandatory to perform SML test on the packaging used or can Supplier recommendation be used. And if analyses have to be performed, who/where/to whom do i turn to?

Your feedback is highly appreciated.

Hi I am Charmeen from Mauritius and work as quality Assistant in a food packing plant. We are already BRC certified for food and now are looking towards Packaging. membership to this forum has proved very useful through sharing of ideas and points of view and i have benefited loads from it. i am now working on Packaging.

Hi Charmeen, I'm glad you are finding the forums useful. Thank you for the feedback.

We use flexible film packaging which we received flat and printed. It is formed then formed in to bags before filling. In BRC, Clause 4.13 of product Analysis, quote: " a company is required to undertake analyses...." is it mandatory to perform SML test on the packaging used or can Supplier recommendation be used. And if analyses have to be performed, who/where/to whom do i turn to?

Can you just confirm are you talking about Migration Testing?

Thanks,
Simon

Yes indeed, Migration Testing and limits for OPP packaging.

We use flexible film packaging which we received flat and printed. It is formed then formed in to bags before filling. In BRC, Clause 4.13 of product Analysis, quote: " a company is required to undertake analyses...." is it mandatory to perform SML test on the packaging used or can Supplier recommendation be used. And if analyses have to be performed, who/where/to whom do i turn to?

Yes indeed, Migration Testing and limits for OPP packaging.

I had an interesting conversation last week on this very subject with a Group Quality Manager for a very large UK dairy.

We both agreed that it was the manufacturer of the packaging that was responsible for ensuring that the material met all legal requirements (including SML) for food contact packaging. What we could not agree on was how often this migration testing should be carried out by the supplier.

The packaging manufacturer may say they carry out the migration testing once when the packaging / food contact coating is first developed and is only carried out again if there is a change to the specification or if the law changes. The end customer e.g. a big retailer may require migration testing to be carried out annually; auditors from retailers like to specify 'annually' as it’s a nice neat frequency for all sorts of testing / reviews etc.

I would side with the packaging manufacturer. Imagine a food packaging film with a heat seal coating that was developed 10 years ago. It met all of the migration limits then and was approved for use with food. So if nothing changes to the specification why the need to test again. 10 years may seem like a long time. But if we just want a shorter testing frequency because 10 years doesn’t seem right. Why not carry out migration testing of every batch?

Our conclusion was we were not sure of the frequency, but if the big retailer auditor wanted annually we would have the debate and then do it. :)

In answer to your question Charmeen; your packaging supplier must provide you with the certificates and migration test results for the material they supply to you. And the packaging material and supporting documents must be able to meet the migration limits laid own in the relevant legislation of the country(s) you supply your products to.

Hope this helps.

Regards,
Simon

Dear Charmeen,

I daresay you have already searched this forum but just in case, these threads have some relevance to yr query -

http://www.ifsqn.com...astic migration

http://www.ifsqn.com...t...ation&st=30

http://www.bag.admin...ex.html?lang=en

Rgds / Charles.C

Hello Charmeen,
This is a big subject to provide a simple answer.

We deal with a lot of regulations around the world and the onus is on the food manufacturer to ensure their food is safe and does not exceed any SML limits as set by various country regulations (USFDA CFR21. EU, Japan, Chinese, Australia/NZ etc), or contained banned substances.

I would suggest that your packaging vendor is suppose to have all the food safety compliance information and conduct the SMLs etc, but they may not have these available or understand the requirements for your products.

If you cannot put sufficient resources in place at your company, make contact with PIRA in the UK, as they are very good at this stuff and can provide all the advice and test facilites either directly to yourselves or to your packaging vendor. Have a look at the PIRA web site for more information and key people to contact: http://www.smithersp...compliance.aspx

Cheers
Peter

Dear Peter ,

Thks for yr link. The website you linked has interesting and readable content although, from a quick look, their info. policy is somewhat annoying / disappointing, eg most (seemingly) external links are internally recycled only, the latest info. displayed (and one download I sampled) appears to be ca. 2006. I did eventually find one genuine EC reg. link at the bottom of a page which seemed current so i suppose this format is a commercial manouevre.

Regardless, the input is appreciated, thks again.

Rgds / Charles.C

PS - Of course, as I'm sure you are aware, a lot of professional advisory help is also available from the current location.

PPS @ Charmeen - Thks for the OP in 2007, hope you are still following the forum.