Dear Phil,
Very interesting item.
This is clearly a highly pragmatic approach although I was a bit dubious over the basic concept since it seems to hinder the general distribution of knowledge plus it may give problems at export destination, eg –
“Q10. Does the CFIA maintain a public listing of ingredients/components which are permitted to be present in non-food chemical products used in federally registered food establishments?
A10. No. Each formulated product’s list of ingredients/components is evaluated on an individual basis according to its intended use. Only a list of accepted formulated products is maintained by the CFIA.”
However this reservation seems to be offset by the CFIA general labelling requirement for non-food chemicals–
“Q11. What information is required to be included on the label of non-food chemical products? A11. Every label shall show the following basic information:
Name and address of manufacturing or distributing firm. The address may be that of the head office of the firm;
Descriptive name of the product. This is required to be displayed prominently and immediately adjacent to the brand name, to denote the function. A statement on the specific intended use in food establishments must also be included;
A list of all major ingredients. Should there be a list of active ingredients on the label and major ingredients of product are considered to be non-active, a second list with these major ingredients should be included on the label;
Direction for use in a food plant, to include any precautionary statements necessary to avoid contamination of food such as "Rinse with potable water", including all necessary information to achieve its technical effect;
A net content statement;
Where applicable, the words "Product of...." indicating the country of origin. This statement shall be placed below the descriptive name of the product.
Q12. Which non-food chemical products require a label?
A12. The following non-food chemical products are required to be labelled: barrier creams, cleaners, decharacterizing agents, denaturing agents, deodorizers, disinfectants, egg treatment compounds, inks, lubricants, maintenance aid products, microbial control agents, pesticides, processing aids, refrigerants/heat exchanger agents, release agents, sanitizers and water treatment compounds.”
I presume approval of the label is part of the requirement for a product to be approved in the first place
I believe (?) this requirement is unusually comprehensive (and to be applauded!) unless the word “ingredient” is allowed to be interpreted in a generic fashion, eg "contains an approved colouring”.
BTW, I noticed that “Packaging Materials / Coatings / Adhesives do not seem to appear in the A12 list (unless classified as a processing aid [unlikely I think]) although there are hundreds in the database ?
Rgds / Charles.C