Packaging materials are part of the food processors’ ingredient list, so it only makes sense that they should be treated the same as any substance when it comes to food safety. Whether you sell equipment, raw materials, converted packaging, services or just about anything else that supports the food industry, you need to have the mindset that at some point in the downstream supply chain, you are part of the food industry, and that food packaging should be treated with the same food safety rigor as food materials.
The FDA regulates food contact materials based on the premise that they are potential food additives, specifically in Section 201(s) of the Act:
A food additive is: “Any substance the intended use of which results in or may be reasonably expected to result … in its becoming a component of food.” Additionally, "Any substances which then become part of a food by being transferred from the packaging are considered “indirect food additives.”
You can conclude, then, that packaging materials are potential food additives and should be treated as such.
Typical Expectations for Packaging Supplier Approval
When determining a supplier for packaging purposes, many companies will utilize things like surveys and risks assessments, but many may also require site audits, which can be conducted by a 3rd party, GFSI, or other food safety certifications. Additionally, some companies may develop their own internal audits for new packaging suppliers.
Some of the other typical assessments for supplier approval may include:
- GMPs, employee practices, and training
- HACCP/Food Safety Risk/Hazard Assessment
- Controls in place to eliminate identified risks—CCPs or prerequisites
- Supply chain management/approval process for packaging suppliers
- Raw material regulatory approvals
- Chemical migration testing
Although numerous manufacturing processes are used in packaging, many user companies believe that one general standard fits all when it comes to implementing a food safety standard for packaging materials. This is not the case, however.
According to Food Safety Magazine, "there are 24 common manufacturing processes used in producing packaging materials. Six are used in the production of flexible plastics, three for rigid plastics, three for paper, 11 for metal containers and one for glass. Composite packages are based on the above processes."
With these types of complexities involved in the manufacturing process, it's important that both parties involved work together to ensure that packaging suppliers adhere to HACCP-based food safety standards based on their individual manufacturing processes.
Top Food Safety Related Issues Associated with Packaging
Food safety continues to constantly be in the news, especially with the rollout of the Food Safety Modernization Act (FSMA). But no one likes to see headlines that include food recalls, especially when it comes to your own company.
One of the major ways a recall indirectly impacts a company is with the loss of consumer confidence. This loss of confidence can be with the brand, the product category, the company itself, and/or the food industry as a whole. Additionally, other brands and other companies that are either in direct competition or are selling similar products can also feel the pain of a product recall.
Currently, one of the top culprits for food recalls comes from undeclared ingredients and allergens, and this can often times be directly linked to packaging.
Undeclared/Unlabeled Allergens and Misbranding
As mentioned above, undeclared ingredients and allergens were responsible for the greatest number of recalls in the U.S. in 2013, and continue to be high on the recall list, causing significant consumer health issues, scrap costs, and sourcing conundrums.
What are some of the common reasons for undeclared allergens and ingredients? These can include:
- Wrong food or wrong package
- Mixed labeled packaging materials – packaging supplier or food plant errors (e.g., labels, cartons, film, lids, cups, etc.)
- Human errors
- Incorrect label printing
- Copy review errors
- Prior print versions reappear
- Printing changed or lost
Correct labeling is the law, and if consumers have a food allergy, especially a sever allergic reaction to an allergen, these labels need to be accurate. For example, a mother with children who suffer from food allergens will check the label when she purchases something, when she puts it away, and when she feeds it to her children. The labels need to be correct, as these allergies can be life-threatening. Proactive packaging suppliers help to prevent mixed labeling.
A few controls to help prevent mislabeling include:
- Implementation of strict controls at points where human error could occur
- Changeover/Line Clearance checklists utilized
- Print copy reviews
- Electronic Visions Systems used to supplement the human eye
- Rework controls implemented
- Consistent employee training and reinforcement
- Joint responsibility between the packaging supplier and the food plant
- Have sound quality management systems in place
- Conduct risk analysis with packaging – "What could happen if…"
- Controls to prevent incidents are in place
- Secondary checks/controls are also in place to:
- Prevent potential for human error
- Use of technology when you can
- Learn from prior mistakes—yours and others
- Share and learn from mistakes from plant to plant
Chemical migration doesn’t have nearly as many recalls as undeclared allergens and misbranding, but it does and has played a role in a few major recalls, which result in large amounts of product being recalled and thousands, if not millions, in lost revenue. Some of the issues with chemical migration include:
- Migration into products (e.g., film, pallets, ink, etc.)
- Perceived food safety issues (odors and tastes)
- Social media now plays a large role in perceived risks (think BPA in cans)
For example, Kellogg's cereal was recalled in 2010 because the inner lining for a number of products was imparting a bad taste and odor to the food, which had also been associated with nausea and vomiting in some consumers. The source was later identified as higher than normal levels of a chemical (2-Methyl Naphthalene) in the liners. The company was forced to recall roughly 28 million boxes of tainted cereal, which consequently cost the food giant millions of dollars.
Another example comes with Johnson & Johnson’s 2010 recall of over 60 million bottles of Tylenol due to a musty odor that was caused by trace amounts of a chemical formed as a by-product of mold growth on high-moisture wooden pallets. Again, this resulted in a loss of consumer confidence in the brand and millions in revenue.
A few controls to help prevent potential chemical migration include:
- Have supplier approval programs (resin and other materials)
- Letters of guarantee/Certificates of Conformance
- Chemical migration testing
- Audits of incoming materials
- Consider the end use of the packages and the foreseeable use (e.g., direct product contact, microwave, hot fill, pH of the food, etc.)
At the end of the day, food safety is everyone's responsibility and we should all be doing our best to not only protect consumers and eliminate recalls, but also provide consumers with the best quality products possible.
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