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Food Safety and Packaging: What Do CPGs Expect of Suppliers?

Denis Storey
March 18, 2021

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eBook: “The Importance of a Strong Supplier Approval Program”

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Food packaging serves many significant roles supporting the safety and quality of the foods we eat. It protects food from harm, provides valuable ingredient information, catches the customer's eye, warns of potential dangers (including common allergens), acts as a container for easy transport, and allows for traceability. Packaging can also alert consumers as to the freshness or possible contamination of a product.  

To ensure food packaging is safe for products, The U.S. Food and Drug Administration (FDA) regulates food contact materials as though they are potential food additives. Section 201(s) of the Act states: 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." 

Due to shared regulations, food manufacturers consider consumer-packaging as "ingredients" in the same way they view other ingredient manufacturers and hold them to the same safety standards.  

Expectations for Packaging Supplier Approval

Food companies conduct packaging supplier evaluations using surveys, risk assessments, and site audits involving third party, Global Food Safety Initiative (GFSI), internal, or other food safety certifications.   

Typical assessments include:

  • Current Good Manufacturing Practices (CGMPs), employee practices, and training

  • Hazard Analysis Critical Control Point (HACCP) / Food Safety Risk / Hazard Assessment

  • Controls to eliminate identified risks - Critical Control Points (CCPs) or prerequisites

  • Supply chain management and approval process for packaging suppliers

  • Raw material regulatory approvals

  • Chemical migration testing

Top Food Safety Related Issues Associated with Packaging

The most used common packaging materials in the food industry are plastics, glass, metals, wood, and their derivatives. No standard approach supports the numerous manufacturing processes required to produce food packaging across these materials. With such complexity involved in manufacturing processes, both food and CPG companies must work together to ensure both parties adhere to HACCP-based food safety standards for their respective manufacturing processes. 

Product recalls don't always occur due to a problem with the food product itself. Too often, a recall is associated with a misalignment of product packaging. The top three food safety-related issues associated with packaging are:

  • Undeclared/Unlabeled Allergens and Misbranding
  • Foreign Material Contamination
  • Chemical Migration

1 - Undeclared/Unlabeled Allergens and Misbranding

In a 2019 study, Food Safety Magazine identified package mislabeling of undeclared allergens as the top reason for product recalls. For the sixth year in a row, undeclared ingredients and allergens were responsible for the highest number of recalls in the United States. 

Some of the common reasons for undeclared allergens and ingredients 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 error

  • Incorrect label printing

  • Copy review errors

  • Prior print versions reappear

  • Printing changed or lost

The law requires correct labeling. Consumers with food allergies, especially those with severe allergic reactions, rely upon the accuracy of labels to keep them safe. 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 the potential for human error and use technology when possible

  • Learn from prior mistakes — yours and others, and share lessons learned between plants

2 - Foreign Material Contamination

Foreign Material Contamination is a leading issue with plastic and metal contaminants continually rank as the top two most commonly implicated foreign materials. Common reasons for foreign material contamination include:

  • Harvesters and other field equipment

  • Debris from processing machinery

  • Debris from equipment used during distribution 

  • Lack of employee oversight

  • Naturally occurring minerals which spontaneously form on foods 

Here are a few controls to help prevent foreign material contamination:

  • Foreign object risk management programs for suppliers

  • Clear procedures and proper training to verify incoming, storage, and internal movement of goods

  • Processing lines to include camera inspection systems, metal detectors, x-ray scanners, air jets or sieves

  • Monitor contaminations from the processing environment

  • Pest control programs

  • Precise maintenance and repair procedures

3 - Chemical Migration

Chemical migration is the transfer of chemical contaminants from food contact materials onto food. This underestimated source of chemical food contamination plays a significant role in product recalls, resulting in millions in lost revenue.  

For example, Del Monte Foods recalled more than 64,000 cases of corn in 2019 due to improper packaging sterilization leading to the potential contamination of organisms and pathogens that cause botulism. The recall impacted 25 states and required Del Monte to provide replacement items to retailers and consumers alike.    

Some of the common reasons for chemical migration from packaging can include any combination of:

  • Fat content

  • Temperature

  • Storage time

  • Surface to volume ratio

  • Contact time

Chemical migrations aren't always physical. In addition to film and ink-based chemical transference, odors can also transfer from packaging to foods. 

In 2010, Kellogg's cereal issued a recall because the inner lining for several products imparted 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.

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.)

For food manufacturers, the safety of finished goods is not only dependent on the ingredients themselves but also on the suppliers used along the food supply chain. Having a properly managed supplier program can help to ensure quality is met. Our eBook, "The Importance of a Strong Supplier Program" outlines what a strong program looks like and the steps to build your own.  Download it here.