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Jack
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How do you evaluate the food safety risks of packaging innovation (e.g. compostable, recycled, or multi-layer materials)?
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How do you evaluate the food safety risks of packaging innovation (e.g. compostable, recycled, or multi-layer materials)?
Cathy Gladwin
Administrator
Staff member
Hi @Jack - this is a good question. Right now I'm spending hard and frustrating hours and hours searching our packaging for our new manufacturing site, to launch brand new products and I have pretty high standards in terms of searching out packaging. I don't want plastic but where leakage or protection from humidity is an issue, what do I do? Right now, glass jars are my solution - completely recycleable, completely safe from migration and leaching of chemicals associated with plastics (even paper products laminated with plastics - which is the same concern for cans) and free of aluminium which has it's own risks and environmental concerns in terms of recycling.
Yes I am using this post to look for a bit of sympathy and have a bit of a moan! But until I took on this NPD work, honestly, I had no idea of the frustration and time it takes to find the right solution, with the right MOQ, at the right price and lead times!
OK, back to the actual question. It's a big one, because you mention "food safety" risks. So we realise that the driving force is environmental concerns but also practical economical costs that make us consider the options in the first place, but at the same time, we must document all the risks related to the food safety at the end of the day. So I was looking at "compostable pouches" as an example of this. all plastic carries a risk of leachables / extractables, and typically the softer the plastic, the higher the risk. If we're talking about storage, then temperatures are not much of a concern if we assume that the product is stored ambient or chilled or frozen, but heat isn't an issue unless 1. storage conditions are abused, or 2. the product is intended to be cooked in the packaging or heated in, for example cook in bags/tubs/trays. Plastic processing equipment is a different story again.
Whatever we choose as our packaging, we have to get assurances from the supplier and this will specifically involve 1. the Food contact declaration of conformity - referencing applicable legislation such as Commission Regulation (EU) 2020/1245 of 2 September 2020 amending and correcting Regulation (EU) No 10/2011 on plastic materials and articles intended to come into contact with food, and 2. get the specification showing exactly the limitations (if this info isn't already in the declaration) of how the packaging should be used. During my time auditing sites, I've seen the technical spec being filed but not read, and the packaging has been used in conditions exceeding the limitations specified. This completely invalidates the food safety assurances we've worked so hard to obtain.
Once all details are checked, document the risks and those assurances to mitigate the risks in the relevant risk assessments (HACCP being the most top level one, and then raw material and packaging risk assessments, being more detailed and specific to each supplier).
One more comment on recycled content, we know the industry is being pushed to include more recycled content in packaging and there's always the concern that recycled materials are less safe because of the risk of contamination. However, this is really not the case. The recycling process itself is usually so agressive (such as washing and thermal processing) that the resulting material is free of contamination that can pose a risk - certainly from a microbial point of view if not a chemical one. In addition, the recycling process should be validated, and this will give the supplier the assurances that they are then confident to make in their technical specifications and declarations of conformity for the relevant food storage application.
All we need to do is think of all relevant risks, document them and get the documented evidence that they have been mitigated (and don't forget to apply this thinking to the full shelf life of the products as well as any extention that might be applied ot the shelf life such as by freezing the product).
Yes I am using this post to look for a bit of sympathy and have a bit of a moan! But until I took on this NPD work, honestly, I had no idea of the frustration and time it takes to find the right solution, with the right MOQ, at the right price and lead times!
OK, back to the actual question. It's a big one, because you mention "food safety" risks. So we realise that the driving force is environmental concerns but also practical economical costs that make us consider the options in the first place, but at the same time, we must document all the risks related to the food safety at the end of the day. So I was looking at "compostable pouches" as an example of this. all plastic carries a risk of leachables / extractables, and typically the softer the plastic, the higher the risk. If we're talking about storage, then temperatures are not much of a concern if we assume that the product is stored ambient or chilled or frozen, but heat isn't an issue unless 1. storage conditions are abused, or 2. the product is intended to be cooked in the packaging or heated in, for example cook in bags/tubs/trays. Plastic processing equipment is a different story again.
Whatever we choose as our packaging, we have to get assurances from the supplier and this will specifically involve 1. the Food contact declaration of conformity - referencing applicable legislation such as Commission Regulation (EU) 2020/1245 of 2 September 2020 amending and correcting Regulation (EU) No 10/2011 on plastic materials and articles intended to come into contact with food, and 2. get the specification showing exactly the limitations (if this info isn't already in the declaration) of how the packaging should be used. During my time auditing sites, I've seen the technical spec being filed but not read, and the packaging has been used in conditions exceeding the limitations specified. This completely invalidates the food safety assurances we've worked so hard to obtain.
Once all details are checked, document the risks and those assurances to mitigate the risks in the relevant risk assessments (HACCP being the most top level one, and then raw material and packaging risk assessments, being more detailed and specific to each supplier).
One more comment on recycled content, we know the industry is being pushed to include more recycled content in packaging and there's always the concern that recycled materials are less safe because of the risk of contamination. However, this is really not the case. The recycling process itself is usually so agressive (such as washing and thermal processing) that the resulting material is free of contamination that can pose a risk - certainly from a microbial point of view if not a chemical one. In addition, the recycling process should be validated, and this will give the supplier the assurances that they are then confident to make in their technical specifications and declarations of conformity for the relevant food storage application.
All we need to do is think of all relevant risks, document them and get the documented evidence that they have been mitigated (and don't forget to apply this thinking to the full shelf life of the products as well as any extention that might be applied ot the shelf life such as by freezing the product).