Appropriate Standards for Food Packaging Adhesive Manufacture

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Bulksupplier

Please can someone advise me on what standards should be applied when manufacturing adhesives for food packaging?

I guess most of the regulatory compliance burdon falls on the packaging manufacturers (our customers), but I want to make sure we have taken all necessary measures to minimise the risks of contamination.

I have purchased a copy of the BRC Global Standard to Packaging and Packaging Materials, but this doesn't address manufacture of chemicals very well.

Specifically, we have a production unit that is mainly used to manufacture industrial products using some raw materials and intermediates which are definitely not food 'safe'. It is not practical to clean the plant between products. The best we can do is flush and drain and then test the 'food grade' product for possible contaminants. Is this strategy likely to be acceptable, or do we need to build a separate unit dedicated to food-grade products?

Many thanks for any help people can give me on this one.
 

harry

Trusted Information Resource
1. Will it be in contact or not in contact with the food packed?

2. As a minimum, GMP/HACCP will come into play - one of the requirements is prevention of contamination. How can you satisfied this if you choose not to wash your machine properly/thoroughly?
 
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Bulksupplier

Thanks harry,

The reason we choose not to wash the plant is because the product reacts with water to form solids, which would have to be dug out with jack hammers! We could use a solvent instead of water, but this would create a greater risk as a contaminant and would also create an effluent stream for disposal.

The adhesive is not intended to come into contact with the food, but can migrate to some extent through the packaging film, especially if not fully cured.

Which version of HACCP/GMP should we follow?
 

Ajit Basrur

Leader
Admin
Thanks harry,

The reason we choose not to wash the plant is because the product reacts with water to form solids, which would have to be dug out with jack hammers! We could use a solvent instead of water, but this would create a greater risk as a contaminant and would also create an effluent stream for disposal.

The adhesive is not intended to come into contact with the food, but can migrate to some extent through the packaging film, especially if not fully cured.

Which version of HACCP/GMP should we follow?

I would recommend you to refer 21 CFR Part 175.105 - Adhesives from the FDA.
 

harry

Trusted Information Resource
........................ Which version of HACCP/GMP should we follow?

The BRC standard you mentioned earlier has its roots in HACCP. Also there's the well known Dutch HACCP. Except for some minor differences here and there, all haccp programs are practically the same. By definition:

Hazard Analysis Critical Control Point (HACCP) is a systematic preventive approach to food safety and pharmaceutical safety that addresses physical, chemical, and biological hazards as a means of prevention rather than finished product inspection.

In your case, it is a chemical hazard and you had to addressed it by having acceptable controls. Is there no way for you to have a dedicated machine/equipment?
 
B

Bulksupplier

Thanks Harry,

Installing dedicated equipment is a question of payback on the considerable investment required. Margins are relatively good but volumes tend to be low in this business. Furthermore, even dedicated equipment doesn't address the risk of raw material contamination.

I guess from your comments that the HACCP route is the most appropriate for us.

:thanx:
 
D

Daniel73

The FSA commissions research and surveys on chemicals that might transfer to food.

The responsibility is for industry to ensure the chemicals used comply with Regulation 1935/2004, and whatever research that may entail.

Adhesives are part of a variety of food packaging materials. For example, they are used to:

1) Manufacture rigid packs from cartonboard (box closures)
2) Seal flexible packaging - including wrappers, pouches and lidding
3) Attach labels
4) Laminate (bind together) layers of food contact materials
 
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