risks of recycled packaging

WORLD of FOOD SAFETY CONFERENCE Bangkok, Thailand, Thursday 23rd May 2013

RISKS of RECYCLED PACKAGING.

Ralph Moyle Packaging Solutions with Ralph Moyle Pty. Ltd. // National President of the Australian Institute of

Packaging.

WORLD of FOOD SAFETY CONFERENCE

The Safety of the Food we produce is paramount.

Consumers rightly trust us with the responsibility of maintaining the

highest standard. They put into their bodies what we

make.


Food and Packaging are intimately linked. • Packaging has core roles in the food

industry. • Protect

• Transport Safely. • Shelf Life


Packaging has the challenges of meeting consumer needs / expectations. • Minimal quantity. • Sustainable materials • Assessable / Re-sealable. • Low cost / High performance • Socially responsible. • Minimal impact on the Environment.


Environmental Focus on Packaging.

• Reuse • Reduce • Recycle.


Recycling does have risks and Packaging Safety Issues are many:

ITX Poly Aromatic Amines (PAA)

Semicarbazide (SEM) Epoxidised Soyabean Oil (ESBO)

BPA Mineral Hydrocarbon Oils

and this is not a complete list.


U - Environment

P - Packaging

F – Filling or Product

U P F

Migrants

U P F

Migrants


Mineral Oils Hydrocarbons – Where do you find them?

1. They are by-products of crude oil refinement. 2. Applications in packaging include:

• Inks • Adhesives • Lubricants • Plasticizers • Protective Coatings.


Example – Inks. In inks, Mineral oils often carry the pigments. >Ink applied to newspaper. >Oils absorb and attach to paper fibre >Newspaper added to recycle loop where the most of the oil attached to the paper fibre is likely to remain. > The oil transfers into the recycled paper product. > Possible product contact.


What is the concern? Mineral Oils can accumulate in several of the bodies organs over a long period of time and endanger human health. This relationship is not fully understood.


When did this become an issue? • 2010 Swiss Survey of German supermarket

products. • 2011 Confederation of European Paper

Industries (CEPI). • 2012 UK Food Standards Agency survey. • 2012 Nordic Countries and Germany.


Legislation of Food Packaging and Safety.

WORLD of FOOD SAFETY CONFERENCE Is Regulation of Food Packaging Relevant?


European Legislation. Framework Regulation (EG) Nr. 1935/2004

Art. 3: materials and articles ... ... shall be manufactured in compliance with good manufacturing practice

... do not transfer their constituents to food in quantities which could: (a) endanger human health (b) bring about an unacceptable change in the composition of the food (c) bring about a deterioration in the organoleptic characteristics

WORLD of FOOD SAFETY CONFERENCE European Legislation continued: • (EU) No 10/2011 on plastic materials and

articles intended to come into contact with food.

• (EU) No 321/2011 – Commission Implementing Regulation of 1 April 2011 amending Regulation (EU) No 10/2011 as regards the restriction of use of Bisphenol A in plastic infant feeding Bottles.

http://ec.europa.eu/food/food/chemicalsafety/foodcontact/documents_en.htm


Chinese Legislation. GB 9685-2008 Hygienic standards for uses of additives in food containers and packaging materials http://www.codeofchina.com Issued by the Ministry of Health (MOH) containers and packaging materials and other equipment or

utensils in contact with food paper, bamboo, wood, metals, porcelain, ceramics, plastics,

rubber, fibre, glass … Regulates food packaging 959 additives (positive list, migration

limitis) Official under revision since 25 Jan 2013

http://www.codeofchina.com/

WORLD of FOOD SAFETY CONFERENCE USA Legislation.

Code of Federal Regulations (CFR) for FCS (food contact substances) 1. Chemical Asessment Migration: single-use-applications vs. repeat-use-applicationsand Packaging info: consumption factors (CF) and food-type distribution factors (fT) 2. Toxicological Assesment 3. Environmental Asessment 21 CFR 25.40 or exclusion of environmental assessment (EA) DC = CF(M) = CF Ʃ (MFSL)(fT) DC: dietary concentration M: Meanvalue related to fT –value MFSL: Migrationlimit EDI = DC x 3 kg food per person per day EDI: estimated daily intake; (1.5 kg liquid und 1.5 kg solid food)

WORLD of FOOD SAFETY CONFERENCE USA Legislation cont….

04.January 2011-FDA Food Safety Modernization Act It aims to ensure the U.S. food supply is safe by shifting the focus from responding to contamination to preventing it. Title I – Improving Capacity to prevent Food Safety Problems Title II - Improving Capacity to Detect and Respond to Food Safety Problems Title III - Improving the safety of imported food Title IV – Miscellaneous provisions

30. March 2012 the FDA denied a request to prohibit the use of BPA in human food and packaging http://www.fda.gov

WORLD of FOOD SAFETY CONFERENCE Australia and New Zealand Legislation.

The Brand owner is responsible for the safety of the

packaging, regardless of the issue.

The Australian regulations for packaging migration of components, do not have the rigor by comparison to

the FDA or EU regulations.

WORLD of FOOD SAFETY CONFERENCE GMP for the Manufacture of Paper and

Board for Food Contact (09/2010)

WORLD of FOOD SAFETY CONFERENCE BRC Packaging.

The BRC/IOP Global Standard for Packaging and Packaging Materials

– Issue 4 published in February 2011; audits will commence against Issue 4 from Aug.

2011 Certification to the Standard verifies:

technical and functional performance aids manufacturers’ fulfillment of legal obligations

helps provide protection to the consumer

WORLD of FOOD SAFETY CONFERENCE What to do now?

1. Understand the origin of your food contact packaging.

2. Work with your supplier and where necessary, the suppliers to your packaging manufacturer.

3. Require certification that the packaging you are receiving meets EU.

WORLD of FOOD SAFETY CONFERENCE Key Steps required.

1. Obtaining a Certificate of Compliance - Description of the material - Legal statements of compliance - List of components - List of restricted components - Migration levels. (OML & SML)

2. Monitoring program 3. Audits

It is already out there!

WORLD of FOOD SAFETY CONFERENCE What to do now?

1. Understand the origin of your food contact packaging.

2. Work with your supplier and where necessary, the suppliers to your packaging manufacturer.

3. Require certification that the packaging you are receiving meets EU.

Thank you Ralph Moyle Packaging Solutions with Ralph Moyle Pty.Ltd. National President – Australian Institute of Packaging.

With thanks to Johannes Bergmair E-Mail: [email protected] Austrian Research Institute for Chemistry and Technology

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