Materials: Leaving food safe and taste intact

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Recalling a product must be a retailer’s biggest nightmare. Aside from the possible damage to your reputation, there is also the massive cost in terms of lost profits, paying the workforce to orchestrate the recall and refunding customers. “It’s not unusual for a wide-ranging product recall to run into millions of pounds,” says Geoff Spriegel, the British Retail Consortium’s (BRC) director of global standards.

While a chemical migrating from the packaging to the food is less common than, say, general environmental contamination of livestock (see box), the whole retail supply chain needs to be aware of the chemicals present in the packaging to ensure there is no health risk and the food reaches the consumer in good condition.

“It’s a complex matter to bring packaging together with something people eat. There are a set of considerations that are unique in terms of product safety being paramount,” says Helen Munday, director of food safety and science at the Food and Drink Federation (FDF).

“Legislation is not so much about the levels of a particular chemical that are in the virgin packaging, but what can be transmitted to the food. That can mean from secondary as well as primary packaging, so you have to be very aware of the full package.”

The main legislative driver ensuring food is not tainted by packaging is European directive (1935/2004).

It outlines that chemicals from packaging should not endanger human health or cause a change in composition or decomposition of the food. It also stipulates a maximum migration limit of no more than 60mg of the chemical for every kilogram of food substance. “It’s a measure of the inertness of the packaging rather than safety considerations,” says Chris Howick, product stewardship manager at polymer producer Ineos ChlorVinyls. “If a manufacturer uses a material at the maximum migration limit then, at the very least, it would have to show that limit is obeyed.”

Bisphenol A

It is clear that plastic packaging in particular is a big concern for the general public. The media furore surrounding Bisphenol A in babies’ bottles is a case in point. While studies have shown that, under strict conditions, the potential migration of Bisphenol A from packaging is well below the tolerable daily intake, there are still calls to ban the chemical completely.

Manufacturers, therefore, need to be certain about exactly what they are putting around food products. “You have to be careful as the components of plastic packaging could migrate at different rates. You need to know the material you are using complies with the regulations,” says the BRC’s Spriegel. The key is clearly a good flow of information along the supply chain, and good documentation to show compliance with

the regulations.

The European Commission says it is essential food manufacturers liaise with packaging producers in order to define the most appropriate package for the food, taking into account factors like composition and storage. “In turn, packaging manufacturers should contact raw material producers in order to ensure the packaging they are producing is made with appropriate material,” says an EC official.

Communication breakdown

The official continues that the EC reported a case of bad communication to the European Food Safety Authority (EFTA) earlier this year, when it highlighted the migration of 4MPB (4-methybenzophenone) from the ink on the outside of the cereal carton to the product. “The food producers did not inform the cardboard manufacturers about the nature of the plastic bag used for the cereal. And the cardboard box producers did not tell the food producers they had used an ink that contained a highly migrating substance,” he says. Thankfully, in June, the EFTA said there are no health risks from the short-term consumption of 4MPB at the levels found earlier this year.

Potential migration of chemicals is something ink producers such as Sun Chemical take seriously. Jo Watkins, European marketing director for packaging, says the firm produces all inks in line with legislation and provides a lot of technical data to brand owners. “We take stewardship of our products very seriously,” she says. “But ultimately we can design it for a specific application and don’t know exactly where it will go on the pack. We try to give the best technical advice and ensure the chain takes its responsibility to make a pack that’s fit for purpose.” She adds that as well as potential health risks, the firm also looks at potential taint and odour to comply with legislation. “Chocolate and tea can pick up odour. Some of the things that can be transferred are digestible, but unacceptable in terms of the product and so should be avoided,” she adds.

Ink and recycling

Direct food contact inks are only a small part of the market. Sun Chemical is also looking at how inks can work with recyclable materials. It is currently investigating natural inks, as well as those compatible with the product, such as a PET ink for a PET film. “Even de-inking could be developed,” says Watkins. “To a certain extent, it’s the reverse of our standard model – instead of getting a product to stick, we want it to come unstuck after use.”

Lawmakers are currently examining legislation surrounding recycled materials, because of the growth in collections and the desire to use recovered material to create new food packaging. “If you take something that’s not being manufactured from virgin material, you are never quite sure exactly what you’ve got,” says the FDF’s Munday. How these products will interact with inks and coatings is another consideration.

Even if wide-ranging product recalls are relatively infrequent, testing packaging in context is clearly paramount to avoid making a costly mistake. But it is no good just doing it in the laboratory, and cases like Bisphenol A underline the need to consider real-life scenarios which involve the whole supply chain. As Munday says: “There’s a big difference between risk and hazardous. The theory can tell you there is something in the pack [that could transfer to the product], but you might not be aware of it at home.”

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RULES, GLORIOUS RULES

The starting point for food contact legislation is European directive 1935/2004, and its subsequent amendments. The fundamental premise is that food-contact materials should not transfer components into the food in quantities that could be dangerous to health, unacceptably change the composition of the food or affect taste and odour. Chocolates and tea are particularly susceptible to picking up odours.

The overall migration limit should not exceed 60mg per kg of foodstuff. Furthermore, labelling and advertising should not deliberately mislead the consumer.

Plastics are the only packaging materials to have specific legislation at a European level, although some countries do have national legislation on the other materials. There is also legislation for ceramics. The regulations also cover a wide range of areas such as cutlery, work surfaces and the material used to line fridges.

The regulations that exist in England, Northern Ireland, Scotland and Wales are the translation of the European legislation into the legal framework of the four nations, establishing what firms need to comply with and the penalties for failing to do so.

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PROOF OF THE PUDDING

Since 2007, the Food Standards Agency has published an annual report on the incidents it has investigated in its role as protector of consumers and the food supply chain. Last year, it investigated 1,298 cases, a small drop on the previous two years and took a range of action, such as working with local authorities to ensure contaminated wheat does not reach the human food chain or helping farmers prevent lead poisoning in their livestock.

• In 2008, there were only 35 incidents relating to food-contact materials.

• Eighteen of those incidents were reported as being caused by the migration of chemicals from plastic packaging and utensils.

• A further five cases were reported to be caused by metal packaging and utensils.

• An additional five were said to be from “other packaging” and there were no cases of migration from paper and board packaging last year.

• The other packaging-related incidents were due to products being incorrectly labelled by the manufacturer, of which there were 108 cases last year.

• While the number of food-contact-material cases has risen steadily since 2000, only 103 of the 7,879 incidents investigated since then have been related to food-contact materials.

• By comparison, 2,575 were due to a contaminated environment, 317 due to allergens and 334 due to unauthorised ingredients.

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