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A fundamental tenet of food packaging is that it shall do no harm to any consumer using the package. A second basic objective is that food packaging should contribute to preserving the safety of the contained food product. In its simplest terms, packaging is intended to protect the food contents against the natural and man-made surrounding environment.
Why then might the American Institute of Baking (AIB) plant inspection arm issue a document titled “A Call for Action: Food Safety for Packaging Suppliers” and a follow-up, “The Industry Responds,” in December 2007? Are the packaging supply industries somehow falling short in their obligations and responsibilities to the food (and beverage) industries they are supposed to serve? One might assume that a paucity of media headline incidents screaming all manner of deficiencies might be evidence of a near-perfect record by makers of paperboard, corrugated fiberboard, metal, glass, and plastic. On the other hand, it is indeed possible that much has been hidden by aggressive programs to prevent, counter, or minimize each of the many problems that inevitably arise. But, to apply a cliché, out of sight is not out of mind.
The majority of packaging suppliers to the food industry are domestic, utilizing local and regional raw materials, technology, and people. A hardly insignificant quantity of materials, however, is obtained from offshore sources. Converters—with whom most food packagers deal directly—are the organizations that extrude and blow plastic, print, cut, score, emboss, fold, stack, nest, and otherwise ready the packaging structures for the food packagers’ equipment and food. In addition to North American converters, volumes of basic materials such as plastic resin, metal closures, paperboard, and rolls of naked plastic film from offshore locations are found in the supply stream. This column has previously cautioned readers to closely oversee any and all offshore-derived packaging materials and converted materials. Many countries and their internal agencies and trade associations do not have the safeguards and regulations that underlie our supplier network.
HACCP in Package Supplier Operations
Many suppliers of food (and drug and personal care product) packages have instituted Hazard Analysis and Critical Control Points (HACCP) programs to present a basic safety understructure for their converting operations. HACCP programs are especially important for primary package converters because their outputs—such as metal cans, glass bottles, and flexible films—are in direct contact with food products. Obviously, with food plants that are mandated to employ HACCP, e.g., meat processors, requiring HACCP in their suppliers’ operations is standard operating procedure.
Because package material converters are not primarily food processors, they are not necessarily focusing on foreign objects and debris physically entering their materials or empty containers. Neither is the food company quality apparatus always alert for issues in package materials. HACCP programs among suppliers—particularly when the effort is one that closely links the supplier and the food packager—are becoming effective tools to minimize problems. But, unfortunately, HACCP programs are hardly universal among packaging suppliers.
According to the AIB report, the No. 1 reason for food product recalls is mislabeling. As every food and food packaging scientist and technologist well knows, mislabeling violates FDA regulations and renders the packaged product the object of mandatory recall. Persons with allergies, diabetics, vegans, or Kosher adherents, as well as those who seek low-fat or low-calorie foods, may be more than misled by mislabeling. A label that omits a critical warning may cause harm to such a consumer. Refrigerated and frozen foods not clearly marked as such might be distributed at ambient temperatures, leading to microbiological growth, some of which could be pathogenic, or thawing and loss of quality, including enzymatic and microbiological activities.
Labeling is not just the printed cut or roll-stock paper or plastic film adhered to the package surface after filling and closing. Labeling includes printed flexible package materials, paperboard cartons, preprinted metal cans, and embossed and fired glass bottles. Evidently, mislabeling arises often from mixed printed package materials obtained from pallets that contain several different designs of package, mixed cases, and mixed cartons. Because food plant employees may not be able to read English, a mislabeled pallet load of package materials—or one or more wrong cases on a pallet—can easily be placed in a food packaging line. Electronic pallet or case scanners could solve this issue, but few are installed in food packaging operations.
Analogous errors arise from selecting the wrong package material cases—for example, when the food packager produces many different flavors sequentially differentiated only by print copy. Most label errors are very difficult to spot at the high speeds at which packaging equipment operates. Some beverage canning lines operate at speeds that exceed the human eye’s ability to read the design. Fortunately, such automated lines are equipped with vision equipment that can detect deviations.
Changeovers—common in today’s food packaging operations—can be a source of mislabeling when splices are made in flexible packaging rolls or in cartons or labels themselves. Until automatic scanning becomes standard on food packaging lines, employee vision and reading skills buttressed by alertness training are indispensable to avoiding mislabeling incidents.
The second-most-frequent cause of product recalls in the food and beverage industry is glass contamination. Admittedly, some of the glass comes from unshielded light bulbs or windows, but today, most food and converting plants have been protected against such intrinsic hazards. The major portion of glass contamination comes from glass bottles and jars weakened during manufacture and/or chipped, abraded, or broken during transit and warehousing. Glass-containing cases, or even pallets, may have been abused, hit, dropped, vibrated too vigorously on road beds, or compressed, or may bear small slivers and fragments that find their way into open-mouth empty bottles and jars. Often, required paperboard partitions to separate glass containers have not been fully seated, and most food companies receive cased, partitioned empties.
The easy solution is 100% cleaning of empty glass packaging before filling and closing, but many small packagers do not have such equipment. It is essential that evidence of broken glass be followed by thorough cleanup such as, for example, on a pressurized glass bottle line where occasional explosive forces are at work.
And then there is the paperboard debris that fl oats into open-mouth empty bottles and jars—both glass and plastic.
Many reasons exist for the gradual conversion of glass to plastic packaging, one of which is the elimination or reduction of broken glass on or near food processing and packaging lines. Inspection for glass contamination can be high-speed vision (electronic), but many plants still depend on visual observation. (Do not blink, get bored, or doze for an instant!)
Rare, but still existent, are fragments from plastic, which are even more difficult to find than glass. Incidents with rigid plastic, infrequent though they are, are sufficient to warrant a program of overt watchfulness.
How many times have aromas, scents and odors from one product migrated or drifted from one package into another of a different flavor profile? When chocolate is contaminated with a citrus aroma, the result is reduced quality, but not a hazard or even unpleasant. When the fatty product is the recipient of a real stink or off odors or pet food spills wafting around the dairy counter, the effect can have lasting economic consequences. (Think pepperocini pickle juice volatiles from a broken glass jar permeating into adjacent chocolate. Yes, Virginia, it happened in real life.)
When the offending system is cleaning compound or other chemicals in the plant, the transport vehicle, or the retail back room, the result can be hazardous to the consumer.
The presence of solvents from inks or coatings that have not been removed in the converting operations can be adverse or even toxic to eventual contained food products since solvents employed overseas may be volatile organics. It is thus vital that materials received from such sources be more carefully scrutinized.
Perhaps you did not realize that package materials from reputable and reliable suppliers might be sources of food safety issues. You trust your ingredient supplier shipments implicitly, don’t you? No? You rely on the supplier to produce safe inputs and to perform the requisite inspections, which you verify? Ingredient suppliers know their roles and so are careful, and yet errors occur.
With packaging suppliers one step removed from the food itself, errors are more probable—not highly likely, but possible. Without implying any widespread problems, no one yet has demonstrated perfection. And most food processors have not instituted continuing oversight over their packaging suppliers. The issue of potential food safety problems arising from package materials is large enough to suggest that converters and food packagers address this issue before it becomes another of those many problems that make headlines.
by Aaron L. Brody, Ph.D.,
Contributing Editor, President and CEO, Packaging/Brody, Inc., Duluth, Ga.