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Self full of cheese packed in food safe flexible packaging.

A General Overview of Packaging Food Safety

Posted 07/24/2019 by Justine Hanlon, Market Manager, Flexible Packaging

Food safety is an important subject in packaging, both globally and regionally. The role of packaging in food safety continues to grow as consumers eat more meals outside of the home and expect packaged foods to remain safe for extended periods of time. Adhesive suppliers and other manufacturers of packaging materials must monitor regulations and requirements as consumer safety is more closely examined. Consumer packaged goods (CPG) manufacturers should expect considerable support in food safety compliance from their packaging suppliers.

Flexible packaging, and the adhesives used in the construction of flexible packaging, plays a significant role in the global food safety conversation. The materials that make up flexible packaging help ensure that fatty foods, such as meat, cheese and seafood, are safe for consumption. Although adhesives generally make up less than 5 percent of flexible packaging, unintentional food contact may occur by migration through the packaging.

How EU Flexible Packaging Regulations Affect North America

The U.S. Food and Drug Administration (FDA) regulates the use of adhesives in food packaging. The FDA’s adhesive rules focus on the manufacturer’s responsibility to use a suitable, approved adhesive for food packaging. FDA regulations for indirect food additives tend to focus on the food contact substance itself. Regulatory compliance for adhesives focuses more on the manufacturers of food packaging and finished food products that contain adhesives. FDA-compliant adhesives must follow FDA regulations 175.105 and 175.300, and be manufactured from pre-approved raw materials. Adhesive formulators create products from FDA’s section 175.105-approved substance list.

A company may ask the FDA to review new adhesives under its Food Contact Notification Program. If the components of an adhesive do not meet the regulation requirements, and they migrate into the food contained in the packaging, the food is considered to be contaminated. Determining what is safe and fit for use in food packaging is an important and oftentimes long process for adhesive suppliers.

Good Manufacturing Practice (GMP) requirements, used in conjunction with FDA regulations, are intended to keep from transferring anything to the food contained in the packaging. This is achieved by ensuring that all adhesives used in flexible food packaging are adequately cured, ensuring no adhesive components will migrate through the packaging and cause anything that could be hazardous to health or that changes the taste, odor or composition of the food.

Primary Aromatic Amines (PAA)

Primary aromatic amines (PAA) is a potential toxicological issue because of its identification as a carcinogenic substance. PAA is a potential, non-intentionally-added substance (NIAS) that can be found in flexible packaging and needs to be monitored to ensure it doesn’t migrate into food at detectable levels. Adhesives, inks and coatings that contain polyurethanes are common components within the flexible packaging industry. PAA, although not a component of adhesive formulas, can be formed during the curing process. Trace amounts of adhesive isocyanate monomer within the adhesive formulation can react with existing moisture and create PAA that can then migrate into food and be consumed by the end user.

There are different reasons why a laminate might not end up fully cured, most often as a result of poor processing conditions. For example, low humidity and very cold temperatures could cause a package to cure more slowly or not at all. That is why understanding the total packaging process – from the handling of the materials, laminating, pouching, and final filling – is necessary to create a truly food safe package.

One-Day Food Safety and Nylon Technology
Migration Studies

Components of adhesives for use in food packaging that are not the subject of a food additive regulation may still be used if they are not reasonably expected to become a component of the food. A migration study (a lab test to see if a detectable amount of the chemical can be extracted into the food simulant) can be conducted to determine if a new raw material or adhesive will become a component.

In order to design a successful migration study, suppliers must:

  • Define which chemicals are likely to migrate;
  • Identify potential chemical material hazards;
  • Verify an appropriate detection limit based on potential exposure.

In order to successfully plan a migration study, the intended final use of the adhesive is required. Testing samples must be prepared under the same manufacturing conditions as the end use and take into account the type of food, processing temperatures, film types and thickness, amount of adhesive used, adhesive composition, and cure times.

Time, temperature and food type are important in interpreting how end use affects migration. As time and temperature in a package increases, migration potential also increases. Fatty foods, such as meat and cheese, enhance the migration of chemical substances.

Determining the potential for migration requires an understanding of the end use or type of food and the packaging structure. Adhesive safety is in part dependent on the packaging structure or barrier film used. Different films have different barrier properties depending on thickness, temperature, and food type.

Adhesive testing is usually tested on a final formulation and packaging type, not on individual raw materials or pure adhesive. Testing on specific structure and packaging type ensures that migration does not change due to changes in curing times, conditions, adhesive, and packaging type. Migration testing typically requires 10 or more days to conduct and usually employs sophisticated, computer-controlled instrumentation.

To learn about our flexible packaging solutions, click here. You can also learn more about food safe packaging here.

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