their packaging suppliers provide them
with letters of continuing guaranty, stating that the materials that they supply
are approved for food contact use. This
letter should reference both the compound used in the material plus cite the
specific section of the regulation. In addition, it is a good idea for processors to
keep these files updated. Asking the
packaging supplier to provide such a letter on a yearly basis is not a bad idea.
This is also something that auditors will
almost always ask for when conducting
an audit. A sample of such a letter may
be seen in Figure 1.
Of course, this does not stop persons
from questioning the safety of materials
used in packaging. The material that is
currently being targeted is bisphenol A
(BPA). BPA is an industrial chemical
used to make a hard, clear plastic known
as polycarbonate, which has been used
in many consumer products, including
reusable water bottles and baby bottles.
BPA is also found in epoxy resins, which
act as a protective lining on the inside of
metal-based food and beverage cans.
There are people who believe this compound poses a po-
“We also need to ask whether the food package is
something that could pose a health risk or an
issue that could pose a hazard that is reasonably
likely to occur.”
tential health risk, especially if the com-
pound is subjected to heating or mi-
crowaves. In addition, since many
packages used for infant formula contain
the compound, there is concern about
exposing a more sensitive population.
The compound has been examined by
toxicologists from both the European
Union and the U.S. According to an up-
date issued by the U.S. Food and Drug
Administration (FDA) in January 2010,
“Studies employing standardized toxicity
tests have thus far supported the safety of cur-
rent low levels of human exposure to BPA.
However, on the basis of results from recent
studies using novel approaches to test for sub-
tle effects, both the National Toxicology Pro-
gram at the National Institutes of Health and
FDA have some concern about
the potential effects of BPA on
the brain, behavior and
prostate gland in fetuses, in-
fants and young children. In
cooperation with the National
Toxicology Program, FDA’s
National Center for Toxico-
logical Research is carrying
out in-depth studies to an-
swer key questions and clar-
ify uncertainties about the
risks of BPA.”
FDA is encouraging
industry to look for alternatives to BPA but
has not banned the material.
There have been sit-
uations in which pack-
aging has been
identified as the cause
of health issues. One
such example was the
and recall of 1982.1 In
this case, there were Type E botulism
cases attributed to canned salmon pack-
aged in Alaska. The can had a defect (a
triangular tear called the Index Defect)
that was caused when the flattened can
was formed into a cylinder. The botulinum spores gained access to the can
after processing, grew out and produced
toxin. The packaging was blamed for the
outbreak, but it was the forming operation that was the actual cause. Investigators determined that the flattened can
blanks, which were loaded into the reformer magazine, were torn or damaged
when being transferred from the magazine to the former.
This problem did, however, have a
silver lining. The salmon industry not
only made a concerted (and successful)
effort to improve product handling, sanitation and processing operations, but
also adopted a new canning technology.
The new technology was the one-piece
can. Shipping materials to Alaska is expensive, so processors have always
worked to make shipping more effective.
Flattening body blanks for canning allowed more cans to be shipped. After
the botulism issue, the one-piece can allowed the same economies in shipping.
This can was tapered, allowing it to be
nested and shipped. Since the cans were
already formed, all the operators needed
to do was fill, seal and process the containers. There were problems that had to
be resolved when they were first used,
but the industry addressed those issues,
and the result was a safer product.
Figure 1: Continuing Product Guarantee
*Courtesy of Scholle Packaging
Packaging and Food Spoilage
As noted above, one of the roles of
the food package is protection: protection from food pathogens, spoilage organisms, pests, tampering, damage, etc.
Packaging materials that have been properly used should not pose a problem in
any of these areas. However, there are
times when processors accidentally use
or select the wrong materials to be used
with their foods. All food processors