offering no objection to a specific use.
The prior sanction exists only for a specific use of a substance in food delineating level(s), condition(s), and product(s)
set forth by explicit approval by FDA or
USDA prior to September 6, 1958.
Threshold of Regulation (TOR) Exemption: A substance used in a food contact article may be exempted from the
requirement of a food additive listing
regulation if the use in question has
been shown to meet the requirements
in 21 C.F.R. 170.39. For details, see 21
C.F.R. 170.39. For a complete listing of
the TOR exemptions, consult the TOR
inventory on the CFSAN Internet.
Claims and Counterclaims on Food
Plenty of general information is
available on the Internet, creating
confusion about the safety of food
packaging. Simply searching terms such
as “microwaveable foods,” “plastic
bottled water,” and “canned foods” will
result in various statements ranging
from informative to alarming. 2, 3 Some
information arrives from public opinion, while some other information may
be traced to commercial or scientific
sources. Regardless of the content or
the source, it is imperative that food
processing and packaging professionals
be adequately informed and prepared
to present information about the safety
of FCSs being used. Whether an FCS
exists in finished products or contacts
equipment during processing, storage,
and transportation, this information
should be presented and summarized
via packaging labeling, a website, or
other means. The following example of
Internet searches can provide insight
into the gravity of how important it is
to understand FCSs.
A recent Internet search about food
packaging safety yielded a 2018 report4
by the American Academy of Pediatrics
(AAP) about a policy statement published online in July 2018. According to
the AAP report, an “increasing number
of studies suggest some food additives
can interfere with a child’s hormones,
growth, and development, according to
the policy statement and accompanying technical report. Some may also
increase the risk of childhood obesity,
rates of which have tripled since the
This report, which cites scientific
evidence, also states the potential health
hazards as follows:
Bisphenols, such as BPA [bisphenol A],
used to harden plastic containers and line
metal cans, can act like estrogen in the body
and potentially change the timing of puberty,
decrease fertility, increase body fat, and affect
the nervous and immune systems. BPA is
now banned in baby bottles and sippy cups.
Phthalates, which are used to make plastic
and vinyl tubes in industrial food production, may affect male genital development,
Use miniDART™ to Tell Your Product Story with
Conviction and Evidence
Daily headlines about environmental destruction, foodborne illnesses, fraud,
and adulteration have consumers worried when deciding which brands to trust
and which products to buy for their families. Chocolate production destroying
the rain forest? Produce not sourced locally?
Organic bread not made with organic wheat?
Olive oil not pure?
To retain customers and grow market
share, producers and processors are responding with commitments to improve transparency, safety, and sustainability of their products and ingredients. They work day
and night to improve their processes and better control their supply chains in
an effort to provide the best products and meet their customer commitments.
But how do they actually prove it? How can they not only tell a product’s journey from field to table, but actually verify it? To be certain that their ingredients
are really fresh, pure, safe, sustainable, organic? To remain the brand that customers can trust?
miniDART lets the food industry tell their product story with conviction and
evidence. It is an innovative, item-level Internet of Things (Io T) traceability
solution using patented, U.S. Food and Drug Administration-affirmed, DNA
barcodes (safe Tracers™). They are applied directly to raw materials and finished
product for real-time tracking and whole-chain traceability. Product-and lot-specific information is encoded in safe Tracers for an easy-to-use traceability
solution that moves with the product, even after primary packaging is discarded
or 2D labels are lost or replaced.
The Io T miniDART solution is part of Safe Traces’ solution suite created for a
more digital, transparent, and safer food system. It gives quick access to information about where foods come from, how they were produced, and whether
the food is the subject of an ongoing recall.
Who Uses miniDART?
Any facility producing, processing, preparing or packaging foods including
bulk good (grains, beans, cereals fresh produce) or liquids (juices, oils, etc.)
can use the miniDART solution, which is easily retrofitted into legacy production systems.
The miniDART Advantage
Item-level traceability without packaging and in real-time revolutionizes fresh
produce and commodity food traceability where packaging is typically absent
and product is often commingled. The miniDART can encode traceability data
for multiple supply chain events (e. g., harvest, shipping, product transformation,
etc.). Use miniDART to tell your story about source, authenticity, and purity.
Contact us to find out more: www.safetraces.com; email@example.com