fsanz is in the process of reviewing the food standards code in relation to chemical migration from packaging into food, but what does this mean for food manufacturersit is an offence to sell food packaging or handling materials that are unsafe or will make food unsafe, but the code does not yet comprehensively pin down at what level or exposure certain chemicals will become unsafe when used in packaging.the code &ndash as it standsfood businesses must comply with requirements in the australia new zealand food standards code. currently, there are four main areas of the code which cover chemical migration currently in force.standard 1.4.3 &ndash articles and materials in contact with foodthis standard specifies that any material in contact with food, including packaging material, must not cause bodily harm, distress or discomfort. but it does not specify materials that can be used in the manufacture of food packaging materials or the method of manufacture.standard 1.4.1 &ndash contaminants and natural toxicantsthe standard includes maximum levels mls for a few chemicals associated with migration from packaging, but is in no way exhaustive. it covers the real nasties, including vinyl chloride, tin, acrylonitrile a genotoxic carcinogen and other potential contaminants such as polychlorinated biphenyls.standard 3.2.2 &ndash food safety practices and general requirements.this australiaonly standard details requirements on food businesses to only use packaging material that is fit for its intended use only use material that is not likely to cause food contamination and ensure that there is no likelihood that the food may become contaminated during the packaging process.the code needs work, and they&rsquore getting there. but in the meantime, what should manufacturers dodr barbara butow, a senior scientist at food standards australia new zealand, says manufacturers can look to eu and us regulations, which are more comprehensive than australia&rsquos current standards.eu or us codes &ndash how are the two differentthe eu requirements regulate migration limits and migration into food, whereas the us requirements are around the packaging itself.&ldquothe usfda requirements are incredibly detailed around what you can use your packaging for and under what conditions, so temperatures and times and for what materials,&rdquo butow says.&ldquoso the outcome is the same, as i understand it, but the way that you get there is slightly different. i think the eu regulations appeal to a lot of companies because it&rsquos a level that can be measured, whereas the us regulations, they&rsquove got a database of cumulative exposure data intake cedi, which is around the exposure to the chemical from the packaging.&rdquobutow says manufacturers can help ensure their product is safe by going back to their suppliers for assurance.&ldquoi think they need to be aware what the packaging material is, what potential chemicals could migrate from there and under what conditions. if it&rsquos a material that&rsquos going to be stored for a long time, is it greater potential for migration or leakage of chemicals.&ldquothey need to look at how&rsquos it going to be stored and what food is the packaging going to be used for. all those things are good manufacturing practice. if it&rsquos following gmp, then you can look at some of the iso standards. if people are concerned about mineral oils leaking from cardboards then maybe put a barrier in, although some people say the barrier might not be adequate.&ldquoso there are codes of practice out there which describe all these things and then there&rsquos a code of practice for printing inks, the eupia code of practice.&rdquobutow says that while food manufacturers can access international regulations, they&rsquore not easy to navigate.&ldquointernational regulations are not a one stop shop and certainly the code of federal regulation in the us, you have to go through layers upon layers to get down to the chemical that you&rsquore interested in to get the actual requirement. it is there, but not the risk assessment behind it.&rdquois it safebutow says that while consumers might not assume there&rsquos regulation on absolutely everything, they &ldquojust expect packaging to be safe.&rdquo&ldquoit&rsquos only when there&rsquos something on the news and again it tends to have a bit of an imported food bend to it than people&rsquos ears prick up.&rdquo&ldquowe really welcome input from industry, it&rsquos just a call for information, a call for participation,&rdquo butow says.&ldquoso if and when we go down the track of adding a bit of regulation, or touching up the standard, at least we&rsquoll know who to approach for input.&rdquodr barbara butow presented at the 2015 national technical forums.
