Archive for the ‘Regulations, Rules and Laws’ Category

Yeast & Mold Standard

December 1, 2017

Reul asks,

We recently had a batch of doublewall boxes held at the port because it was mishandled by the shippers and delayed for about two weeks. The dry container van was stored at the Customs Yard. Maybe the two weeks of exposure to cyclic condition, high humidity at night time and occasional rainfall may have resulted in a favorable condition for spore to develop into molds.

Do you know a standard or allowance of presence of yeast/molds in a corrugated box? We have this analysis of 1500 CFU from the swab test conducted on the samples coming from a certain batch of corrugated boxes that we produce.

This has been a concern for us since one of our customers complained the boxes they received had some dusty matter on its surfaces. We sent samples to an independent lab for microbial analysis and it was confirm to have that reading mentioned above. Is this value alarming?

That’s a tough question. We have no threshold count for molds and yeasts. It would not come with the containerboard except where the relative humidity or liquid water is present with the spores. Certainly the conditions you described could have had an impact on the condition of the boxes and the growth of molds if spores were present. Depending on what the contents are and what the end user environment is these conditions could very well be unacceptable.

— Ralph

Advertisements

Letters of Compliance regarding chemical migration

November 20, 2017

Jeff asks,

We have received three requests from customers in the last month, asking for letters of compliance regarding chemical migration testing of corrugated packaging. They are saying this is a requirement for their SQF 2000 audits.

Is there a statement we can make to our food manufacturer customers that would generally satisfy their requirements?

The world has not agreed yet on what the general statement or regulations will look like. The Global Harmonization Standard or GHS is still in committee as they work to iron out the specs.  We do not have issues with mineral oil migration in the USA. Ask your sheet supplier for the letters that you can provide to your customers. They know the process and materials going into the manufacture of the sheets and should have a reasonable understanding their product as it corresponds to your customers’ requests.  Also, placing the responsibility of compliance on your supplier may be beneficial to you in the long run. I’ll keep my ear to the ground on the GHS and update when if I hear of any changes.

Has anyone else had experience on  this subject that they can share? Let us know what your experiences and thoughts may be.

— Ralph

Regulations on box storage for food related boxes

November 17, 2017

Tim asks,

Ralph, are you aware of any regulations regarding the storage of secondary packaging for food related boxes? We make secondary packaging for a customer and they received some of our boxes that were covered with stink bugs. Apparently there was a small hole in the wall, which we have repaired, where the boxes were stored. Being that they are secondary boxes it does not required us to be AIB certified.

Those little insects get everywhere! There should not be any regulations for reasonable storage of secondary packaging. Below is a link for recommended practices for the storage of corrugated. https://www.pmmi.org/sites/default/files/PMMI-B155-TR2.3.pdf

I would also suggest that you walk through 21 CFR 110 for the “Current Good Manufacturing Practice in Manufacturing, Packing, or Holding Human Food.”  You may also consider an overview of the Food Safety Modernization Act.

However, regardless of whether there are regulations or not, your customers don’t want any little six-legged stowaways in their shipments. Perhaps you could bag or stretch wrap the entire pallet to protect against further infiltration or contamination from dust or other elements that me be present in the atmosphere.

– Ralph

RoHS Compliance

August 23, 2017

Scott asks,

We have a customer that is shipping products into Europe and they want to know if our packaging is RoHS compliant. Do you have any information on RoHS requirements or specifications?

The RoHS (Restriction of Hazardous Substances) used in Europe and Asia is very similar to our CONEG (Coalition of Northeastern Governors) regulations. Both focus on the reduction and control of toxics (heavy metals, phenyls and phthalates) in packaging. RoHS included six initial substances; Lead, Mercury, Cadmium, Hexavalent Chromium, Polybrominated Biphenyls and Polybrominated Diphenyl Ethers.

In the 2015 Directive revision four additional substances were added to the list of regulated substances. These included Bis(2-Ethylhexyl) phthalate, Benzyl butyl phthalate, Dibutyl phthalate and Diisobutyl phthalate.

Your board supplier should be able to provide a COA or Certificate of Compliance or the paperboard you purchase from them. You may also want to solicit the same from your ink and glue suppliers too just to have them on record. Also keep in mind that labels, stickers and films are also considered part of your packaging. The exceptions are stickers or labels required by governmental agencies to meet health and safety or transportation requirements.

You can find additional information on RoHS at http://www.rohsguide.com/, and for more information on CONEG visit coneg.org/tpch.

— Ralph