Stay well Stay Safe

Stay Well Stay Safe – Review of Safety Regulations of Packaging

Stay well Stay Safe is the new wish on the social platform which has taken precedence over the earlier one – Take care and Khuda Hafiz. In this age of continuous combat between man at one end with microbes and viruses at the other end,people are imbibing the values of these wishes and looking forward to practical ways of translating these wishes into practice. We are going to see heightened awareness in consumer on immunity booster, hygiene and safety in food and food packaging. And at the same time, we do not wish to miss the zing on packaging at the point of purchase. As for myself fruit has become an inseparable part of my diet in lunch and dinner for immunity boosting! So, it may not be surprising now to see an increased consumer preference shift from flavored carbonated beverages to fruit pulp-based drinks like Paperboat, Swing, etc. which offers both fruit pulp and a contemporary differentiating trendy pack to sip in!
That is what we call a synergy between the product and packaging which influences customer opinion to select a product in the market. While the Food Business Operator needs to delve into the deliverables through the food, the packaging professional has to ensure that the packaging is both attractive and safe in contact with food.

In 2018 FSSAI laid guidelines of Packaging regulation through science-based standards in articles related to food. This game changer regulation or standards on packaging were adopted from BIS standards and we can roughly categorize them into two types – Packaging components in direct contact (eg sealant layers) and Packaging components into indirect contact like inks. While people generally pay more focus on direct contact material , indirect contact materials like inks and their components can pose much serious risks , if not properly designed .This is because inks  have more complicated and complex chemicals, than direct food contact material , for colour and rheological properties  ,taking the liberty of being an indirect food contact material.  We can here pick up, in brief a few cases, which are importance in contemporary industry.
BIS recently published its revised standards IS 15495 which requires inks in food packaging to be Toluene free. Like other similar standards this standard is also adopted by FSSAI and hence mandatory for compliance from 1st February 2021.

Toluene is classified in CMR (Carcinogenic, Mutagenic, Reproductive Toxicity) category 2. Also, Toluene is identified as a POP -Persistent Organic Pollutant. In overall Toluene can affect the consumer (food taste and toxicological safety) , the printer while printing the job ( Occupational safety ) and environment ( Environmental Safety through discharge of toluene to environment) .Eliminating Toluene is right step from all angles but the criticality is in execution .Since Toluene is not prohibited in non-food packaging some brands and printers can still continue to use Toluene in other applications like in personal care products . Use of Toluene in the same premises with the same machineries can trigger Toluene impurity in food packaging which we can label as NIAS – Non Intentionally Added  Substance .This is an area where brand has to take care as the standard has zero tolerance towards Toluene presence and the presence of a NIAS is conventionally regarded as one of below 10 ppb

The second area of concern in the contemporary industry is the frequent printing of promo codes inside the food packaging on the middle layer, or on the soft drink bottle labels for consumer engagements. In many cases the barriers between indirect contact ink and food product can be reasonably reduced with increased risk for the ink to come in direct contact with product through accidental exposure, which is prohibited from regulatory point of view.  Therefore, in such cases direct food contact ink should be used keeping in view of consumer safety though these inks are costlier, comparatively dull and not eye catching with not so high visibility.

The third case we are discussing here is Nitrosamine – related to Pharmaceutical Packaging. Absence of nitrosamine is a compliance requirement, because of their mutagenic potency, when packed pharmaceutical products arrive in Europe. European Medical Agency (EMA)  finalised a review under Article 5(3) of Regulation (EC) No 726/2004 in June 2020 to provide guidance to marketing authorisation holders on how to avoid the presence of nitrosamine impurities in human medicines. EMA and respective  national authorities in EU continue to monitor the presence of nitrosamine impurities in medicines. The Nitrosamine from packaging can be generated from the reaction of Nitrocellulose in Inks and Amines either present as a part of the ink or part of the medicine. This rection to generate nitrosamine can happen under high temperature of sealing the pack though they were not present originally as part of the original ink. The right way for compliance will be to choose a revised ink system. Some Printing ink companies have developed alternative formulations.

In India also, FSSAI laying down the regulation with scientific standards, is engaged in monitoring compliance for both food and packaging materials. Sometime back FSSAI did a major exercise on packaging material samples checking for compliance, coming from both organized and unorganized sector, through national labs. Recently FSSAI has initiated nationwide survey to curb the sale of adulterated edible oil. FSSAI has collected 4700 + samples pan -India from lands as far as Ladakh and Andaman to intensify drive against adulteration of edible oil.

We have to be conscious on changing rules and regulation and be proactive in compliance for consumer safety and to ensure a thumbs up for our industry and brands.

It will be worthwhile to note a few applications of inks as well, at the end of the discourse which can boost brands and brighten up our lives, for example, thermochromic inks which can change colour with temperature change. A label with such ink can be applied on a beer can sold from retail outlets, whereby the original colour, say, white changes to a soothing colour of sea blue when the content is adequately chilled giving value for money. Again, the perishable packed food has a Use By Date or Best Before Date printed on it indicating only storage time and not temperature whereas the food degradation kinetics are overwhelming decided by the storage temperature and not by storage time. In such cases actual usability of the material can be measured with a colour change label and programmed to express the composite sum of exposure. So, foods edible and safe to eat , which had passed its use by date, will not be thrown into waste collection boxes anymore.  Some day in future when we get affordable technology and food becomes scare commodity from the population burst, such smart packaging may be visible as a common practice on the shelves

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Atindra Narayan Chaudhuri has more than three decades of experience in Flexible Packaging Industry and now engaged as consultant and advisor in Packaging and related Industries. He is engaged with National regulatory Body BIS (Bureau of Indian standards) for around last two decades and has contributed in revision of Indian Standards related to Packaging and Food Contact safety which had been adopted by FSSAI as mandatory standards in India.

He has also contributed to revision of Plastics and Environment related standards in BIS and ISO which had been adopted by MoEFFCC as mandatory regulations in Plastics Waste Management. He represented India in the recently held ISO conferences in the field of Plastics and Environments. He is a major in Chemistry with B.Tech and M.Tech in Plastics and Rubber Technology . He is also Life member of AFST(I) – Association of Food Scientists and Technologists CFTRI Mysore and Institution of Engineers (India) as M.I.E. and Chartered Engineer

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