Packaging Food Safety at Nestlé
Radtech Technology Expo & Conference
Chicago, IL
April 30, 2012
Stephen Klump
Packaging Safety and Compliance Manager
NQAC Dublin
1
Outline
1. Background : Challenges
2. The Nestlé Strategy for Packaging
Materials
3. Conclusions
2
1. Challenges
3
Materials in contact with food
and non-food items...
4
… induces a complex supply chain !
Chemical Converters
industry RAW MATERIALS
Paper and board
Metal, Glass
Adhesives
-Monomers Plastics
- Antioxidants Inks
- Colorants
- Pigments
- Solvents
- UV stabilisers
- Slip agents
- Resins
Packaging
Retailers Nestlé
Materials
Co-packers
5
Set-off phenomena caused a
crisis at Nestlé
SET-OFF
multi-layer packaging material
6
Crises affect the whole supply chain
7
It takes years to build
trust and fidelity in
brands and products
It takes seconds to
destroy that Trust
8
The migration of UV photo-initiators was known...
9
2. Nestlé strategy for
___packaging materials
10
What is the Goal of the Nestlé Packaging
Safety and Compliance Initiative?
To Prevent a Packaging Recall
due to safety and compliance concerns.
11
Adherence to national and local
government regulatory framework(s)
EU- framework Directive 1935/2004
US FDA- 21CFR and FCN
CONEG and
California Proposition 65
Other Government Regulations
GB 9685-2008
12
Collaboration and Partnership
throughout the value chain is key!
Nestlé is committed to delivering good food
This means using safe packaging materials
13
Collaboration and Partnership
throughout the value chain is key!
What packaging material suppliers expect from Nestlé:
• Specifications to include relevant safety requirements, food
applications, process conditions, target consumers and
specific use.
What Nestlé expects:
• To obtain thorough certification to regulations
• To obtain qualitative composition of packaging material to
secure early identification and elimination of chemical
contaminants in packaging
14
Packaging Safety and Compliance Initiative
Nestlé Material Specs
• Regulatory
Compliance
FDA / CONEG /
PROP65 / LONO
• Compositional
Information
Packaging
Safety and
Compliance Surveillance testing of
plus GMP packaging materials
15
Nestlé Packaging Safety and
Compliance Documents
Given to Suppliers
• Nestlé Guidance Note on Packaging Inks
• Nestlé Standards on Materials in Contact with Food (Abstract)
• Nestlé Certificate of Compliance templates:
Regulatory (Part 1) and
Chemical Composition (Part 2)
16
Certificate of Compliance (CoC)
CoC for Regulatory (Part 1) certifies to:
• Food application
• Conditions of use
• FDA (21CFR, FCN, etc) & Canadian Regulations
Prop 65 (carcinogenic substances)
CONEG (heavy metals)
CoC for Chemical Composition (Part 2)
• Complete compositional information
• CAS number level of detail
• CONFIDENTIAL DOCUMENT
17
Chemical Composition
18
Nestlé Inks Guidance Document
19
Nestlé Inks Guidance Document
20
Nestlé Inks Guidance Document
21
Nestlé Inks Guidance Document
22
Nestlé Inks Guidance Document
23
Nestlé Inks Guidance Document
24
Nestlé Inks Guidance Document
Additional solvent:
• Benzene
25
Swiss Ordinance for Inks
The Swiss Ordinance includes two parts:
• Part A which lists the substances that have been
toxicologically evaluated and for which a Specific Migration
Limit (SML) has been set.
• Part B which lists the non-evaluated substances for which
the default SML has been set at 0.01 mg/kg (1 ppb)
• Note: SML refers to what migrates into food or food
simulants.
English translation of Swiss Ordinance:
http://www.bag.admin.ch/themen/lebensmittel/04867/10015/index.html?lang=en
26
Swiss Ordinance for Inks
What does this mean for migration of inks?
List B: not supposed to migrate into the food
– limit 10 ppb (µg/kg)
List A: ok to migrate into food up to the limit specified.
27
Migration
How can you ensure that migration is low enough?
1) Test the food
• (expensive)
2) Use a functional barrier
• (a what?)
28
Functional Barrier
A functional barrier may be considered to be a barrier
consisting of one or more layers which either:
• reduces the migration of authorised monomers and plastics’
additives below the specific migration limit (SML) or
• reduces the migration of unauthorised substances into foods
or food simulants to a ‘not detectable’ level.
29
Functional Barrier
These conditions may be achieved in several ways:
• through the use of an absolute barrier,
• by using a barrier layer which reduces migration to
toxicologically insignificant levels, or
• via a barrier layer which provides sufficient migration lag
time to limit the migration of a monomer or additive to
toxicologically insignificant levels during the food contact
period.
Source: Castle et al
30
Functional Barrier
• Polyolefines, EVA are not good functional barriers
• PET, PolyAcryloNitrile (PAN), PVC, PVDC, Nylon
(PA), EVOH : can be efficient functional barriers if
sufficiently thick layers used
• PET, PA, EVOH : functional barrier efficiency is
reduced by water vapour
Source: Feigenbaum et al
31
Functional Barrier
Absolute Functional Barriers:
• Glass,
• Metal Cans
• Aluminum foil 9µm
32
3. Conclusions
33
Since recent crises, the packaging
world has changed
All the value chain will benefit from
better knowledge on packaging
materials
Nestlé seeks:
● More technical information sharing on
packaging materials
● Science-based partnerships
Nestlé is looking forward to better
and stronger partnerships
34
- Last thoughts
If you only remember one thing from
my presentation today, it should be:
Collaboration and Partnership
throughout the value chain is
key!
35
36
