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food contact

What’s changed?

There is an addition to Clause 4.7.5, which now states that materials and parts used for equipment and plant maintenance shall be of an appropriate grade or quality.  It also states that materials that pose a risk by direct or indirect contact with food or food contact surfaces must be food grade and we need to consider the allergen status of the materials.

What does that mean then?

BRC have re-worded and added to this clause, to clarify that all that materials that come into contact with food must be of a suitable grade and quality. Previously, the way that this clause was worded made it sound like it only applied to lubricants.  The addition to this clause is quite a big change.

Previously, the standard said materials such as lubricants; which meant that we all focused on just the lubricants. Now they’ve split this clause into two parts. The second part refers to the lubricating oil and the first part is now generic to the materials used in equipment.

This means that we now need to prove that all materials that come into contact with food, or pose an indirect risk to food, as they are over open product for example, need to be suitable for food use.

So what should we do?

So, to comply here, you will need to generate a list with engineering, of all the direct food contact materials as a minimum – such as food contact conveyors, seals, filters etc. Don’t forget all of your tools, such as scoops or scrapers.

For each material, you’ll then need to gather evidence to show that the material is suitable for food use. The best way to prove that they comply, is to ensure that the specification for the material states that they meet the requirements of local legislation.

  • UK and Europe is Regulation 1935/2004 – The Materials and Articles in Contact with Food.
  • America is the FDA’s 21 CFR: Packaging & Food Contact Substances regulations.

Just so you know, where you are using stainless steel – make sure that it is either 304 or 316 grade, as these are suitable for food use.  Therefore, they’ve changed it so that it does cover lubricants, but it also covers all food contact materials.

If you’re interested in knowing more about packaging compliance, we are writing articles about the upcoming Issue 6 of the BRC packaging standard.  If you’d like to hear about these too and you are a subscriber to this newsletter, you just need to update your preferences on the link included on the email in this newsletter.  If you’re not a subscriber, you can join Techni-K Smart Knowledge using the link below – make sure you select the packaging option when you choose your subscription preferences.

6 Comments

  • Rebecca says:

    Our auditor was happy with a general ‘it looks like stainless steal – I can’t see any rust’, along with a materials in contact with food statement for our machine belts. How would we prove otherwise on tables etc that have been here for a very long time (and certainly before BRC was!)
    For context we are a fresh produce grower and packer with only tables, flow wrappers, slicers – that sort of thing. We don’t use any scoops etc.

    • Kassy Marsh says:

      Thanks for sharing this. Please just be aware that although your auditor was ok with it during your audit, it doesn’t mean in the future it won’t get picked up…

  • Meriam Grace Aquino - Castillo says:

    Hi,
    This will be of great help to my consulting work on food manufacturing companies.

  • Very useful information and very well explained

    thanks Kassy!

  • Peter says:

    Hi, part of our production lines – mixers/paddles are made using steel S275, we have four lines using these mixers so replacing them is not really an option. Producer of these mixers wont’s issue us a statement saying material is fit for food production and we DO NOT have metal detectors/X-ray in place (it’s very unique product). We do not use water as a ingredient, either in these mixers or the product. Any ideas how to go around ‘must be food grade’ ?

    • Kassy Marsh says:

      This is a tricky one, as you can’t prove that the material is suitable for food. The issues are that the material may not be smooth enough to be cleaned correctly and that it may rust. You could prove cleanliness using swabs and you could carry out routine inspections from a rust perspective. I would say that’s as much as you can do. If it’s picked up at audit and your evidence isn’t sufficient, then I’m afraid you would need to look at replacing the food contact elements or coating it with a food grade material.
      Probably not what you want to hear I know…

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