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Good manufacturing practices for food contact materials:
■ Required for food contact materials throughout the world□ U.S. FDA 21 CFR 174.5□ EU Commission Regulation (EC) 2023/2006□ Etc.
Good Manufacturing Practice (GMP)
GMP includes:
■ Preventing contamination and cross-contamination■ Clearly defined and controlled manufacturing processes■ Clean manufacturing, packaging and storage facilities■ Operator training■ Corrective action plans■ Collection and retention of appropriate documentation■ Auditing, as needed
■ Primarily apply to North American compliance■ Are industry self-enforced, but open to government inspection■ Require statute-based compliance
□ U.S. FDA 21 CFR & GRAS substances “generally recognized as safe”□ Canada Safe Food for Canadians Act (SFCA)□ USDA & National Sanitation Foundation (NSF)
■ Based on positive (acceptable) and negative (unacceptable) substance lists■ Require GMP ■ Require documentation
What if the material is not specified as being food grade?
■ Ask the vendor if they have a food grade alternative■ Ask the vendor whether they have previously investigated food use■ Ask the vendor for a full formulation disclosure for third-party review
When should I consider a risk assessment?
■ If the material (e.g. ink) contains proprietary substances■ If the material is questionable for food safety ■ Should be performed by a competent third-party service
