Instructions for HACCP evaluations

Instructions for evaluating chemical risks caused by contact materials

Self-monitoring must cover all contact materials used in a food establishment (for example devices, articles, supplies, surfaces, packing materials).

Chemical risks caused by contact materials must be taken into account in risk assessment (HACCP) that is part of the self-monitoring plan, if said risk assessment is required of the food industry operator. It should be performed especially on contact materials that are meant for long-term storing and for foods that themselves contribute to migration (fatty, hot and sour foods).

Operator assessment on substances with a specific migration limit (SML), contained in the packing materials, should include addressing the following questions:

  • Does the packing material contain SML substances? Are there test results on their migration? Are the results below the limits?
  • If the packaging is formed by two parts, do both parts contain the same SML substance?
  • Is it possible in such a case that the migration limit for the SML substance is exceeded if the substance migrates into food from both parts of the packaging?
  • What preventive or restorative measures have been performed, are performed or can be performed if there is a risk? 

Operator assessment on dual-use additives, contained in the packing materials, should include addressing the following questions:

  • Does the packing material contain dual-use additives, are they mentioned in the declaration of regulatory compliance?
  • If the material contains them, does the declaration of regulatory compliance mention their concentration or migration level?
  • If there is no mention of concentration or level of migration, can the information be obtained from a packing material supplier?
  • Is the use of additives allowed with the packed food or are there restrictions on maximum amounts?
  • Is it possible that a migrating additive could have technological effects on the food? For example, is the migration so low that the additive has no technological effects on the food? Is the level of migration below a maximum amount restriction?
  • If the same additive is also added to the food during processing, assessments are required to clarify whether the total concentration of the additive exceeds maximum amount restrictions.
  • Is the food in compliance with food and additive legislation, despite the migration? Are additives allowed in food at all?
  • Is the additive migration so extensive that the packing material should be defined as an active material?
  • Should the use of additives be mentioned in packaging labelling?
  • What preventive or restorative measures have been performed, are performed or can be performed if there is a risk?
Page last updated 11/28/2018