Guidance for Food Establishments Concerning Construction Materials and Packaging Materials and Non-Food Chemicals

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1. Introduction

Food establishments are responsible for demonstrating to CFIA inspectors that the construction materials, packaging materials and non-food chemicals used in their facilities are safe and suitable for their intended use. This is an essential part of good manufacturing practices to prevent the contamination or adulteration of food products from these materials. Food establishments are also required to meet all applicable regulatory requirements, including Division 23 of Food and Drug Regulations for packaging materials and Section 4(1) of the Food and Drugs Act for non-food chemicals.

This guidance is intended to provide regulated parties with information regarding the different options for demonstrating the safe use of construction and packaging materials, and non-food chemicals that will be used in their facilities. The Reference Listing of Accepted Construction Materials, Packaging Materials and Non-food Chemical Products is no longer the exclusive means to show acceptability.

2. Background

The Reference Listing of Accepted Construction Materials, Packaging Materials and Non-food Chemical Products (otherwise known as the Reference Listing) is a list of construction materials, packaging materials and non-food chemicals which have been found by the CFIA to be acceptable for use in establishments operating under the authority of the Agency. Many of the existing CFIA food commodity manuals and other documents have direct links to the Reference Listing. The primary purpose of this listing was to provide a ready reference, for both CFIA Inspectors and establishment staff, of the products that had been submitted and accepted for a specific use.

As of July 2nd 2014, the CFIA no longer evaluates materials for inclusion in the Reference Listing. All construction material submissions and submissions related to gloves, aprons etc. that are currently in process will be completed by the CFIA. Any new submissions received on or after July 2nd 2014 will be returned as the Reference Listing will not be further amended with any new entries. The previously evaluated information contained in this database continues to be validFootnote 1and made available on the CFIA website.

3. Options

Depending on the type of material or chemical being used and their potential hazards/risks, there are a series of options that should be considered. These options, elaborated in the table below, include:

  1. Continue to use products that are already are included in the Reference Listing, provided they continue to use the product for its intended and previously accepted use(s) (formulation, label directions, etc.)
  2. Have on file a Letter of Acceptance (LOA) previously provided by the CFIA;
  3. Have on file a Letter of No Objection (LONO) from Health Canada for the product used. Note that Health Canada will continue to assess packaging materials and non-food chemicals (not construction materials) on a voluntary basis if requested by industry; and/or
  4. Have on file a Letter of Guarantee (LOG) from the supplier of the product or material.

Table 1: Summary of Options to Demonstrate Safe Use of Construction and Packaging Materials and Non-Food Chemicals for Food in Canada

Note - The checkmark checkmark in this table indicates that any one option is acceptable. The X mark is used to indicate when the specific option is not applicable.

Options to Demonstrate Acceptability and Safe Intended Use
Material Type Included in the existing CFIA Reference Listing Previously issued CFIA Letter of Acceptance (LOA) Health Canada Letter of No Objection (LONO) Supplier or Manufacturer Letter of Guarantee (LOG)
Food packaging material used:
  • for infant formula or,
  • as part of a novel processFootnote 2
X X checkmark Optional to provide/retain in addition to a Health Canada LONO
Processing aids for use in federally registered meat establishments (carcass washes)Footnote 3 checkmark checkmark checkmark Optional to provide/retain in addition to a Health Canada LONO
Non-food chemicals (cleaners, disinfectants, sanitizers, etc.) checkmark checkmark checkmark checkmark
Food packaging material (wraps, trays, pouches, etc.) checkmark checkmark checkmark checkmark
Food-contact work apparelFootnote 4 (gloves, aprons, etc.) checkmark checkmark checkmark checkmark
Construction materialsFootnote 4
(interior floors & walls, coatings, etc.)
checkmark checkmark X checkmark Required for meat establishments only; recommended best practice for all othersFootnote 4

4. Factors to Consider

  1. Gathering the key information
    • Determine if the products are already pre-approved by the CFIA or Health Canada and are included in the Reference Listing, and if they will continue to be used for the intended and previously approved use (formulation, label directions, etc.).
    • Check to see if:
      1. you already have a Letter of No Objection (LONO) or Letter of Acceptance (LOA) on file, previously issued by Health Canada or the CFIA for the product used;
      2. you need a LONO from Health Canada;
      3. you need a Letter of Guarantee (LOG) from the supplier of the product or material.
  2. Requesting Letter of No Objection from Health Canada
    • Review information about how to request a LONO from reference links available on Health Canada's website.

      Note: Health Canada will continue to assess packaging materials and non-food chemicals (but not construction materials) on a voluntary basis. Refer to the Health Canada website references for more information regarding submissions for mandatory and voluntary assessments.

    • When complete, keep the LONO on file.
  3. Requesting Letter of Guarantee (LOG) from supplier or manufacturer
  4. Preparing for Follow up Verification of Compliance
    • Have all letters and documentation pertaining to construction materials, packaging materials and non-food chemicals accessible and up to date for CFIA inspectors who may, from time to time, verify that the materials being used are compliant with all applicable regulatory requirements.
    • Where there are reasonable doubts about the safety of any products used, CFIA inspectors may request additional supporting documents with which to conduct a more in-depth review to verify that the products meet all applicable regulatory requirements, including Division 23 of Food and Drug Regulations for packaging materials and Section 4(1) of the Food and Drugs Act for non-food chemicals. If the safety assessment indicates potential food safety issues, the CFIA will take appropriate compliance actions.

Annex 1: Definitions

Food Establishment
can include any industry involved with food manufacturing, processing, treating, preserving, grading, packaging, labelling and slaughtering of animals from which meat products may be derived. Note any industry that is involved with the manufacture of food packaging materials should also be aware of any criteria that may apply to the materials that they may be using too.
Construction Materials
are defined as materials used for the construction of interior floors, walls and ceilings surfaces as well as any coatings and joint sealants that are used in facilities where foods are prepared or stored. Examples: Coatings for wall, ceiling, floor, wall and ceiling panels, pipe covers, door etc.
Non-Food Chemicals
are defined as substances or products that are used in processing plants. Although their intended use is not to become part of the food product, these chemicals may find their way into foods during production. These substances or products are termed as "incidental additives" by Health Canada and fall outside the current interpretation of the regulatory definition of a food additive. Examples: cleaners, lubricants, disinfectants, barrier creams etc.

Note: pest control products do not fall within scope of this document as they need to be registered by Pest Management Regulatory Agency.

Novel Foods
are defined as products that have never been used as a food; foods which result from a process that has not previously been used for food; or foods that have been modified by genetic manipulation. Example: high pressure processing etc.
Packaging Materials
are defined as products that are used to wrap, cover, hold, or protect food products and are intended to come in direct or indirect contact with food. Examples include, paper wraps, wrapping materials, films, synthetic casings, nettings, trays, pouches, cartons, cardboard boxes with coated surface and bags. Any equipment or storage material, which may come in direct contact with foods, also falls within this definition of packaging materials.
Food Processing Aids
are defined as substances used in or on food for a technical effect during processing or manufacture. Its use does not affect the intrinsic characteristics of the food and results in no or negligible residues of the substance or its by-products in or on the finished food. Examples: antifoaming, filtering aids, certain microbial substances etc.
Food Safety Enhancement Program (FSEP)
A CFIA program that specifies the minimum requirements for an effective food safety management system based on HACCP principles and encourages its development, implementation and maintenance in all federally registered establishments, excluding federally registered fish establishments which are subject to the requirements of the Quality Management Program.

Annex 2: References and Further Reading

CFIA Website

The Reference Listing Database

FSEP Manual B.2.1 Purchasing/Receiving/Shipping Requirements - Letters of Guarantee

Infant Formula Pre-market Notification

Health Canada Website

Guidance for Industry on Novelty Determination of High Pressure Processing (HPP) - Treated Food Products

Guide for Preparing Food Processing Aid Submissions

Guidelines for Incidental Additive Submissions

Information Requirements for Food Packaging Submissions

Pest Management Regulatory Agency (PMRA)

Technical Consultation - Policy Intent for Issuing an Interim Letter of No Objection (LONO) for Processing Aids

Guidelines for Cosmetics Manufacturers, Importers and Distributors (for hand cleaners, barrier creams)

Health Canada Contact Address for Letter of No Objection submissions

Food Packaging Materials & Incidental Additives Section
Chemical Health Hazard Assessment Division
Health Canada
251 Sir Frederick Banting Driveway
Postal Locator 2201C
Ottawa, Ontario, K1A 0K9
Canada
Email: FPMIA-MEAAI@hc-sc.gc.ca

Telephone: 613-952-4026

Other References

Canadian Centre for Occupational
Health and Safety

MSDS (Material Safety Data Sheets) Database

United States' Website

Federal Food, Drug & Cosmetic Act (for export purposes only)

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