What? Why would food-grade not be food-safe? What is the difference between food-grade and food-safe? Doesn’t it mean the same thing? These may be some of your initial thoughts. So, what is the difference between food-grade and food-safe? Food-grade means that the material is fit for human consumption or permitted to come in contact with food. 21 CFR 174-178 for example, can be used to verify if a component is an appropriately regulated indirect additive and considered GRAS (Generally Recognized as Safe) for its intended use. But are food contact materials sometimes utilized for something other than its intended use? You bet your 483 they are. This is an important component that is often overlooked. Just because that material is permitted to come in contact with food, it doesn’t necessarily mean it is food-safe. Food-safe means that the food-grade material is also fit for purpose for its intended use and will not create a food-safety hazard. For example, it may be fit for purpose to use a food-grade container to hold a dry ingredient but that same container may not be fit for purpose to be used to hold a hot liquid. Section 117.40 in Subpart B of FSMA states: “Food-contact surfaces must be made of nontoxic materials and designed to withstand the environment of their intended use and the action of food, and, if applicable, cleaning compounds, sanitizing agents, and cleaning procedures”. Processors will be called upon more than ever to prove that food contact materials are indeed safe and “fit for purpose” or safe for its intended use. The practice of simply having a certificate of conformance stating that your food contact materials are food-grade will likely no longer be good enough. If you are familiar with GFSI and its standards, you already know that simply having a certificate of conformance for food contact materials is unacceptable if the manufacturer/supplier doesn’t acknowledge that the material is safe to use under the conditions in which you will use them (i.e., for its intended use). So, asking your supplier a few more questions about your food contact materials can go a long way when conducting an in-depth hazard analysis and a food-safety risk assessment. Some common questions are:
- What is the recommended safe temperature range for this material?
- Is this material safe for the type of food that it is contacting (i.e., fat percentage, pH, moisture percentage, etc.)?
- Will the material physically hold up to the manufacturing environment for which it is being used?
You also need to think about how the material is constructed. Does it have pieces/parts that can be accidently removed during use, such as a pail with an attached handle that often falls apart and can potentially make its way into the product stream? Or maybe a cleaning brush that often loses its bristles. Does the material/equipment have seams, and are those seams smooth and cleanable? When evaluating equipment, always make sure it is designed for the intended use. If equipment is not designed for its intended use, it can often render it ineffective and depending on how critical the process, significantly increase a food-safety risk. Choosing materials that are “food-safe” can be just as important as choosing materials that are “food-grade”.
Have you ever heard someone say “it’s only a trash can if you put trash in it”? What does that mean exactly? It usually means that containers designed for trash may be used to hold food ingredients or products intended for human consumption. What is the potential risk in that situation? Is that container safe for food contact? It is obviously not the intended use and adulterated product may be the end result. So how does someone determine if the food contact material is “food-safe”? There are several third-party certification companies that verify food equipment and/or food contact materials are indeed “food-safe”, including HACCP International, NSF and 3A. If the material or product that you are evaluating does not have one of these certifications, then the burden is on you to properly risk assess the potential hazards of your operation and to prove to your customers and regulatory bodies that your process is food-safe. So, during your next food-safety team meeting, challenge your team members to take a good, hard look at everything that comes in contact with the food stream and ask, “is this truly ‘food-safe’?”