Food safety and packaging considerations in a post-FSMA world

By Gary Kestenbaum in Food Safety on June 09, 2014

Welcome to the inaugural installment of Packaging Digest’s monthly Food Packaging Safety column. In this and future segments, we intend to discuss aspects of food packaging safety, quality and suitability that are important to those throughout the food packaging community.

There are few in the discipline of food product development and manufacturing who do not live and breathe food safety every day. Incidents involving actual and suspected contamination of food, be they physical, chemical or biological, are mentioned in one or more venues continuously. It is the risk event that makes for sleepless nights.

Based on frequency and degree of harm, many of us in the packaging business have felt immune to the risks of negatively affecting food safety. Somewhere along the line, we have come to the erroneous conclusion that food contamination is caused by something, anything, other than the packaging. We bemoan, “Why we are being held to the same standards as food producers? They are in a different arena, with much greater risks and challenges! We’ve never had a documented incident of our packaging contaminating anything. Why are we forced to throw money and resources that we don’t have to spare, all of a sudden, at this technical issue that WE didn’t cause?”

These are legitimate questions, which deserve answers for clarity and finality, and will be addressed and answered in future columns. It is important to remember that any item or environmental stimulus, edible or not, that enters the confines of a food-producing, transporting or storage facility, has the potential to cause harm, to persons, pets, products and businesses if not vetted and validated for suitability and wholesomeness from a regulatory and industry standards standpoint. This includes animals, vegetables, ingredients, processing and handling equipment, people, vehicles, utilities and, of course, packaging materials.

Before the passage of the Food Safety Modernization Act, and in the days when food safety concern was addressed off stage, we in the packaging industry applied a level of care and concern to packaging that would be considered by today’s standards as “low risk”.  Rarely could one point to a newsworthy incident where a food-borne illness was determined to have been directly caused by contaminated packaging.  Fast forward to 2014 where food packaging safety is no longer a “low risk” concern. Customers, end users, the public and public officials are not impressed by numbers that show our industry to be statistically “squeaky clean” when it comes to causing illness or harm. Whatever sea change has befallen us, it encompasses food packaging and related support items as well as the food within the package. In many companies, secondary (non-food contact) and intermediate (internal) packaging is under the microscope as well, because, as industry experts know, physical, chemical and biological risks are potentially everywhere.

This monthly forum will not dwell on or debate the question of whether the onus placed on the packaging industry is fair or deserved. We will occasionally refer to that aspect, but repeat visitors can expect to see plain-speak and honest talk about food industry, regulatory and customer expectations, best practices, guidance and process. We look forward to your participation, including comment regarding your experiences and questions related to your challenges. Until next month, when we will discuss the effects of FSMA and GFSI on food safety awareness and urgency, safety first!


Gary Kestenbaum has 40 years’ experience in the food and packaging industries, six as a supplier with National Starch, 18 as a product developer with General/Kraft Foods and 15 as a packaging engineer and developer. In his current position as senior food packaging safety consultant with EHA Consulting Group, Kestenbaum provides guidance on packaging safety and suitability--related projects for raw material manufacturers, converters and associated supporting professionals. He can be reached at or 410-484-9133. The website is

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