Food packaging safety expert Gary Kestenbaum offers considerations and suggestions for a corporate strategy to address negative publicity and public perception of your packaging.
Recent and not-so-recent articles have appeared in mainstream media regarding food packaging safety, targeting the use of fluorinated additives that present a confusing soup of chemical acronyms (PFOA, PFOS, PFAS, PFC and others) on food contact packaging with a focus on fast food.
Based on the tone of the articles and video news briefs, I suspect the media targeted fast-food applications rather than retail grocery items because media graphics and “teasers” of trendy, iconic well-known fast food brands generate instant viewer/reader attention.
The stories were virtual clones of one another, typical of sensational stories linked to food and packaging safety along the lines of “Do you know what’s in your [blank]?” All led with close-up photos of a fast-food burger contained within a paper wrapper, sometimes accompanied by a paperboard container of fries. The rhetoric began with a general question of food packaging safety and then referenced fluorinated additives, followed by a brief description of the components, their application and broad usage. Sound bites, quotes and comments from health agencies, related organizations and consumer safety groups were added to create or maximize the atmosphere of concern, fear and worry.
The domino effect
This style of reporting had me recalling similar experiences with the safety of food additives being called into question in the 1970s, when chemicals used in the process of food starch modification came under industry scrutiny. The minute that customers ultra-sensitive to negative consumable product publicity—baby food manufacturers, as a prime example—were connected to the use of starch products utilizing these “named” process chemicals, they instantly ceased use and returned all the bagged starch inventory to the supplier. The domino effect was amazing, even before the advent of the internet. Suddenly, the entire custom food starch industry came under pressure to replace said modifying agent with effective alternatives capable of passing an objective, consumer-friendly safety test. “Effectiveness” in the food industry is in the eye of the purchaser, and as you know, a supplier cannot just show up at the customer’s door one day with an untested replacement and begin taking orders.
Factored into the equation is also the importance of any scrutinized component or processing aid linked with the ability of the user to stay in production. In the case of the baby food manufacturer, they switched to native (unmodified) starch and lived with the impacts to end-product texture.
Another well-known example involves an ingredient that consumer health watchdogs love to target: food grade azo dyes, also known as F,D&C or certified colors, used in numerous products. These additives appear on consumer and scientific watch lists, and media health risk-related blitzes reoccur periodically. When that happens, manufacturers and users alike sweat out the criticism and negative press. Some heavy users of food azo dyes visit and revisit alternative colorant options in the event certified colorants become restricted by regulation. Business plans may not be perfect, but they are developed and updated in ways that allow manufacturers to switch products, processes or components and, thus, stay in production in the event of regulatory action.
So, too, has the packaging industry been affected by callouts of fluorocarbons and phenolic compounds, bisphenol-A (BPA) most notably. Following a recall or market withdrawal, products, compounds and brands can be at risk, typically for the short term.
Food risk vs. food packaging risk
Where comestible additives typically differ from food-contact packaging additives is in actual harm and risk perception. In my experience, consumers tend to pay closer attention to news of possibly contaminated food more so than news of potentially contaminated packaging. Aside from broken glass and similar harmful packaging fragment-related defects, they perceive comestibles as having higher safety-risk potentials than do the product packaging. Microbiologically-based events—salmonella, listeria monocytogenes, E. coli, etc.—represent tangible, instant harm risk to consumers and call for immediate and definitive action within the supply chain. Typically, food packaging additive-related events are not treated with the same level of action and fear because they fail to represent unquestioned toxicity or immediate, clear risk. Opponents charge that they may represent health risks over time, based on frequency of use, intake, body mass of the typical user and breadth of availability in the industry.
Most packaging chemical component negative press is limited. Manufacturers and users know that they must react responsibly to consumer backlash and regulatory scrutiny. Manufacturers may hastily assemble task forces to quickly develop internal strategies to identify targeted at-risk items and replace them as soon as possible with credible, effective alternatives. Often, that replacement schedule is derailed, halted or discontinued because the publicity diminishes and then, in time, ceases.
Specific to fluorinated additives and their uses in fast-food primary packaging, articles academically posed the question “why not just use something more basic with which everyone is familiar?” for example, waxed paper. One simplistic, but accurate response is that the wax for coating paper may be sourced from paraffin or microcrystalline wax. Both are hydrocarbons associated with well-documented articles describing the effects of frequent contact and non-contact exposure to hydrocarbons and other volatile organic compounds.
Classic example: Reverse decision U.S. vs. Canada
When debating the wisdom or value of switching to alternative food or packaging additives, consider a classic example of action-for-action’s sake, i.e., the debate on the safety of the sweetener sodium saccharine (allowed to remain in use in the United States as an artificial sweetener) vs. the alternative, sodium cyclamate. Pressured to act to uphold the intent of the language in 1958 amendments to the Federal Food, Drug and Cosmetic Act (also known as the “Delaney Clause”), FDA chose to remove cyclamate from the list of approved food additives. Canada’s regulators looked at the same data, interpreted it, then applied an opposite approach, banning sodium saccharine and allowing the use of sodium cyclamate.
The point is, today’s alternative “savior” may become tomorrow’s villain. Allowable ingredient options in the United States may be considered violative in other countries. The sensible way to address these food packaging additive safety “grenades” is to anticipate, evaluate and act with practical alternate strategies rather than with fear.
Users of food packaging well-position themselves when they build for the future based on knowledge, background, awareness, risk potential and alternatives. Here are 5 key guidelines:
- Know what components are in your packaging.
- Understand valid health risks and regulatory implications of components contacting or migrating into the food inside the package.
- Quantify and qualify the risk potential for migratory and sensory impacts.
- Align with suppliers who share your knowledge and concern, capable of testing safer and effective alternatives.
- Plan to test and evaluate practical alternatives which can be quickly integrated.
Finally, develop a practical, cross-functional decision tree describing how the organization will react if components, additives, ingredients or processes come under scrutiny. Some organizations choose to stay the course and weather the storm. Others conclude that targeted replacement projects must be initiated and integrated to protect the integrity of the business. Whatever the objective, make sure that your organization has one which protects consumer health and safety, as well as corporate reputation, in that order.
Gary Kestenbaum has 40+ years’ experience in the food and packaging industries including 6 as a supplier with National Starch, 18 as a product developer with General/Kraft Foods and 15 as a packaging engineer and developer with Kraft. 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 firstname.lastname@example.org or 410-484-9133. The website is www.ehagroup.com.
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