Canadian Manufacturing

Proving the safety of food and beverage substances under shifting Health Canada regulations

Manufacturers not always aware of changes to CFIA letters of approval

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Sponsored article by Henkel Canada Corporation

Food and beverage manufacturers are highly attuned to the safety and health impacts of materials and substances used in their operations.

Perhaps more than in any other industry, stringent assessments and due diligence must be conducted before non-food chemicals, packaging materials and building construction supplies are brought into the facility.

Up until recently, such assurance was easily obtained from the Canadian Food Inspection Agency (CFIA), who issued ‘Letters Of No Objection’ for a host of these products. As many manufacturers are by now aware though, a regulatory change in 2014 means new letters are no longer issued by CFIA, so other options must be taken to demonstrate product safety.

In July 2014, Health Canada announced the CFIA no longer requires industry to pre-register construction materials, packaging materials, non-food chemicals and working apparel. In addition, the CFIA no longer has regulatory authority to evaluate or register these materials.

As such, manufacturers like Henkel Corporation can no longer request new Letters Of No Objection from the CFIA for products falling under these categories, including all types of adhesives, thread sealants, threadlockers, silicones, and floor coatings.

While CFIA no longer evaluates and registers these materials, Health Canada will continue to provide Letters of No Objection for food packaging materials and non-food chemicals. Examples of these products include adhesives, lubricants, anti-seize, surface preparation and cleaning products. Health Canada will not, however, evaluate construction materials.

Health Canada defines construction materials as those used for the construction of interior floors, walls and ceilings surfaces, floor coatings and joint sealants used in facilities where foods are prepared or stored.

Non-food chemicals are substances or products 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.

Ensuring safety

Henkel Corporation has closely followed Health Canada and regulation changes through the years, and readily provides guidance to its customers on product selection and certification. Food manufacturers using impacted products may opt to:

• Continue to use products that already have a Letter of No Objection. All of the letters of no objection obtained by Henkel have been posted online. This webpage will continue to be updated as new letters arrive from Health Canada.
• Have on file a Letter of Acceptance (LOA) previously provided by the CFIA;
• Have on file a Letter of Guarantee (LOG) from the supplier of the product or material.

The CFIA requires Letters of Guarantee for non-food chemical products coming into contact with food or food contact surfaces contain:

• The identification of the non-food chemical product by brand name or code number;
• A statement that the non-food chemical product is safe and suitable for use as intended in food establishments;
• A statement that the firm will provide, when requested by the CFIA, all supporting documents to demonstrate the product is safe and/or suitable for use as intended;
• Directions for use in food establishments including any pertinent limits, or reference to label instructions, if information regarding directions for use is available on the label
• The signature of the firm providing the letter of guarantee.

Proven products

As a trusted supplier to the food and beverage industry, Henkel provides high-performance products to solve daily maintenance and production challenges. Its cutting-edge products offer a comprehensive breadth of the most relevant agency approvals and certifications, such as FDA and ANSI.

LOCTITE maintenance products are proven to:
• Extend processing equipment life;
• Increase line efficiency;
• Improve operator safety and product quality;
• Improve plant hygiene;
• Reduce operating costs.

LOCTITE 2046 for instance, is the only threadlocker compliant with FDA food additive regulations. In today’s high-speed fluid-filling lines, loose fluid-filler valve head cover bolts can cause product damage, unscheduled line shutdowns, and even product contamination.

LOCTITE 2046 may be used as a strengthening or coupling agent for joints on food processing equipment that may contact all types of food, in full compliance with the Federal Food, Drug, and Cosmetic Act, and all applicable food additive regulations.

Another example of how Henkel products comply with a range of industry-accepted standards and certifications is the LOCTITE 567 Thread Sealant. It complies with NSF / ANSI 61 for drinking water system components.

LOCTITE 567 has excellent solvent resistance, allows easy assembly, prevents galling and can withstand temperatures up to 400°F (204°C). The product is excellent for high- pressure applications such as locks and seals, tapered metal, pipe threads and fittings.

Henkel offers hundreds of non-food substances and construction materials already accepted by the CFIA and in numerous other cases, can demonstrate products’ adherence to the most important and widely-recognized industry food safety standards.

For more information on the Government of Canada’s regulations, please visit this federal web page.

For more information on products for your food and beverage operations contact a Henkel Adhesive and Sealants Specialist at 1-800-263-5043 or visit Henkel’s web site.

To view more articles from Henkel Canada, see the Productivity Success Centre.

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