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

Although the Safe Food for Canadians Regulations (SFCR) came into force on January 15, 2019, certain requirements may apply in 2020 and 2021 based on food commodity, type of activity and business size. For more information, refer to the SFCR timelines.

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Introduction

Food businesses are responsible for ensuring 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 businesses are also required to meet all applicable regulatory requirements of the Food and Drugs Act, the Food and Drug Regulations and the Safe food for Canadians Act and Regulations.

This guidance is intended to provide food businesses with some recommended options to demonstrate the safe use of construction and packaging materials, and non-food chemical.

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 which were previously included in the Reference Listing of Accepted Construction Materials, Packaging Materials and Non-food Chemical Products, provided:
    • the product continues to be used for the intended and previously accepted use(s) (formulation, label directions, etc.), and
    • the manufacturer continues to support the product for this use.
  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.

Keep in mind!

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 were previously found by the CFIA to be acceptable for a specific use.
The CFIA no longer pre-approves such materials and products. The reference listing is now available as a reference only. The last update to the listing was made in January 2016.

As the list is no longer maintained, it is recommended that you verify the accuracy of the information with manufacturers.

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

Note - The Check checkmark in this table indicates a recommended practice. The X mark is used to indicate when the specific option is not applicable.

Material Type Included in the Reference Listing and verified with Manufacturer 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:

X X Required
Check
Optional to retain in addition to a Health Canada LONO
Processing aids used as carcass washes Table Note 2 Check Check Check Optional to provide/retain in addition to a Health Canada LONO
Non-food chemicals (cleaners, disinfectants, sanitizers, etc.) Check Check Check Check
Food packaging material (wraps, trays, pouches, etc.) Check Check Check Check
Food-contact work apparel Table Note 3 (gloves, aprons, etc.) Check Check Check Check
Construction materials Table Note 3
(interior floors & walls, coatings, etc.)
Check Check X Check Table Note 3

Table Notes

Table Note 1

The Food and Drug Regulations require mandatory Health Canada pre-approval or pre-market notification of packaging materials used in infant formula, or in a novel process More information can be found on the Packaging Materials page on Health Canada’s website.

Return to table note 1  referrer

Table Note 2

It is a recommended practice for all food businesses to get a voluntary assessment from Health Canada for the processing aids they use. Refer to: Health Canada's policy on differentiating food additives and processing aids.

Return to table note 2  referrer

Table Note 3

The CFIA no longer issues LOAs for food-contact work apparel or construction materials. Previously issued letters will remain valid as long as the chemical composition, the product's name, the name of the manufacturer or the name of the registrant, the intended use and, when applicable, its labelling content remain unchanged and/ or any new scientific documentation shows no potential health risk from its intended use.

Health Canada does not issue LONOs for construction materials.

Please note: It is a recommended practice for all food businesses to retain documentation about the safe intended use of food-contact work apparel and construction materials in the form of a manufacturer/supplier's Letter of Guarantee.

It is important to retain LOG for any product that is not covered by a previously issued LONO or included in the Reference listing. The LOG must be included in your Preventive Control Plan. Details on the minimum information that should be captured in the LOG can be found in Incoming ingredients, materials and non-food chemicals.

Return to table note 3  referrer

Factors to Consider

  1. Gathering the key information
    • Determine if the products:
      • were previously pre-approved by the CFIA or Health Canada,
      • are included in the Reference Listing, if they will continue to be used for the intended and previously approved use (formulation, label directions, etc.), and
      • if the Manufacturer continues to support the product for this use.
    • Check to see if:
      • 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;
      • you need a LONO from Health Canada;
      • 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. Demonstrating the safe use of the construction and packaging materials, and non-food chemicals
    • 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 If the safety assessment indicates potential food safety issues, the CFIA will take appropriate compliance actions.

Definitions

Establishment

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

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
see SFCR definition for Package (noun)
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.

References and Further Reading

CFIA Website

Incoming ingredients, materials and non-food chemicals

Infant Formula Pre-market Notification

Health Canada Website

Reference Listing of Accepted Construction Materials, Packaging Materials and Non-food

Chemical Products

Packaging Materials

Food Processing Aids

Guidelines for Incidental Additive Submissions

Information Requirements for Food Packaging Submissions

Pesticides and Pest Management

Policy for Issuing an Interim Letter of No Objection (iLONO) for a Food Processing Aid

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

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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