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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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.
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:
- 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.
- Have on file a Letter of Acceptance (LOA) previously provided by the CFIA;
- 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
- 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.
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:
|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 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.
- 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.
- 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.
Factors to Consider
- 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.
- Determine if the products:
- 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.
- Requesting Letter of Guarantee (LOG) from supplier or manufacturer
- Examples of what to request in a LOG from suppliers or manufacturers can be found in Incoming ingredients, materials and non-food chemicals. When received, keep the LOG from the supplier of the product or material on file.
- 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.
- 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.
- 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
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
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)
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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