Contaminants

A Weed is just a misplaced plant

bee-549221_1920The Foodstuffs, Cosmetics and disinfectants Act No. 54 of 1972 [1] requires that food marketed to humans is not injurious to health. This is a “catch all” statement – so where no specific regulation exists, in court the onus would be on the producer to ensure the food is safe for human consumption.

Codex defines a contaminant as “Any substance not intentionally added to food or feed for food producing animals, which is present in such food or feed as a result of the production (including operations carried out in crop husbandry, animal husbandry and veterinary medicine), manufacture, processing, preparation, treatment, packing, packaging, transport or holding of such food or feed, or as a result of environmental contamination.” Interestingly they exclude physical contamination such as insect fragments and rodent hair. (CODEX STAN 193-1995)

Currently there are many South African regulations that deal with contaminants including: heavy metals (R500 of 2004), pesticides (R246 of 2005) colourants (R1008 of 1999), hydrocarbons (R230 of 1977) and toxins; even allergens in the labelling regulations (R146 of 2010) could be classed under contaminants.

Rather than expecting a complete absence of a contaminant, regulations often state a permissible level for a specific food group, or all foodstuffs. So it is vital to understand that if a limit exists in a certain product group, this does not mean that other groups are not regulated. Thus, other groups should not contain the contaminant. For example preservatives are permitted in certain food categories, but considered contaminants in similar categories.

This was certainly true for the Pimaricin in export wine case (2009). Pimaricin, commonly used to preserve fruit juices and fruit concentrate was found in some export wines; it was present due to the addition of grape concentrate, occasionally used in the winemaking process. Although allowed in South African wines it is prohibited in some countries.

In some cases regulations do not exist for contaminants, either as the need for regulation has not yet arisen, or because no amount of contamination should be allowed. Two examples that illustrate this point are Sudan red and melamine. When these scares hit in 2005 and 2008 respectively, industry started looking for regulations specifying limits for these compounds.

Sudan red is a colourant used in various industries mainly oil and gas, and should never be in contact with food. As such, there was, and still is, no need for it to be specifically legislated. No amount of Sudan red would be safe for consumption.

For melamine, no legislation existed at the time, but now R1054 of 2009 is in place. Apart from adulteration and food fraud, melamine may also come into contact with food through use of certain containers. Prior to this regulation the onus would have been on the producer to prove that a small amount is firstly safe in the product and secondly present purely due to unavoidable circumstances.

Whether added or unintentional, if it is harmful or not permitted, much like ‘a weed is just a misplaced plant’, these substances if present in foodstuffs are contaminants.

Article by: Norah Hayes

Footnote:
1. Regulations are listed under number and year of first print and should include all subsequent amendments.

Suppliers

My supplier did what?

Many manufacturers are unaware of the extent to which the safety of their end product is dependent on their suppliers. Like the man in the image to the left, each producer in the food chain plays a vital role in holding the chain together to maintain food safety and legality of the end product.

As a food manufacturer you may have asked yourself questions to the tune of “I produce chocolate brownies, why should I worry about pesticides or heavy metals!” – The problem is that our suppliers often aren’t aware of the legal limits of contaminants related to their products. This is often exacerbated when buying raw materials from distributors or importing products, as these legal limits sometimes differ from country to country.

It is important to realise that these limits set by the South African government are not guidelines and that it is a criminal offence to sell product that does not meet the legal limits. Ultimately the onus is on the manufacturer to ensure that their supplier provides them with product that is safe and legally compliant.
So what’s the solution? Firstly, know the legal limits of the products being supplied to you, and secondly if your supplier is supplying product that is legal. To assist producers a set of tools are available to monitor and manage suppliers and include product specifications, certificates of analysis (CoA), supplier assessments, questionnaires, audits and lab tests. To be effective these tools require you as the producer to know what questions to ask your suppliers. Let’s take a brief look.

First, what are the legal limits? We will cover some of the regulations in this issue of Chimera News, but if you have specific questions about the regulations for your product, give us a call.

Ask your suppliers for a specification for each product they supply you with. At minimum these will contain the ingredients, allergens and legal limits for contaminants applicable to the product.

Request a CoA for each batch of product. This is a record showing that the product conforms. If legal limits exist these must appear on the CoA or a laboratory report issued with the CoA.

Supplier assessments, questionnaires and audits assess the supplier’s level of compliance to food safety standards. Ask your supplier what food safety certifications they have, if any, and if they comply to good manufacturing practices (GMP).

Lastly, lab tests can be used to verify conformity, but are expensive and most effective when combined with a risk assessment to determine products that are at greatest risk. Where possible place the responsibility for raw material testing on the supplier.

These are just some of the tools available to help producers manage their end of the supply chain more effectively.

Article by: David James Scott

Contaminants

What are food contaminants?

Agricultural contaminants, environmental contaminants and adulterants, these can be considered as the three main sources of food contaminants. The agricultural contaminants include pesticides and veterinary drugs. Environmental contaminants are those chemicals transferred to food during growing, processing, packaging, storage or distribution; these include heavy metals, mycotoxins, histamine and chemical toxins. Adulterants are substances intentionally added to foodstuffs that are either harmful to the consumer, illegal present or constitute food fraud.