The Tech Box

The Tech Box – September 2022

Packaging and Food Safety

September is National Food Safety Education Month (FSEM). Consumers are encouraged to take an active role in preventing foodborne illness by following proper food safety practices that can help lower their chance of getting sick. It’s also a great opportunity to remind consumers about the important role that packaging plays to keep goods clean and safe on their journey to consumers, whether it’s to their favorite restaurants and stores, or to their front doorsteps.

Fresh produce has been documented by the US Center for Disease Control and Prevention (CDC) as a leading source of food-borne illness (CDC, 2015). With the passage of the US Food Safety Modernization Act (FSMA) in 2011, the supply chain has become an even greater source of scrutiny for growers, shippers and retailers. FSMA now requires US entities to take a proactive rather than reactive approach to food safety (US FDA, undated).

Food-borne illness has not been directly associated with shipping and transport containers. But our industry has done our due diligence by

conducting multiple independent studies

, which confirm that corrugated containers that transport fresh produce are safe and clean.

There are a combination of United State Department of Agriculture (USDA) and U.S. Food and Drug Administration (FDA) requirements that must be met for compliance with food packaging regulations. While you may think you’re not involved since the regulations are specific to direct food contact, your customers may assume it includes all packaging. This means it helps to be knowledgeable on the subject.

Two FAQs on the Fibre Box Association (FBA) website,




, provide specific information on what you need when a customer asks for certification of compliance with food safety requirements. If you aren’t part of a direct food contact program, since neither the USDA nor the FBA certify or approve packaging materials, box plants must self-certify with a Statement of Assurance, or with a “Continuing Product Guarantee.” Please see the FAQs for specific details.

PFAS, synthetic chemicals known also as per- and poly-fluoroalkyls, have been regulated lately in at least 21 states. This includes 6 states where their sale or manufacture has been restricted or banned from food and/or consumer products and packaging, according to the NCSL (

National Conference of State Legislatures



EPA regulation

focuses on drinking water and waste management/treatment. However, FDA scrutiny is on food packaging. “Conducting regular self-audits for possible exposure to PFAS risk and potential regulatory violations can result in long term savings for companies and should be commonplace in their own risk assessment.” (

FDA PFAS Action Targets Food Packaging

, July 21, 2022,

The National Law Review


Find out whether your vendors of inks, special (hot melt) adhesives and treatments or coatings have tested their products for total organic fluorine content, which is considered the simplest way to assess a material’s total PFAS content. Or ask for assurance that PFAS haven’t been intentionally added. Those are the probable inputs of PFAS to your products, if any.


Mary Alice