1.3 Food Grade Materials
Subsections 6(2) and 6(3) of the amended O. Reg. 119/11 require that all equipment, utensils, containers or other food contact surfaces are constructed of food grade material that is non-toxic and that will not cause or contribute to their contamination. These subsections are in addition to the requirements of subsection 4(1) that prohibits the selling, packing or transporting of any maple product that is contaminated and subsection 4(3) that prohibits the mixing of contaminated maple product with maple product that is not contaminated.
- 1.3.1 Background
- 1.3.2 Food Grade Material Criteria
- 1.3.3 Non-Food Grade Materials
- 1.3.4 Food Grade Materials
- 1.3.5 Food Grade Materials Summary
Food contact surfaces must be constructed of materials that protect the safety and quality of maple products. It is essential that equipment, utensils, containers etc. that come into contact with maple sap or maple products are appropriate for their intended use and do not create a food safety hazard or alter the composition and/or sensory characteristics. In addition, the materials must not be adversely affected by the associated collection, production, packing or storage environment.
A number of factors must be considered to determine the most appropriate food grade material. For example, while food grade plastic is appropriate for consumer containers from a food safety and quality standpoint, it is not appropriate for equipment or utensils intended for use in a high temperature environment (e.g. evaporator pans).
Lead is a significant risk to consumer health. There is a direct correlation between the amount of lead in equipment used for collection, storage, and processing of maple sap/syrup, the length of maple product exposure to this lead, and the lead content of maple products.
Evaporators, metal storage tanks and filling units manufactured before 1995, even those constructed of stainless steel, used tin/lead solder for seams, as did galvanized equipment manufactured before 1994. Terneplate, another tin/lead alloy, was used as a coating for sap collection buckets and eight gallon milk cans. Brass and bronze, sometimes used in the construction of maple equipment fittings and in sap/syrup pumps, are alloys that may contain small amounts of lead. Some of this lead-bearing equipment is still being used for maple syrup production and/or storage. Use of any equipment containing lead that contacts sap or maple products during collection, storage, transportation, production or packing must be discontinued by January 1, 2018.
Standards for materials used in food applications may be determined by compliance agencies such as Health Canada or the United States Food and Drug Administration. Where there are no regulations, standards setting organizations such as NSF International and the American National Standards Institute have developed voluntary standards that are widely accepted throughout the world.
Piping and/or tubing used to transfer maple sap or maple syrup must not contaminate these food products during processing and must be able to withstand repeated cleaning and sanitizing. All plastic pipe used in these applications must be food grade or suitable for potable water at its intended operating temperatures. Potable water pipe requirements have been determined by NSF/ANSI and carry their designations, as listed in section 1.3.4.
Subsection 4(1) of O. Reg. 119/11 prohibits the sale of maple products that are contaminated. Subsection 4(5) defines "contaminated" as any maple product that contains or has been exposed to a hazard (such as lead) that may directly or indirectly cause the maple product to be unsafe for human consumption.
Subsection 6(2) of the amended O. Reg. 119/11 requires that, "Every person who operates premises at which maple products that are intended to be sold are produced or packed shall ensure that all equipment, utensils, containers, and other food contact surfaces that are used during the production or packing of maple products and will come into contact with the maple products during their production or packing, are made of food grade material that is non-toxic and that will not cause or contribute to the contamination of the maple products.
Subsection 6(3) of the amended O. Reg. 119/11 requires that, "Every person who collects, stores or transports maple sap for use in maple products that are intended to be sold shall ensure all equipment, utensils, containers and other food contact surfaces that are used during the collection, storage or transportation of the maple sap are made of food grade material that is non-toxic and that will not cause or contribute to the contamination of the maple sap".
Requirements of Section 6(2) and 6(3) will be met when materials used in equipment, utensils, containers and other food contact surfaces that are intended to come into contact with maple sap or maple products are:
- appropriate for intended use; suitable for the activity being conducted and the environment in which it is being conducted
- non-toxic; surfaces and coatings are free of lead solder, lead, and/or lead-containing alloys or other toxic components likely to contaminate food
- non-porous/non-absorbent; to prevent contaminants such as chemical residues, mould spores, etc. being trapped/absorbed/transferred to sap or syrup
- smooth; surfaces are free from pitting, cracks, crevices, open seams, holes, corrosion, loose scale, peeling paint, etc.
- corrosion resistant in the intended end use environment
- inert; does not chemically react with, or leach into maple products, does not react with cleaning chemicals, etc.
- durable; able to withstand repeated cleaning and sanitizing without surface degradation
- cleanable; does not harbour bacteria or cleaning and/or sanitizing chemicals
- non-breakable; will not create a physical hazard
- kept in good repair and properly maintained
Materials that do not meet these criteria may transfer contaminants to maple products, adversely affecting their safety and quality. Beginning on January 1, 2018, materials that do not meet these criteria are also non-compliant with the requirements of O. Reg. 119/11.
Below is a partial list of materials sometimes found in maple equipment that do not meet food grade criteria.
- Terneplate (a tin/lead alloy coating with up to 85 percent lead)
- Lead solder (a tin/lead alloy - may contain up to 60 percent lead)
- Non-food grade plastic (chemical composition and/or material purity not deemed acceptable by a compliance agency e.g. Health Canada)
- Galvanized steel (a pure zinc coating) often associated with lead soldered seams in older equipment, utensils and valves; standards set by the Manufacturers of Maple Sugaring Equipment do not permit the use of galvanizing on any food contact surface
- Painted steel (may contain lead, peeling probable)
- Brass (a copper/zinc alloy) depending on its composition, may contain small quantities of antimony, arsenic, phosphorus, manganese, silicon and up to 3.8 percent lead to improve machinability - lead-free brass may be used only for connections and joints
- Bronze (a copper/tin alloy) depending on its composition, may contain small quantities of phosphorus, manganese, aluminum, silicon and up to 20 percent lead to improve wear performance and machinability
- Wood (only hard maple or equivalent density woods may be used only as table tops or cutting boards; no other types of wood may be used)
- Swimming pool grade diatomaceous earth
Food grade materials include, but are not restricted to, the following:
- Stainless steel (as determined by NSF/ANSI 51, requires a minimum 16% chromium which includes SAE series 200, 300 or 400 series - 300 series is most commonly used in the food industry)
- Plastic recognized as food grade (meets compositional and purity standards, as well as established conditions of use, determined by a compliance agency e.g. Health Canada)
- Aluminum (as determined by NSF/ANSI 51, only Alloy Series 1000, 3000, 4000, 5000 and 6000 may be used. Its use is generally limited to sap buckets and 6000 series aluminum filter presses)
- Glass (as determined by NSF/ANSI 51, if not subjected to impact by hard objects during use)
- Filter fabric (meets voluntary national standards established by NSF/ANSI 42 & 53)
- Reverse Osmosis membrane (meets voluntary national standards established by NSF/ANSI 58)
- Diatomaceous earth (meets standards determined by a compliance agency e.g. Health Canada)
- Plastic piping and/or tubing (meets standards of NSF/ANSI 51 for food equipment materials
- Plastic tubing suitable for potable water (designated as NSF/ANSI 61 or NSF-PW)
Direct contact of maple sap and/or maple syrup with non-food grade materials may adversely affect both their safety and quality, as well as be in contravention of sub-sections 6(2) and 6(3) of Ontario Regulation 119/11. Only food grade materials suitable for their intended use may be used in food contact surfaces, effective January 1, 2018
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