DEVELOPING NORMS

FOR
FOOD GRADE PAPER

05 JUNE 2022

By: D K Singhal, www.dksinghal.in

 Packaging Needs
2

Nature already presents all precious things

packaged in the most eco-friendly way.
However, humans need packaging for additional
requirements of extended storage (shelf life),
transportation, presentation etc.
 Packaging Medium
3

Plastics (including PE, PP, MLPs and other such

materials) have proved to be wonderful media for
packaging.
Considering environmental concerns, now the world
has to search some alternate material.
 Paper
4

Paper is not a new packaging medium.

But of course, there are some limitations.
One must agree that paper is not that good
packaging material considering-
Water barrier
Moisture barrier
Oil & Grease Resistance
Oxygen Barrier properties etc.
 Paper Limitations
5

While researches are going on to find a suitable

process to develop paper having better properties,
I’d like to look at the whole scenario from a
distance.
 Application Areas
6

As we begin to think about paper as a packaging

medium, the first point that comes to our mind is the
suitability for packaging snacks (namkeens, potato
wafers etc.), liquids (fruit juices), pan masala (aroma
barrier) etc.
 Applications Forgotten
7

We often forget applications where-

Desired packaged material is not very demanding
(Biscuits)
Shelf life is not very long (Bread)
Foodstuff has to be consumed within a few minutes
(Chat-kachori, Samosa, Bhelpuri, Street Food)

May I ask…
 The Question
8

Aren’t we all behaving like a high-school

headmaster who sets a basic qualification to seek
admission to class-IV in his school as cracking
IIT-JEE?
 Standards
9

Standards do play a vital role in developing or

damaging a market.

Too strict standards often lead to various problems

as their side-effects. Let us have a look at a typical
case-
 Packaged Water
10

The basic aim for standardization for packaged

drinking water was to ensure water of adequate
quality; and the side effect was-

Packaged drinking water transformed-

From a luxury product to a status symbol.
From a status symbol to social requirement.
Finally to a big creator of plastic waste.
 Present Standards
11

At present in India, there are no mandated

standards for food grade paper.
Mills are supplying food grade paper on the basis
of FDA178 or FDA182 testing.
FSSAI has presented some standards for general
packaging materials, but these are based either
upon the transmission rates through packaging
media or contaminants in paper.
 Standards for Paper
12

It is recommended that standards must consider

various aspects and to be set accordingly.
For paper, we may consider having different
standards for-
Packaging paper for long shelf life
Paper plates/crockery
Paper for packaging low-shelf life products
(bread/burger) etc.
Paper for solid foodstuff (Biscuits, cookies)
 Packaging Food Grade Products
13

For packaging for long durations, strict standards

may be considered, while there should be softer
standards for short duration products.

Furthermore, it must also be kept in mind that every

contamination in paper packaging is not expected
to get transferred to foodstuff during storage or
transportation.
 Low Shelf Life Products
14

For bread etc., separate applications may be

developed.
Here, the focus must be low transmission rates (but
not extremely low) of moisture, oxygen etc., low
water absorbency (low Cobb60), Kit value of 3-4
are enough.
Later on, wax coating on paper can also be done
to further achieve the desired properties.
 Pesticide Content
15

Pesticide content is another important aspect but

also a little over-emphasized issue.
For example, the limits for PCP, as per USFDA
178.3800 are 50 mg/kg of paper.
Let us consider only 10% of PCB can get released
from paper during handling, and also weight of
paper packaging is just 10% of that of foodstuff.
If you eat 200gm packaged food….
 Pesticide Content
16

As per present norms:

200gm food: 20gm paper
20gm paper: 50*20/1000 = 1mg PCP
It has been seen that the PCP, having a half life of
30-50hours in humans, does not show any harmful
effect upto 3mg/kg/day body weight.
That means, for a person having 80 kg weight,
250mg PCB can be tolerated by the body.
 Pesticide Content
17

Had the PCP norm as 500mg/kg in place of

50mg/kg (i.e. 10 times more), PAPER would have
still be safe as a packaging material.

Please note that the objective is not to blame any

standard, but to highlight the over-strictness of some
standards, that makes a product costlier, and
sometimes technically and economically unviable.
 Varying Norms
18

Let us also compare USFDA and FSSAI norms for

PCP content-
USFDA 50mg/kg
FSSAI 0.05mg/kg*

We have already seen that even 50mg/kg is fully

safe; one may ask-
“Why the norms should be made unnecessarily
stringent?”
* See next slide
 FSSAI Standard
19

Food Safety and Standards (Packaging)

Regulations, 2018 refers to IS:6615 (General
Purpose Packing or Wrapping Paper) for packing
materials intended to come into contact with food.
As per IS:6615, the paper should be made from
virgin pulp and free from dioxins. The PCP
(Pentachlorophenol) content should also be less than
0.05mg/kg.
 DIY PCP Detection
20

Take a paper containing 50 mg/kg of PCP.

Take its 5gm sample, shred it into small pieces, and
boil in 500mL of distilled water for 30 minutes.
Let us consider 50% of PCP has been extracted this
way.
Filter and make up the volume of water to 1000mL.
The water shall contain roughly 125 µg PCP.
PCP has taste threshold of 30 µg/L.
 Stringent Norms
21

To strict norms initially make the product costlier, but

many a times may force consumer to use
unapproved products.
FYI more than 99% of street food is being served
on paper that has not been approved.
Compared to other countries, India uses more street
food.
Hence there is an urgent need to address to this
issue.
 Natural Items
22

Many natural products are

traditionally being used for
serving food.
A too rigid approach might
ensure 100% surety about
hygiene of the foodstuff
being served, but, overall, it
may be harmful for the
environment too.
 Conclusion
23

A holistic approach while developing norms related

to food packaging is a must.
We should ensure that the norms are practical,
feasible and optimal.
 Thank You.
24

DK Digitally signed
by D K Singhal

Singhal Date: 2022.06.05

16:31:47 +05'30'

D K Singhal
www.dksinghal.in