SO - YOU WANT TO DIE CUT WHAT? It never stops amazing me how many different products are cut with dies and specialty cutting processes. Most recently I have been reminded that there are many companies out there that need to cut food as part of their production. Sometimes it's just slitting, slicing or chopping and sometimes a manufacturer will want to produce a product in a shape that cannot be extruded or made in a mold. In this case, we as die cutters, die makers, and specialty cutters are called upon to step up to the oven and take a shot at the unusual. Years ago I built some tooling that was to be used for cutting brownies into that typical rectangular shape brownies come in. Instead of slitting the shapes in two directions after the sheet of goods was baked, the manufacturer wanted to cut the entire sheet of cooked goods in one shot as it passed down the line. They wanted a very uniform size and wanted to trim the baked edges off so everyone got exactly the same thing. As it happened, we made no effort to look into any type of government regulations or standard industry practices that would help us figure out what materials to use. We had a couple of meetings, used a bit of common sense, and came up with a very basic steel rule die that used solid stainless steel blades and a plastic base that was approved for medical applications by a US government agency (good enough for medical it must be good enough for food, right?). Ejection was handled with a center hole in each cavity that allowed a stainless stripper plate to be activated from the back of the tool. Everything was washable, would resist rusting, corroding, and no part of the tool could flake away and become part of the food. We built a great tool and everything worked well. In retrospect, we probably should have made the tool with no base and welded everything together so it would have been easier to wash, or better yet we should have passed the whole project onto someone that really knew the business. Still the question remains with me today, did we build tooling that met the standards?
All around the world governments have set-up standards that food manufacturers must adhere to. Deep down, I think this is what we all worry about when we get into making tools, or processing foods, and rightly so. In the US we have the FDA (Food and Drug Administration) that tells us how to produce things when it comes to foods - they police it too… In Europe there are as many regulators as there are countries and yet with the growing closeness of European countries an entity called The European Commission is taking more control of these matters. In China, the Ministry of Health plays a big part in who does what and how. From Ministries of Health to Food Inspection Agencies around the world, everyone has got to follow some sort of rule when they process foods. There are even cooperative agreements set-up between countries/agencies to help manage the production of food that will be imported/exported between them. All in all it can become a very complex task to take on compliance with these government regulations.
"I'm just a diemaker" you say! Well we've got to start somewhere and I'll tell you that it's quite a relief to find that a government agency (the FDA is easiest for me to access and has a pretty decent web site) uses at least a little common sense when it comes to the equipment used for cutting food. Here are some excerpts from:
The FDA Code of Federal Regulations- Title 21, Volume 2 - TITLE 21 -- Food And Drugs - Chapter I -- Food And Drug Administration, Department Of Health And Human Services - Part 110--Current Good Manufacturing Practice In Manufacturing, Packing, Or Holding Human Food.
Sec. 110.20 Plant and grounds.
(a) General maintenance. Buildings, fixtures, and other physical facilities of the plant shall be maintained in a sanitary condition and shall be kept in repair sufficient to prevent food from becoming adulterated within the meaning of the act. Cleaning and sanitizing of utensils and equipment shall be conducted in a manner that protects against contamination of food, food-contact surfaces, or food-packaging materials.
Sec. 110.40 Equipment and utensils - (This Includes the Dies and Presses)
(a) All plant equipment and utensils shall be so designed and of such material and workmanship as to be adequately cleanable, and shall be properly maintained. The design, construction, and use of equipment and utensils shall preclude the adulteration of food with lubricants, fuel, metal fragments, contaminated water, or any other contaminants. All equipment should be so installed and maintained as to facilitate the cleaning of the equipment and of all adjacent spaces. Food-contact surfaces shall be corrosion-resistant when in contact with food. They shall be made of nontoxic materials and designed to withstand the environment of their intended use and the action of food, and, if applicable, cleaning compounds and sanitizing agents. Food-contact surfaces shall be maintained to protect food from being contaminated by any source, including unlawful indirect food additives.
(b) Seams on food-contact surfaces shall be smoothly bonded or maintained so as to minimize accumulation of food particles, dirt, and organic matter and thus minimize the opportunity for growth of microorganisms.
Sec. 110.80 Processes and controls.
(10) Mechanical manufacturing steps such as washing, peeling, trimming, cutting, sorting and inspecting, mashing, dewatering, cooling, shredding, extruding, drying, whipping, defatting, and forming shall be performed so as to protect food against contamination. Compliance with this requirement may be accomplished by providing adequate physical protection of food from contaminants that may drip, drain, or be drawn into the food. Protection may be provided by adequate cleaning and sanitizing of all food-contact surfaces, and by using time and temperature controls at and between each manufacturing step.
Wow - Did you actually read all that? Those are three minor sections of a seventeen page document that outlines the basics you need to know to cut food or to build tooling that will cut food in the US. You'll have to go to another document for some of the definitions of some of those sections. All in all though I must say that most of it is common sense and quite achievable within most diemaking shops and with many die cutting machines. If you are not in the US you may find that the rules to follow are more stringent or less stringent. Putting it all together as one neat, consistently reproducible manufacturing process is the trick. There are consultants as well as people from within your various government agencies that can help in setting up and maintaining a proper process.
So to answer the question of whether or not we built tooling that met the standards - I would say yes we did. (That's a load off my mind!) In fact, if the company that was using the tooling was following the rules, they would have had a person in charge of making sure we were in compliance and if there had been a problem, we would have heard about it. And if they were somehow out of line with this way of thinking, I'm sure the Food Police would have caught up with the whole bunch of us.
Of course none of this covers the very related area of diecutting items that will come into direct contact with foods. Labels, packaging, tags, etc….. all fall into this category and although the manufacturing of these will carry somewhat the same rules and regulations that actual food cutting does, the big added factor to watch out for is the type of material that you are incorporating. Papers, plastics, inks, coatings, glues, etc….. are all controlled under many government agencies.
Good luck and I hope this gets anyone interested in die cutting food, or making tools for the same, started in the right direction and further away from that anxious feeling that comes with dealing with government regulations.
Please contact Cut Smart if you would like more information on this subject.
All around the world governments have set-up standards that food manufacturers must adhere to. Deep down, I think this is what we all worry about when we get into making tools, or processing foods, and rightly so. In the US we have the FDA (Food and Drug Administration) that tells us how to produce things when it comes to foods - they police it too… In Europe there are as many regulators as there are countries and yet with the growing closeness of European countries an entity called The European Commission is taking more control of these matters. In China, the Ministry of Health plays a big part in who does what and how. From Ministries of Health to Food Inspection Agencies around the world, everyone has got to follow some sort of rule when they process foods. There are even cooperative agreements set-up between countries/agencies to help manage the production of food that will be imported/exported between them. All in all it can become a very complex task to take on compliance with these government regulations.
"I'm just a diemaker" you say! Well we've got to start somewhere and I'll tell you that it's quite a relief to find that a government agency (the FDA is easiest for me to access and has a pretty decent web site) uses at least a little common sense when it comes to the equipment used for cutting food. Here are some excerpts from:
The FDA Code of Federal Regulations- Title 21, Volume 2 - TITLE 21 -- Food And Drugs - Chapter I -- Food And Drug Administration, Department Of Health And Human Services - Part 110--Current Good Manufacturing Practice In Manufacturing, Packing, Or Holding Human Food.
Sec. 110.20 Plant and grounds.
(a) General maintenance. Buildings, fixtures, and other physical facilities of the plant shall be maintained in a sanitary condition and shall be kept in repair sufficient to prevent food from becoming adulterated within the meaning of the act. Cleaning and sanitizing of utensils and equipment shall be conducted in a manner that protects against contamination of food, food-contact surfaces, or food-packaging materials.
Sec. 110.40 Equipment and utensils - (This Includes the Dies and Presses)
(a) All plant equipment and utensils shall be so designed and of such material and workmanship as to be adequately cleanable, and shall be properly maintained. The design, construction, and use of equipment and utensils shall preclude the adulteration of food with lubricants, fuel, metal fragments, contaminated water, or any other contaminants. All equipment should be so installed and maintained as to facilitate the cleaning of the equipment and of all adjacent spaces. Food-contact surfaces shall be corrosion-resistant when in contact with food. They shall be made of nontoxic materials and designed to withstand the environment of their intended use and the action of food, and, if applicable, cleaning compounds and sanitizing agents. Food-contact surfaces shall be maintained to protect food from being contaminated by any source, including unlawful indirect food additives.
(b) Seams on food-contact surfaces shall be smoothly bonded or maintained so as to minimize accumulation of food particles, dirt, and organic matter and thus minimize the opportunity for growth of microorganisms.
Sec. 110.80 Processes and controls.
(10) Mechanical manufacturing steps such as washing, peeling, trimming, cutting, sorting and inspecting, mashing, dewatering, cooling, shredding, extruding, drying, whipping, defatting, and forming shall be performed so as to protect food against contamination. Compliance with this requirement may be accomplished by providing adequate physical protection of food from contaminants that may drip, drain, or be drawn into the food. Protection may be provided by adequate cleaning and sanitizing of all food-contact surfaces, and by using time and temperature controls at and between each manufacturing step.
Wow - Did you actually read all that? Those are three minor sections of a seventeen page document that outlines the basics you need to know to cut food or to build tooling that will cut food in the US. You'll have to go to another document for some of the definitions of some of those sections. All in all though I must say that most of it is common sense and quite achievable within most diemaking shops and with many die cutting machines. If you are not in the US you may find that the rules to follow are more stringent or less stringent. Putting it all together as one neat, consistently reproducible manufacturing process is the trick. There are consultants as well as people from within your various government agencies that can help in setting up and maintaining a proper process.
So to answer the question of whether or not we built tooling that met the standards - I would say yes we did. (That's a load off my mind!) In fact, if the company that was using the tooling was following the rules, they would have had a person in charge of making sure we were in compliance and if there had been a problem, we would have heard about it. And if they were somehow out of line with this way of thinking, I'm sure the Food Police would have caught up with the whole bunch of us.
Of course none of this covers the very related area of diecutting items that will come into direct contact with foods. Labels, packaging, tags, etc….. all fall into this category and although the manufacturing of these will carry somewhat the same rules and regulations that actual food cutting does, the big added factor to watch out for is the type of material that you are incorporating. Papers, plastics, inks, coatings, glues, etc….. are all controlled under many government agencies.
Good luck and I hope this gets anyone interested in die cutting food, or making tools for the same, started in the right direction and further away from that anxious feeling that comes with dealing with government regulations.
Please contact Cut Smart if you would like more information on this subject.
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