Frequently asked to provide gaskets complying with Food and
Drug Administration (FDA) regulations, gasket manufacturers are often left to
face this broad and complex area that often extends far beyond consumable,
digested products. This information will help explain many of the requirements
for FDA compliant gaskets and why they exist. What does it mean to conform to
FDA regulations? Gaskets are considered FDA approved through GRAS, existing FDA
regulations, and FDA FCN.
GRAS - Materials that are generally regarded as safe (GRAS).
Many materials that have been used successfully in FDA applications are listed
as GRAS. Through scientific procedures, the use of a food substance gasket may
be GRAS for a substance used in food before 1958 or through experience based on
common use in food. However, some materials are already covered by existing
regulations. For example, perfluorocarbon resins and PTFE are found in 21 CFR
177.1550. These would fall under the category “existing FDA regulations.” New
materials that are not covered by either of these previous choices can be
submitted to the FDA through a food control notification (FCN).
The most common gasket materials used for FDA applications
are PTFE gaskets. Covered in 21 CFR 177.1550, filled gaskets made entirely from
PTFE may be used if the filler/s, coloring agents, etc., are considered GRAS or
if they are covered by another regulation. Extractable tests with maximum
limitations are also required based on the surface area of the sample. Some
gasket materials, such as PTFE joint sealant, are supplied with an adhesive
strip to make installation easier. The adhesives must conform to 21 CFR 175.105.
Non-PTFE used materials include elastomer (rubber that is
able to conform to FDA regulations and is used in many flat-faced flanges in
which the available compressive load is low.) Finding an elastomer suited for
the media contained in the given particular system is made possible since
compounds can be created from most elastomer types (NBR, SBR and EPDM.)
21 CFR 177.2600 lists acceptable elastomers, as well as acceptable
fillers, processing agents, additives and curative systems. Gaskets made from
elastomers are covered under this section. Acceptable levels for each component
are listed, extraction tests and limitations are identified, and the test
fluids are based on the intended specificity of service. An example of this
could be that different extractions tests are done for fatty- versus
aqueous-based food service.
Some gasket products may also include an adhesive used as an
assembly aid. While there is no real “sealing function” performed by such
adhesives, since they are used primarily to secure the gasket into position
prior to assembly, these adhesives must also meet certain requirements mandated
by the FDA. An example of an adhesive used with PTFE material might be an
acrylic that is composed of 2-ethylhexyl acrylate, butyl acrylate, methyl
methacrylate and glycerin rosin ether. All four compounds are included in 21
CFR 175.105 as acceptable substances.
Proper identification of a gasket material may be necessary in
order to provide traceability for the end-user. This requirement is usually
satisfied by printing the manufacturer's name or brand name and style number on
one or both sides of the gasket sheet. Once converted to the specified gasket
configuration, the ink may also come into contact with the process media (therefor
it must also meet certain CFR criteria.) All branding ink ingredients must be
acceptable for direct contact with food and pharmaceutical products in
accordance with appropriate sections of 21CFR.
Various FDA applications use piping with sanitary couplings
(such as breweries, wineries, and dairy product plants.) These couplings are
made to be easily disassembled so that the system can be cleaned. These specialized
seals or gaskets used in these couplings are normally made in a specific shape
and cross-section to easily conform under the low available compressive load.
These seals are made from many materials including PTFE, elastomers (with or
without metal inserts), etc.
For applications that involve food and pharmaceuticals,
other requirements may be needed for compliance beyond those of the FDA. These
include those of National Sanitary Foundation (NSF), U.S. Pharmacopeias (USP)
and 3A. For instance, a certification to meet the U.S. Pharmacopeia Plastic
Class VI Requirement is a frequent request. This biological reactivity test requires
samples of the gasket material to be tested by implanting them into live
animals to confirm that no toxic reactions occur from the material. (Tests must
be completed by approved laboratories recognized by the U.S. Pharmacopeia.)
Many countries have changed many of the regulations specific
to direct and indirect contact with food, pharmaceutical, and related products.
Examples of this are the recent changes in the Official Journal of the European
Union Regulation (EC) No 1935/2004. This regulation lays out the principals for
any material or article that comes into contact with food. This regulation
along with (EC) 2023/2006/EC lays out the principals of good manufacturing practice
(GMP) and demonstrates similar practices and concerns as those here in the U.S.
The above information
is provided only as a guide in helping you understand how gaskets may comply
with the Food and Drug Administration. Please call Colonial Seal Company at
856-432-0012 or email sales@colonialseal.com for more information.
Founded in 1994,
Colonial Seal Co. is headquartered in Westville, New Jersey. Colonial Seal
specializes in oil & grease seals, hydraulic seals, rotary shaft seals,
mechanical seals, rubber molded products and gaskets. Through a global network
of manufacturers, Colonial Seal can produce custom seals designed for a
client’s unique sealing applications. Colonial Seal Company is ISO 9001:2008
certified.
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