All about formulating a standard for ink

Sagar Singh, deputy director, Chemical Division, BIS, explains what it takes to formulate an Indian standard in an interview with Rahul Kumar

30 Sep 2022 | By Rahul Kumar

Sagar Singh, deputy director, Chemical Division, BIS

The standard IS 15495, which prescribes guidelines for printing inks for use on food packages, which is now mandated by FSSAI, is a standard created by the Bureau of Indian Standard (BIS). While printing inks constitutes a small part of the package, its impact is immensely significant and the next big issue in sustainable packaging is printing inks. Thus, recently the standard IS 15495 was revised by incorporating chemicals like toluene and certain phthalates. 
At the forefront of these developments is Sagar Singh, deputy director, Chemical Division, BIS. A BTech in Chemical Engineering from IIT-Delhi, Singh, who joined BIS in 2014, is the member-secretary of CHD 14, the sectional committee for printing ink, stationery, and allied products.
BIS structure
Singh says BIS has three core activities — Standardisation (which is in Singh’s purview) certification, and laboratory services.
In standardisation, BIS has 16 departments overseeing different segments, such as chemical, electrical and others, where the organisation formulates Indian standards for various products. 
“We also revise the existing standards,” Singh says. “Because standards are not static. They are dynamic in nature. We need to update them regularly in line with the industry requirements. If we do not consider the industry requirement, the standards become obsolete. We have to keep our pace as per the requirements of the industry. Likewise, we need input from industry, manufacturers, consumers, the technical committees or sectional committees.”
These technical or sectional committees comprise of various experts from the industry. Those experts may include manufacturers, users of the product, education institutes, the government departments, including various ministries, and various laboratories. “So, the committee is a fine mix of all the relevant stakeholders,” Singh says.
There are 25 sectional committees in BIS. CHD 14 is the committee that focuses on printing ink, stationery, and allied products. Singh says CHD 14 has a good mix of ink manufacturers, converters, and suppliers. 
“Whenever we schedule a meeting in consultation with the chairman of the technical committee, we send out the meeting notice to all the committee members,” he adds. 
The process

Singh says there are also sub-committees and panels within the sectional committee. CHD 14 has two panels — one related to printing ink and the other related to stationery items. The printing ink panel has 10 members, including all the major ink manufacturers.
“Whenever you take up any particular subject, for example, if someone proposes a new standard, we take it up through the panel. The panel comprises the core experts in the field,” he says.
The panel prepares a working document, which is then taken up to the sectional committee. Once the sectional committee approves it, the document is sent for wider circulation. 
“By wide circulation, we mean that the document is in public domain available for all relevant stakeholders. It is published on the BIS website. If you are a relevant stakeholder, you can access the document and submit your comments online,” Singh explains.
The document remains in wide circulation for two months. Singh says the public comments can be of two types — editorial, highlighting the language errors in the document, and technical, regarding the standard in questions and what can be done about it. 
After two months, all the comments are collated, and they are discussed in a sectional committee meeting whether they are worthy of inclusion or not. “We incorporate the comments that make sense. After incorporating the comments, the document is sent for publication. After the publication, it is considered the Indian standard,” Singh says.
He adds that it takes 12-18 months for a standard to get published. If it is a priority, it may take nine months. “If the subject is critical in nature, we receive a lot of comments and resolving these takes time,” he adds.
In this sense, Singh says, BIS acts as a facilitator in building consensus among the stakeholders. 
Future standards
Currently, CHD 14 is working on the process of formulating a new standard on eco-friendly printing inks. 
It is also working on revising the standards again, because, as Singh says, the ban on toluene was just the beginning. Now, BIS is trying to incorporate other harmful chemicals in the list. These include non-intentionally added substances and UV photoinitiators.
BIS wants to add Mineral oils, Cobalt Carboxylates, Xylene, Methylcyclohexane in the next amendment. Xylene and Methylcyclohexane will be specific for flexible materials and film printing for Food Packaging. Xylene is a neurotoxin and may cause spontaneous abortion. Methyl cyclohexane is toxic to aquatic life and toxic for the liver and kidney.
Non-intentionally added substances (NIAS) are chemicals that are present in a food contact material (FCM) but have not been added intentionally for a technical reason during the formulation. Many NIAS can migrate from the FCM into food, but it is very difficult to completely understand and control. NIAS have various sources and can be grouped into side products, breakdown products, and contaminants.  
Singh says while BIS is working on building the list of harmful chemicals, the agenda for the future is to switch from a negative to a positive list. “Now, in Annex A, we have a list of prohibited chemicals. Soon, we will have a list of chemicals which are safe to use in ink formulation,” Singh concludes. “This is our vision, and hopefully we will achieve that soon.”

Regulators, brand owners must create awareness on standards: Jatin Takkar 

(l-r) Jatin Takkar of Siegwerk and Sagar Singh of BIS

Ink manufacturer Siegwerk recently conducted a webinar on legal obligations towards packaging safety for FMCG sector and packaging material suppliers. Rahul Kumar spoke to Jatin Takkar, head, product safety and regulatory, Siegwerk India on the subject
Rahul Kumar (RK): How do you see the market evolving in terms of packaging safety?
Jatin Takkar (JT):
Indian regulators have been working to raise the bar on packaging safety and it is evident from the release of the Food Safety and Standard (Packaging) regulations by FSSAI and the revision of IS 15495 Standard by Bureau of Indian Standards. Both the regulators have jointly addressed the critical concerns related to packaging safety for ensuring consumer safety.

Brand owners also are now responding to these evolved regulations very positively and making efforts to ensure that they comply with the new norms. We also see that the entire packaging supply chain, including substrate suppliers, adhesive suppliers, ink manufacturers, and printers adapt well to the new norms, bringing innovative solutions which meet the current legal requirements.
RK: Can you sum up the new norms around packaging safety?
The biggest highlight is that FSSAI has acknowledged the critical concerns related to packaging safety and has now regulated packaging safety through a dedicated regulation — Food Safety and Standard (Packaging) regulations. In the regulation, the legal obligation is entirely given to the brand owners for the obvious reason that they are solely responsible for ensuring the packaging safety and among the packaging supply chain partners none other than brand owners can be regulated by Food Safety and Standard Authority of India.

For the first time, FSSAI has defined the food grade packaging material, which removes all the ambiguity existing in the market as to what can or cannot be classified as food grade packaging material. FSSAI has mandated standards for different plastic and paper substrates, and packaging inks. FSSAI have prohibited the use of newspapers to be used as food packaging material and also prohibited any direct contact between printed surface and food, all because of the hazardous chemicals that can leach into your food from the packaging inks. Bureau of Indian standards on other hand, have revised the Standard IS 15495 to protect the consumer health by restricting the heavy metals as well as ban certain hazardous chemicals which includes toluene, TAA and certain phthalates.
RK: What are the challenges you see on the ground?
Implementation of laws on the ground is always the challenge. We do see that big players in the market are becoming compliant, however in general mid-size and small size players are still not adapting to the new norms. The main reason is that regulators have developed the regulation, but have not promoted the same adequately. In the context of packaging safety, it is critical since the industries that prepare the components of packaging material are chemical industries, which are not directly regulated by FSSAI. In this multiple stakeholder ecosystem, it is important that regulators and brand owners create more awareness on the subject.
RK: How can the packaging supply chain implement packaging safely?
Brand owners who have the legal responsibility of placing safe packaging material in the market must drive this change. They need to develop food contact material experts who understand packaging safety and its legal obligations, packaging supply chain model and are capable of creating packaging safety guidelines for the suppliers as well as assessing the compliance documents coming from the suppliers.

Brand owners also must promote transparency and integration in their supply chain as it will need efforts from all the suppliers (substrate/adhesives/ink/coatings) to create compliant printed packaging material. Last but not the least, brand owners must consider only the competent suppliers who can deliver safe packaging material and put an auditing protocol in place to validate the systematic processes at the supplier end that demonstrate packaging compliances.