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Conference on NIAS and mineral oils

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On March 28-29, 2018, the Italian Institute of Packaging will host a conference on ”NIAS and mineral oils in food contact materials: Regulatory and analytical affairs“ in Munich, Germany. The first session of the conference “addresses the regulatory approach to NIAS, in light of current scientific knowledge, focusing in particular on risk assessment.” The second session focuses on mineral oils and “aims to update the framework of knowledge on the subject and to also illustrate the rules that are about to be implemented, as well as look into what analytical bases are prevailing in the context of the European market.” The full conference program and registration are available on the event website.

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The Italian Institute of Packaging (2018). “Conference NIAS and mineral oils in food contact materials: Regulatory and analytical affairs.(pdf)


FPF webinar on prioritization of unknown substances

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On February 8, 2018, at 02:00 pm CET (Central European Time), the Food Packaging Forum (FPF) will hold a public webinar on prioritization of unknown substances in food contact articles.

Different food contact materials (FCMs) such as plastics, metals, or paper and board bring about a cocktail of unknown chemicals in food likely never intended for consumption. The health risk associated with these chemicals is poorly understood while regulation is lacking. Therefore, methods are needed to prioritize unknown compounds for risk assessment.

Guest speaker Eelco Nicolaas Pieke, PhD candidate at the National Food Institute of the Technical University of Denmark (DTU Food), performed research on quantifying, identifying, and prioritizing chemical contaminants in paper and board FCMs (FPF reported). He will present his research group’s findings on developing comprehensive analytical strategies that permit exploring unknown chemicals, illustrated on the example of paper and board FCMs. After the presentation, there will we time for questions.

For more information and registration, please visit the event website.

Webinar on managing NIAS in the EU and U.S.

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On January 30, 2018, at 04:00 pm CET, the quality assurance company Intertek is holding a webinar entitled “The impact of the EU NIAS regulations on the U.S. FDA final articles indirect food additives compliance.” The webinar addresses “key elements of the regulations” covering non-intentionally added substances (NIAS), as well as challenges in the identification and quantification of NIAS. Further, toxicological risk assessment of NIAS to evaluate “potential health risk associated with the final material or article in accordance with internationally recognized scientific principles” will be discussed. Registration is available on the event website.

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Intertek (2018). “The impact of the EU NIAS regulations on the U.S. FDA final articles indirect food additives compliance.

FPF webinar on prioritizing unknown substances: Video online

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On February 8, 2018, the Food Packaging Forum (FPF) held a public webinar on prioritization of unknown substances in food contact articles.

Guest speaker Eelco Nicolaas Pieke, PhD candidate at the National Food Institute of the Technical University of Denmark (DTU Food), presented his research group’s findings on developing comprehensive analytical strategies that permit exploring unknown chemicals, illustrated on the example of paper and board food contact materials (FCMs) (FPF reported). After the presentation, there was time for questions from the audience.

The video recording of the webinar as well as Mr. Pieke’s presentation slides are now available on the event website.

How to improve risk assessment of FCMs?

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In an article published on February 20, 2018 in the peer-reviewed journal Environmental Health Perspectives (EHP), journalist Nate Seltenrich discussed the Food Packaging Forum’s recent commentary on “Scientific challenges in the risk assessment of food contact materials,” published in the same journal (FPF reported). Seltenrich recapped the publication’s key recommendation to assess the toxicity of all food contact chemicals (FCCs) that may potentially migrate from the finished food contact article (FCA).

Further, Seltenrich cited food contact experts on their views regarding these suggestions. Mark Maier, former toxicologist at Valspar, agrees with testing the overall migrate of the finished FCA (in the case of Valspar can coatings (FPF reported)). However, he disagrees that all FCCs should be tested, as the focus should be on “plausible effects for relevant classes of chemicals at relevant exposure levels.” In contrast, independent consultant Maricel Maffini (co-author of FPF commentary) highlighted that in the U.S., “if a company claims that exposure will be below a certain level, the company may not be required to provide any toxicity info.”

Read more

Nate Seltenrich (February 20, 2018). “What’s in the mix? Improving risk assessment of food contact materials.Environmental Health Perspectives

Reference

Muncke, J. et al. (2017). “Scientific challenges in the risk assessment of food contact materials.Environmental Health Perspectives (published online September 11, 2017).

Food contact plastics seminar 2018

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On April 19-20, 2018, the European Plastic Converters Association (EuPC), together with Polymer Comply Europe (PCE), will hold the Food Contact Plastics Seminar 2018 in Brussels, Belgium. The seminar will address the topic “Ensuring safety of products: Focus on retailers and consumers” and cover five thematic sessions: 1) Contexts of FCMs safety compliance, 2) food producers and converters perspective on safety compliance, 3) regulatory approaches to risk assessment and management, 4) cases of risk assessment and risk management, and 5) the MIGRATOX project and addressing non-intentionally added substances (NIAS) (FPF reported). The full program and registration are available on the event website.

Read more

EuPC (March 1, 2018). “Food Contact Plastics Seminar 2018 – The program is now available.

FPF Workshop 2018: Save the date!

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On October 4, 2018, the Food Packaging Forum (FPF) will hold its sixth annual workshop on “Predicting and ensuring the safety of food contact articles: New science and digital opportunities” in Zurich, Switzerland.

This one-day workshop features high profile speakers and offers an ideal platform for exchanging views with different stakeholders in the field of food contact materials (FCMs). Save the date for this one-of-a-kind event in the FCM world to learn about recent developments in science, business, advocacy, and regulation! As in previous years, the FPF workshop also presents an excellent opportunity for networking.

The 6th edition of the FPF Workshop is dedicated to predictive chemistry and toxicology, computational methods, and digital tools to ensure the safety of food contact articles. Confirmed speakers include Dr. Olivier Vitrac of the French National Institute for Agricultural Research (INRA), Prof. Dr. Bruce Blumberg of the University of California Irvine, U.S., Dr. Sander Koster of Nestlé, Sonja Eijpe of Viaware, and Dr. Pelle Moos of The European Consumer Organisation (BEUC).

The detailed program will be released shortly and registration will open in May 2017 – both to be available on the event website. The FPF will also provide access to a live webcast of this year’s workshop for a minimal registration fee. Participants who cannot attend the workshop in person, may thus still follow the speaker presentations, Q&A’s, and the podium discussion.

Webinar on NIAS case studies


Plastic packaging industry discusses current challenges

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On April 19-20, 2018, the European Plastic Converters Association (EuPC), together with Polymer Comply Europe (PCE), held the 2018 edition of their Food Contact Plastics Seminar (FPF reported). The seminar took place in Brussels, Belgium, and was entitled “Ensuring safety of products: Focus on retailers and consumers.” The program featured four thematic sessions with speakers from industry associations, food and packaging companies, research organizations and consultancies, and the European Commission (EC).

Silvia Freni Sterrantino from EuPC addressed the implications of the EC’s plastics strategy (FPF reported) for food contact materials. She informed that the measure on single-used plastics, as foreseen by the plastics strategy, will include i) improvement of collection schemes for certain items (e.g., bottles), ii) promotion of biodegradable solutions, and iii) charges or levies on certain items (e.g., carrier bags). The measure might be a directive, potentially leading to different interpretation across EU Member States (MS). Therefore, an EU regulation could be an alternative, preparation of which might need more time however. The measure is due by May 2018 (FPF reported).

Patrick De Kort from PCE clarified that the REACH restriction on microplastics only focuses on intentionally added microplastics and accidental release of plastic nurdles or pellets lies outside of the scope of the restriction. The European Chemicals Agency (ECHA) is currently preparing a restriction proposal for microplastics – a measure that is also foreseen by the EC’s plastics strategy (FPF reported). The proposal will be finalized by January 2019 and possibly adopted by June 2020 after revision.

Christian Kirchnawy from the Austrian Research Institute for Chemistry and Technology (OFI) presented its ongoing MigraTox project which focuses on the use of in vitro bioassays for the safety assessment of non-intentionally added substances (NIAS) in food packaging (FPF reported). OFI is currently developing bioassays fit for this purpose, working on sensitivity of single tests (e.g., for genotoxicity), sample preparation (e.g., avoiding false positives and false negatives), validation (e.g., influence of sample matrix), and standardization (e.g., generally agreed protocol). Kirchnawy further noted that bioassays can also be used for the ‘safety by design’ approach, where material samples with the least activity are chosen. However, just because the migrate of a material tests positive in a bioassay does not mean that it is dangerous, he insisted. The bioassay only gives an indication of potential risk and unnecessary panic should be avoided.

Rachida Semail from law firm Keller and Heckman LLP compared the Chinese food contact legislation (FPF reported) to EU legislation and explained its requirements for EU converters. Overall, the two legislations have many similarities, however the Chinese standards are more detailed than the EU regulations. EU converters should determine case-by-case whether compliance with EU regulations is sufficient to comply with Chinese standards. The converters are obliged to do all the compliance work according to Chinese standards but not necessarily in Chinese laboratories.

Bastiaan Schupp and Jonathan Briggs from the EC’s Directorate-General for Health and Food Safety (DG SANTE) gave an update on the EC’s activities concerning EU food contact materials (FCMs) legislation. The EC is currently working on a technical guidance for compliance testing of plastic FCMs (expected soon), a new ceramic directive (FPF reported), and approval of new substances under the plastics regulation (EU) No 10/2011. Briggs informed about the ex-post evaluation of the FCM framework regulation (EC) No 1935/2004 (FPF reported). The study to support the evaluation and to be done by an external contractor will start after the summer of 2018 and take one year. Stakeholders will be consulted in the data collection phase of the study, involving two workshops for all stakeholders and a twelve-week public consultation. After the study, a staff working document, communicating the results and conclusions of the evaluation to policy makers and stakeholders, will be published. Briggs noted that more information and a timeline of the evaluation will be published on DG SANTE’s website. Schupp informed that authorization decisions on more than 140 plastic recycling processes (mostly polyethylene terephthalate (PET)) are due in 2018. The decisions will be based on the scientific opinions by the European Food Safety Authority (EFSA). The EC considers obliging recyclers to monitor incidental contaminants in recycled plastics. Future focus will lie on recycling of non-PET plastics, namely polyolefins, as they represent the biggest part of the market. The EC will also look into standardization of waste streams to create a standard for ‘food grade waste.’ Lastly, Schupp noted that the EU measure on printed FCMs is currently on hold awaiting ‘political validation.’

Read more

DG SANTE (May 2, 2018). “Plenary meetings.

FPF Workshop 2018: Registration open!

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On October 4, 2018, the Food Packaging Forum (FPF) will hold its 6th annual workshop in Zurich, Switzerland. This year’s edition of the FPF Workshop is entitled “Predicting the safety of food contact articles: New science and digital opportunities.

The event program features high profile speakers representing different stakeholders in the field of food contact materials (FCMs). Join us for this one-of-a-kind event in the FCMs world and learn about recent developments in science, business, advocacy, and regulation! This year’s workshop can also be followed via live webcast.

Registration for both the workshop and the live webcast is now open. Please register before September 27, 2018 – spaces are limited.

BfR statement on polyamide oligomers

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On May 30, 2018, the German Federal Institute for Risk Assessment (BfR) published a statement regarding polyamide oligomers in kitchen utensils. The statement focuses on cyclic oligomers that can migrate from kitchen utensils (e.g. cooking spoons, spatulas) made of polyamide (types PA6 and PA66) into food.

Based on available information and predictions from in silico methods, the BfR determined that PA6- and PA66-oliogomers are not suspected to be genotoxic or carcinogenic. Due to lack of experimental toxicological data, the BfR used the TTC (Threshold of Toxicological Concern)-approach and assigned the PA-oligomers to Cramer Class III. This results in a tolerable exposure level of 90 µg/person/day below which any health risks are considered unlikely. However, according to exposure estimations, this threshold is likely to be exceeded and exposure to PA-oligomers may be up to 17.6 mg/person/day.

Therefore, the BfR calls on manufacturers to provide toxicological data on elevated exposures to PA-oligomers. Until then, a conclusive risk evaluation cannot be finalized, the BfR noted.

Read more

BfR (May 30, 2018). “Polyamid-Oligomere: Kunststoffbestandteile aus Küchenutensilien.(pdf; in German)

Non-intentionally added substances (NIAS)

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1. Definition and types of NIAS

Non-intentionally added substances (NIAS) are chemicals that are present in a food contact material (FCM) or food contact article (FCA) but have not been added for a technical reason during the production process. Many NIAS can migrate from the FCM or FCA into food, but it is very difficult to completely understand and control such processes. The term NIAS was introduced for plastic FCMs in Europe in the legal context (Commission Regulation (EU) No 10/2011). However, NIAS are not limited to plastics but also occur in all other non-plastic FCMs.

NIAS have various sources and can be grouped into side products, breakdown products, and contaminants. Side products are often formed during the production of starting substances and all further manufacturing stages. Polymerization side products derived from manufacturing of can coatings are typical examples of such reactions (FPF reported). Structure-providing constituents of FCMs (e.g., polymers, fibers) as well as additives (e.g., antioxidants, UV-stabilizers) are often degraded during manufacture and use, thus leading to various different breakdown products. Contaminants may have very different sources: Starting substances used in the production of FCMs often contain impurities or environmental contaminants which may remain in the final FCA. Processing and especially recycling can also introduce many different contaminants in FCMs and FCAs. Typical recycling-related NIAS are mineral oil hydrocarbons (MOHs), bisphenols, phthalates, and photoinitiators in recycled paper and board as well as flavor compounds, oligomers, and additives in recycled plastics (FPF reported).

2. Analysis of NIAS

Many FCMs and FCAs have a high chemical complexity making a complete characterization of all NIAS unrealistic and the identification of those NIAS that may be of concern very challenging. NIAS may be predicted based on the knowledge of chemical processes, manufacturer’s experience, and conditions of use. Such substances may then be identified and quantified rather easily by targeted chemical analyses. By using non-targeted screening methods, additional NIAS may be detected and at least some of them identified, while others remain completely unknown.

The FCM itself, a migrate or extract can be analyzed or screened for predicted and unpredicted NIAS. Thermal desorption techniques are used to directly investigate FCMs and solid food simulants. Although these methods are quick, they result in complicated fragmentation patterns that are difficult to interpret. Therefore, extracts or migrates of FCMs are typically prepared and used for further separation. Depending on the analytes, gas or liquid chromatography is applied, which is generally connected to mass spectrometry, flame ionization, ultraviolet and/or fluorescence detectors. After thorough analysis, the combination of all available information may allow to assign chemical structures to NIAS. However, many substances still remain unidentified. Quantification of NIAS is also challenging because analytical standards are usually missing. Therefore, concentrations are estimated by comparing peak areas with one or several internal standards. When using detectors optimized for “uniform” responses, prediction error ranges can differ by factors between 3 and 6.

3. Regulations

Europe

It is in accordance with the current European legislation that also non-authorized substances are present in plastic FCMs when they are non-intentionally added (Article 6(4), (EU) No 10/2011), but the FCM manufacturer is obliged to ensure NIAS safety, according to Article 3 of the Framework Regulation ((EC) No 1935/2004) and Article 19 of the Plastics Regulation ((EU) No 10/2011). Consequently, the safety of NIAS has to be assessed. At the moment, no levels of migration or exposure are set for which compliance with this requirement can be demonstrated. As specified in Regulation (EU) No 10/2011, unauthorized substances may be used in plastic FCMs behind a functional barrier, provided they do not migrate at levels above 10 µg/kg food. Substances that are known to be carcinogenic, mutagenic or toxic for reproduction (CMR) or have nanomaterial properties may not be used accordingly. Therefore, in practice a threshold of 10 µg/kg food is often used for NIAS.

United States

Any food contact substance (FCS) that is reasonably expected to migrate into food because of its intended use in an FCA must comply with the legal requirements. The definition for FCS does not cover substances that are non-intentionally added, and the term NIAS is not used in a legal context in the U.S.. However, there are provisions concerning impurities (21 CFR 174.5) and substances originating from direct contact between an FCS and the food (21 CFR 170.3(i)). The U.S. Food and Drug Administration (FDA) recommends including information on the major impurities (e.g., residual starting materials, byproducts, degradations products) when submitting a food contact notification or food additive petition for an FCS.

China

A definition for NIAS is provided in Standard GB 4806.1. Manufacturers shall perform a risk assessment to assess the safety of NIAS, but explicit approvals are not foreseen.

4. Handling the risks of NIAS

In Europe, no clear advice is given by authorities how the risk of NIAS shall be assessed. As a consequence, different industry-associated groups have published guidance documents. Accordingly, the risk assessment shall be based on information collection, chemical analysis, hazard identification and characterization, and exposure assessment. The transfer of relevant information through the supply chain (upstream and downstream) has been recognized as basic requirement facilitating the identification of major NIAS. Subsequently, the hazards of NIAS need to be addressed. A variety of tools and approaches is available for this purpose and can be used individually or in combination: (1) The classical approach evaluates toxicity data for a single, identified NIAS. (2) In silico methods rely on modeling data and can be further supported by read-across; however, they are also only applicable for identified NIAS. (3) Bioassays allow the hazard assessment of complete migrates/extracts. (4) The threshold of toxicological concern (TTC) concept assigns human exposure thresholds to NIAS and can be used for prioritization purposes. Exposure assessment is equally important and generally based on migration and consumption data. Actual migration testing, worst-case calculations, and modelling help to generate migration data, whereas information about the consumption may be obtained from standardized exposure models or specific databases.

However, hazard and exposure assessment of NIAS often relies on estimations, because relevant data are not available. Therefore, different risk assessment approaches have been proposed which are based on the available level of information. NIAS with structural information may be quantified and their hazard and exposure may be assessed by applying one or several of the above-mentioned strategies. According to classical risk assessment approaches, a NIAS is of no concern if exposure is below a hazard-based reference concentration. NIAS with unknown structure and undetected NIAS could generate a response in in vitro bioassays that allows first estimates of their safety. Under very specific conditions, the TTC concept may also help to assign exposure thresholds to unidentified NIAS.

5. Conclusions and challenges

With increasing complexity of FCMs and FCAs, NIAS will continue to be an important topic. Advances in analytical techniques and growing databases steadily facilitate the detection and identification of NIAS, but a comprehensive analysis of all NIAS is not yet in sight. International authorities recognized the importance of a risk assessment for NIAS but have not provided official guidance so far, making it difficult to enforce and comply with the legal requirements. Therefore, strategies for the risk assessment of NIAS have been developed and improved by different stakeholders in the past years. Most approaches focus on the risk assessment of single substances by in vivo, in vitro or in silico methods, but in vitro testing of the whole migrate or extract is also recommended. Additionally, robust exposure models and sensitive methods to exclude chemicals of concern are needed. Regardless of the applied concept for risk assessment, communication within the whole supply chain is essential to facilitate the prediction, identification, and quantification of NIAS.

6. Selected references

FPF Dossier (EN)

FPF Dossier (DE)

Definition and types of NIAS, including examples

Analysis of NIAS

Handling the risks of NIAS

Updated dossier on NIAS

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On June 12, 2018, the Food Packaging Forum (FPF) published the 2nd edition of its dossier on non-intentionally added substances (NIAS) as well as an updated summary article on the same topic. The dossier includes background information on NIAS, describes their origins and detection methods, provides various examples, and explains the regulatory situation. Approaches to handling the risk of NIAS are summarized, focusing on structural identification, hazard assessment, priority setting, exposure analysis, and risk assessment and management.

As a novelty, the NIAS dossier is not only available in English but has also been translated into German to reach a wider audience.

Read more

FPF (June 12, 2018). “Non-intentionally added substances (NIAS).

References

FPF dossier (June 12, 2018). “Non-intentionally added substances (NIAS).” 2nd edition, DOI: 10.5281/zenodo.1265331 (pdf; in English)

FPF dossier (June 12, 2018). “Non-intentionally added substances (NIAS).” DOI: 10.5281/zenodo.1280986 (pdf; in German)

NIAS in polypropylene films

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An article published on June 8, 2018 in the peer-reviewed journal Talanta reported on a nontarget analysis of nonvolatile compounds migrating from polypropylene (PP)-based food packaging films. Paula Vera and colleagues from the Analytical Chemistry Department, University of Zaragoza, Spain analyzed 26 manufacturer-provided samples of PP films used in the EU market to package a wide variety of foodstuffs. For each sample, migration experiments were performed with one or more of the 4 different food simulants, chosen depending on the intended use of the packaging film in question (often, more than one use was reported by the manufacturer). The 4 food simulants used were ethanol 10%, acetic acid 3%, ethanol 95%, and Tenax. The migrates were analyzed by liquid chromatography coupled with mass spectrometry (LC-MS) technique on a quadrupole time-of-flight (QTOF) mass spectrometer.

In total, the researchers identified and quantified 74 compounds. Sixteen of these substances were intentionally added substances (IAS), i.e., known to be authorized for plastic food contact materials (FCMs) and commercially used during PP manufacturing as, e.g., stabilizers, plasticizers, slip agents, surfactants, or lubricants. The remaining fifty-eight chemicals were considered to be non-intentionally added substances (NIAS), as their intentional use in PP films could not be identified in the literature. The scientists organized these substances into six different groups shortly described next.

  • 10 substances that included a 3,5-di-tert-butyl-4-hydroxyphenyl group; they could be degradation products of the antioxidants Irganox 1076 (CAS 2082-79-3) or Irganox 1010 (CAS 6683-19-8), both detected as IAS.
  • 15 substances that included a glycerol group; they could be impurities in antifog/antistatic additive glyceryl monostearate (CAS 31566-31-1), detected as IAS.
  • 9 substances identified as dihydroxy alquilamines, which could be either impurities, or reaction products, or breakdown products of some IAS; two of these compounds, N,N-bis(2-hydroxyethyl) tridecylamine (CAS 18312-57-7) and N,N-bis(2-hydroxyethyl) pentadecylamine (CAS 24910-32-5), were found in 15 out of 26 PP film samples.
  • 7 substances identified as ceramides and dihydroceramides; some are used as functional ingredients in cosmetics, but their origin in plastics is unknown.
  • 5 substances formed by amides bonded by ethylene, which could be degradation products of octadecanamide, N,N’-1,2-ethanediylbis- (CAS 110-30-5), a synthetic wax used “as a dispersing agent or internal/external lubricant” (it is unclear why the authors did not include this substance in the IAS list).
  • 12 other substances forming structural groups with less members; the compound ‘Irgafos 168 OXO’ (CAS 95906-11-9), an oxo-derivative of Irgafos 168 (CAS 31570-04-4, detected as IAS), appeared in all but one PP film sample.

To assess the risks of migrating compounds, all quantified migration values were compared either to their respected specific migration limit (SML) if listed in the Plastics Regulation (Commission Regulation (EU) No 10/2011), or, for substances not listed in this regulation, to the maximum migration values calculated according to the  threshold of toxicological concern (TTC) approach based on Cramer classification.

Five PP film samples did not comply with the Plastics Regulation because the sum of the compounds [N,N-Bis(2-hydroxyethyl) (C8-C18) amine] in the family of dihydroxy alquilamines exceeded their SML of 1.2 mg/kg. In one more sample, Irganox 1076 exceeded its SML of 6 mg/kg in the ethanol 95% food simulant.

With regard to non-listed compounds, 6 samples showed migration at levels exceeding the maximum values assigned according to Cramer class II (for some degradation products) or class III (for some amide compounds) when ethanol 95% was used as food simulant. Since three of these 6 samples also did not comply with the Plastics Regulation legislation, this makes for a total number of 9 non-compliant samples out of 26 samples overall.

The authors conclude that their work “opens up a wide range of possibilities for . . . companies that can reformulate and substitute some additives which are related with . . . NIAS found.”

Reference

Vera, P., et al. (2018). “Identification of non volatile migrant compounds and NIAS in polypropylene films used as food packaging characterized by UPLC-MS/QTOF.Talanta (published June 8, 2018).

Prioritization of NIAS for risk assessment

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In an article published on June 19, 2018 in the peer-reviewed journal Regulatory Toxicology and Pharmacology, scientists propose a strategy to prioritize non-intentionally added substances (NIAS) potentially migrating from food contact materials (FCMs) for further risk assessment.

Eelco Pieke and colleagues from the Technical University of Denmark, National Food Institute, Denmark, worked with NIAS detected by non-targeted mass spectrometry-based screening in the extracts of paperboard FCMs. The methods for preparation of extracts and non-targeted screening, identification, and quantification of NIAS are described in an earlier publication (FPF reported). Here, they propose a method to convert the obtained concentration estimates into tentative exposure assessment and to evaluated the predicted chemical structures by quantitative structure-activity relationships (QSAR) models for carcinogenicity, mutagenicity, and reproductive toxicity. They further describe a decision tree that uses the assessment results to assign the evaluated NIAS into “high priority,” “low priority,” or “unclassified” groups. 

Four risk assessors were asked to apply the proposed strategy to the list of 60 chemical compounds selected from those detected in the extracts of two different paperboard FCM samples, a “recycled unused carton pizza box” and a “carton sheet part of the packaging of luxury chocoloates.” The assessors were able to classify compounds as either high or low priority in 60% of the cases, with about half of the compounds in each of the two categories. The high priority substances included “high-concentration compounds, benzophenone derivatives, and dyes,” while the low priority substances included linear alkane amides, oligomers of polyethylene glycol (PEG), and a number of compounds with “simple structures” considered to be of low risk profile. Compounds that remained “unclassified” either had “disagreements between experts (18%) or . . . a perceived lack of data (23%).” 

The authors conclude that their strategy “provides valuable information based on tentative data and is able to prioritize discovered chemical compounds for pending risk assessment.” They further note that “the inclusion of more assessors can improve the classification results.” This appears feasible because the prioritization of 60 substances in the present study “was performed in a short time (less than 1 h).” 

Reference 

Pieke, E., et al. (2018). “Prioritization before risk assessment: The viability of uncertain data on food contact materials.” Regulatory Toxicology and Pharmacology 97:134-143.


Chemicals associated with plastic packaging

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On July 13, 2018, a preprint of the manuscript submitted to Science of The Total Environment was published in the PeerJ Preprints. The manuscript describes first results from the ongoing project Hazardous Chemicals in Plastic Packaging (HCPP). Food Packaging Forum and six partner non-profit and academic organizations  from Europe- and U.S. are involved in this research project. The scientists compiled a database of Chemicals associated with Plastic Packaging (CPPdb) and ranked human health and environmental hazards of these chemicals.

The CPPdb covers both food and non-food packaging. It currently contains 906 chemicals likely associated with plastic packaging and 3377 chemicals that are possibly associated. In addition, plastic packaging can contain impurities, degradation products, and contaminants which cannot be exhaustively compiled because many of these chemicals are not yet identified. Significant difficulties encountered during this study were the lack of transparency and restricted access to industry data, as well as gaps in publicly available information on both the use and toxicity of plastic packaging-associated chemicals.

At least 148 chemicals likely associated with plastic packaging were identified as the most hazardous based on several harmonized hazard data sources. These included the EU classifications for human health and environmental hazards conforming to the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), i.e., classifications assigned by European Chemicals Agency (ECHA) under the Classification, Labelling and Packaging (CLP) regulation; EU classification as persistent, bioaccumulative and toxic (PBT) or very persistent, very bioaccumulative (vPvB) substance; identification as an endocrine disrupting chemical (EDC) under Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) legislation; and recognition as an EDC or potential EDC in the 2018 report by the United Nations Environment Programme (UNEP) (FPF reported).

These hazardous chemicals are used or present in plastics as monomers, intermediates, solvents, surfactants, plasticizers, stabilizers, biocides, flame retardants, accelerators, and colorants, among other functions. In the next steps of the project, chemicals prioritized as candidates for substitution will be assessed in detail.

In an article by Anna Watson, published on July 19, 2018 by non-governmental organization CHEM Trust (on of the HCPP project partners), Michael Warhurst commented that “this study . . . highlights how many problematic chemicals are potentially in use, which raises concerns about how many different chemicals we could be exposed to and the need to understand what could be the effects of these mixtures.”

Read more

Anna Watson (July 19, 2018). “Hazardous chemicals and plastic packaging: What are the concerns?CHEM Trust

Reference

Groh, K., et al. (2018). “Chemicals associated with plastic packaging: Inventory and hazards.PeerJ Preprints (published July 13, 2018).

EFSA: 6th FIP network meeting on FCMs

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On July 10-11, 2018, the European Food Safety Authority’s (EFSA) Scientific Network of the food ingredients and food packaging (FIP) unit on food contact materials (FCMs), short the ‘FIP FCM Network,’ held its sixth meeting in Parma, Italy. The meeting minutes were agreed on July 27, 2018, and are now available online.

During the first day, the FIP FCM Network discussed the activities of the European Commission’s (EC) Directorate-General for Health and Food Safety (DG SANTE), EFSA, the EC’s Joint Research Centre (JRC), as well as the Council of Europe (CoE). Jonathan Briggs of DG SANTE reported on the EC’s evaluation of the EU legislation on FCMs (FPF reported). The timeframe of this undertaking foresees a supporting study to run from July 2018 to September 2019, a stakeholder consultation period from September 2018 to July 2019, publication and dissemination activities in September 2019, and finally a staff working document by early 2020. Regarding the recycling of plastics for FCMs, the EC will authorize about 140 recycling processes (FPF reported) with adoption and application foreseen for early 2019. The EC will focus on monitoring of incidental contamination and stressed that the bottom line is “safety first.” Katharina Volk of EFSA informed about the renewal of EFSA’s Scientific Panels, which held their inaugural plenary meetings in July 2018 (FPF reported). She also informed about EFSA’s ongoing activities regarding the reevaluation of bisphenol A (BPA, CAS 80-05-7) and phthalates in plastic FCMs. The opinion on phthalates is expected by the end of 2018, while the reassessment of BPA is just about to start. Human and animal hazard studies or data (published, unpublished, or newly generated) that are relevant to BPA safety evaluation can be submitted to EFSA until August 31, 2018. Eddo Hoekstra from the JRC presented a joint project with the industry association European Plastics Converters (EuPC) regarding the migration of non-intentionally added substances (NIAS) from plastic food contact articles (FCAs). Further, the JRC’s EU Reference Laboratory for Food Contact Materials (EURL-FCM) is writing monitoring guidelines for mineral oil residues in food. Also, the “Guidelines on testing conditions for articles in contact with foodstuffs (with a focus on kitchenware)” are under revision, Hoekstra informed. Eugenia Dessipri of the CoE reported that a second edition of the Council’s resolution on metals and alloys used in FCMs and FCAs is currently being prepared. Further, the Council is elaborating a resolution for all FCMs under the framework Regulation (EC) No 1935/2004 that are not covered by specific harmonized regulations at EU level. The resolution aims to provide “general principles and best practices to ensure the quality and safety of these materials” and would be complemented with “material specific technical guides.”

During the second day, Stefania Barmaz and Andrea Terron, on behalf of Domenica Auteri of EFSA, presented the guidance for the identification of endocrine disrupting chemicals (EDCs) in the field of biocides and pesticides that was developed by EFSA, the European Chemicals Agency (ECHA), and the JRC (FPF reported). Thereafter, a session on printing inks was held. Eugenia Dessipri of the CoE reported that the Council is currently working on “analytical issues related to the examination of compliance” of printed FCMs, with a special focus on photoinitiators. Stefan Kucsera of the Swiss Federal Food Safety and Veterinary Office (FSVO) and Stefan Merkel of the German Federal Institute for Risk Assessment (BfR) informed about the two countries’ joint activities on printing inks (FPF reported). Recently evaluated substances include 4-methyl-2-pentanol (MIBC, CAS 108-11-2) and analytical challenges in the safety assessment were highlighted on example of the substances 4-methoxyphenol (MEHQ, CAS 150-76-5) and 4-nonylphenol (CAS 104-40-5). Stefan Merkel further presented the European Printing Ink Association’s (EuPIA) guidance on migration test methods and the Imaging & Printing Association’s (IP) guidance on conformity of indirect FCMs. The BfR is currently preparing “a guideline for the application of adding new substances to the German Ordinance on Printing Inks” for which the EuPIA and IP guidances provide “information on conformity work.” Birgit Mertens of the Vrije Universiteit Brussel, Belgium, reported on a prioritization strategy for genotoxic substances in printed paper and board FCMs that is based on non-animal methods (FPF reported). Another session was held on paper and board FCMs. Maria Rosaria Milana, Dirk van Aken, and Stefan Merkel informed about the on-going activities regarding paper and board FCMs in Italy, the Netherlands, and Germany, respectively. Thomas Schwartz of the CoE discussed the Council’s draft technical guidance on paper and board. Gilles Rivière of the French Agency for Food, Environmental and Occupational Health & Safety (ANSES) presented the work of Eelco Nicolaas Pieke on an analytical strategy to obtain information on unknown substances in FCMs (FPF reported).

Lastly, the FIP FCM Network discussed proposals for possible follow-ups regarding scientific cooperation and activities. The next meeting of the FIP FCM Network will be planned in 2019.

Read more

EFSA (August 2018). “Scientific Network of the food ingredients and food packaging (FIP) Unit on food contact materials (FCM), the ‘EFSA FCM Network’ – Minutes of the 6th meeting.(pdf)

Proceedings of ILSI NA workshop on FCMs

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On July 24, 2018, an article was published in the peer-reviewed journal Regulatory Toxicology and Pharmacology summarizing the outcomes of the workshop “Scientific advances and challenges in safety evaluation of food packaging materials.” The workshop was organized by the North America branch of the International Life Sciences Institute (ILSI NA) and held on September 27, 2016, in Washington, D.C., U.S. (FPF reported).

The event gathered scientists from government, academia, and industry who discussed the safety assessment of FCMs, migration of contaminant residues, emerging analytical methods, exposure assessment models, and new packaging technologies. Further, the workshop focused on recycled materials in food packaging, recycling processes, contaminant residues from recycled packaging, and challenges in the safety assessment of recycled materials. The paper provides an overview of the workshop’s background and purpose as well as summaries of the featured speaker presentations.

Read more

ILSI NA (2018). “Scientific advances and challenges in safety evaluation of food packaging materials: Workshop proceedings.

Reference

Karmaus, A.L., et al. (2018). “Scientific advances and challenges in safety evaluation of food packaging materials: Workshop proceedings.Regulatory Toxicology and Pharmacology 98:80-87.

Oligomers in PBT and PEN polyesters

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In an article published on July 13, 2018, in the peer-reviewed journal Food Packaging and Shelf Life, Maria Hoppe and colleagues from the Fraunhofer Institute for Process Engineering and Packaging IVV, Freising, Germany, address oligomers in polyethylene naphthalate (PEN) and polybutylene terephthalate (PBT). Both materials are used in food contact applications, such as “microwaveable dishware, kitchen utensils and coffee capsules.”

The analyzed samples included a bottle made of PEN and plates made of PBT, obtained from “local suppliers.” The scientists used dichloromethane or acetonitrile to extract the samples for one day at room temperature or 40 °C, respectively, and analyzed the extracts for the oligomers sized below 1000 Da. In the PBT extracts, seven cyclic and three linear oligomers were identified, while in the PEN extracts, five cyclic and two linear oligomers were found. The total oligomer content was 0.34% in PBT and 0.81% in PEN material.

Migration experiments were performed for the samples of PBT plates which were immersed in 20% ethanol and stored at 40 °C or 60 °C for 30 days. Only the low molecular mass oligomers, i.e. the linear and cyclic PBT dimer and the cyclic PBT trimer, could be detected in the migrates, while the oligomers with higher molecular mass “were less abundant in the polymer and are not expected to migrate to a great extent since the diffusivity decreases with increasing molecular mass.” For the two quantifiable PBT oligomers, however, “even at a storage temperature of 40 °C after three days the migration . . . into the food simulant will exceed 50 µg/kg.”

The 50 µg/kg value for oligomer migration from PBT has not been officially defined as a migration limit, but it “can be used as an indirect migration limit since this level is considered to not raise any concern from a toxicological viewpoint,” the authors explain. They suggest that the high migration observed could be due to “swelling of the PBT polymer at elevated temperatures” and argue that “the use of ethanolic food simulants at elevated temperatures to simulate long-time storage scenarios for polyesters like PBT is debatable” (FPF reported). Based on modeling estimations, the migration values at 23 °C would be “very low” even after 900 days of storage, namely at 28 µg/kg for a 0.5 L bottle made of PBT and 2.5 µg/kg for a similar bottle made of PEN. To confirm the modeling predictions and potentially “adjust the testing conditions for polyester type polymers,” the authors call for “investigating experimentally the migration of oligomers during longer storage times at room temperature and comparing these values to accelerated migration tests.”

PBT oligomers have also been studied by Fabrian Brenz and colleagues from the Department of Chemistry and Food Chemistry, Technical University of Dresden, Dresden, Germany, who summarized their findings in an article published on December 28, 2017, in the peer-reviewed journal Food Additives & Contaminants: Part A. They analyzed “PBT pellets and the slotted spoon produced from the pellets by injection molding . . . provided by a manufacturer of plastic kitchen utensils.” Isolation of PBT oligomers was performed either by extraction in dichloromethane, acetonitrile, dimethylsulfoxide, or 20% ethanol (one hour at 60 °C) or by reprecipitation where the polymer is first dissolved, then treated in an ultrasonic bath, then reprecipitated and washed with 2-propanol. The supernatant remaining after reprecipitation and washing steps is then evaporated, and “residual oligomers” are dissolved in dimethylsulfoxide before analysis by mass spectrometry.

The total content of isolated oligomers was estimated to be around 0.8% after dichloromethane extraction or around 1% after extraction by reprecipitation. In the acetonitrile extract of PBT, 26 different oligomers sized below 1000 Da were identified in total, including cyclic oligomers, linear oligomers, and dehydration products. In addition, a cyclic pentamer sized 1100 Da was identified as well. In 20% ethanol extracts, several differences were noted compared to the acetonitrile extracts, the “major difference . . . [being] that cyclic oligomers were not detectable except for the dimer.” Therefore, the authors concluded that “although the amount of cyclic oligomers is predominant in PBT it does not seem to reflect their migration potential into aqueous foods since the dominant oligomers in 20% ethanol are the linear ones.” Similar to Hoppe and co-authors, Brenz and colleagues also questioned whether ethanol “is appropriate to be used as a food simulant for migration testing of polyesters.”

They also studied the migration of PBT oligomers in water, namely by boiling the PBT spoon in distilled water for two hours, cooling, repeating the same procedure for two more times, and using the third migrate for analysis. The sum of migrating linear oligomers amounted to 0.29 mg per item, while the cyclic PBT dimer was detected at 0.05 mg per item. According to the estimations for “a scenario in which an adult would be preparing a meal with the PBT spoon in the range of once per week to once per day (worst case),” an intake would be at “0.04 up to 0.29 mg/person per day for linear oligomers,” and “0.007 up to 0.05 mg/person per day for cyclic oligomers.” These values do not exceed the daily intake limits assigned based on the threshold of toxicological concern (TTC) considerations, namely the value of 1.8 mg/person per day for linear oligomers and 0.09 mg/person per day for cyclic oligomers. Therefore, “the migration of PBT oligomers from the tested PBT spoon could be considered as safe with regard to aqueous foodstuffs,” the authors concluded.

References

Hoppe, M., et al. (2018). “Oligomers in polyethylene naphthalate and polybutylene terephthalate – Identification and exploring migration.Food Packaging and Shelf Life 17:171-178.

Brenz, F., et al. (2018). “Linear and cyclic oligomers in polybutylene terephthalate for food contact materials.Food Additives & Contaminants: Part A 35:583-598.

Oligomers in polyester coatings for metal cans

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Polyester-based can coatings are used as replacements for epoxy-based coatings containing bisphenol A (BPA, CAS 80-05-7). During storage, polyester coatings can release non-intentionally added substances (NIAS), such as oligomers (FPF reported). Two studies published in 2018 also addressed the oligomers in polyester coatings.

An article by Emanuela Pietropaolo and colleagues from the Dipartimento di Scienze e Innovazione Tecnologica, Universita del Piemonte Orientale “Amedeo Avogadro,” Alessandria, Italy, published on October 4, 2018, in the peer-reviewed Journal of Chromatography A, presented a method for the conclusive identification and exact quantification of 16 oligomers (four linear and 12 cyclic) identified in two different types of polyester resins and final enamel can coatings. The method uses “ad hoc standards . . . synthesized by acylation reaction between alkyl diols and phthaloyl chlorides.” The different combinations of extraction conditions (at 60 °C in 95% or 50% ethanol for four  hours or ten days) “showed no significant differences between the amounts of cyclic oligomers,” as most “extracts showed only a small amount of linear compounds and a prevalence of 2 + 2 cyclic oligomers.” The authors conclude that their study “shows the great importance of the synthesis of specific standards to allow exact quantification in food contact material migrates.”

The article by Malcolm Driffield and colleagues from the Packaging and MS Solutions team at the UK research agency Fera Science Ltd. published on February 26, 2018, in the peer-reviewed journal Food Additives & Contaminants: Part A, compared the concentrations of monomers and selected oligomers in foods with concentrations after migration or extraction. The scientists analyzed two different polyester coatings, both based upon 5-norbornene-endo-2,3-dicarboxylic anhydride (CAS 129-64-6), which were “commercially applied, packed with different food stuffs, processed and stored” for various time periods between eight and 43 months. The examined foods were selected “to represent a range of aqueous and acidic processed foods” and included beans, peas, corn, tomato products, soup, pumpkin, potatoes, and Jalapeno peppers. For extraction and migration experiments, “laboratory-prepared and cured panels” coated with either coatings were used. The laboratory procedure “mimicked as closely as possible industrial application and cure in order to minimize any potential differences between the coated panels and cans tested.” Extraction was done with acetonitrile for 24 hours at room temperature, and migration was carried out in water or ethanol at 121 °C for one hour followed by ten days at 40 °C.

The results showed that (1) “migration of selected monomers into the real foodstuffs analyzed, apart from two [(cream style corn and pumpkin)], did not exceed 50 µg/kg,” (2) “migration of oligomers into 50% aqueous ethanol . . . [was] higher than that into real foodstuffs,” (3) “migration levels determined in foodstuffs following long-term storage were significantly lower than those reported for simulants exposed to a similar coating following long-term storage”; this “question[s] the suitability of those conditions to represent realistic migration; (4) “there are no obvious trends in monomer or oligomer levels associated with different foodstuffs”; therefore, the authors recommend “to determine levels in the foodstuffs of interest.”

References

Pietropaolo, E., et al. (2018). “Synthesis, identification and quantification of oligomers from polyester coatings for metal packaging.Journal of Chromatography A (published October 4, 2018).

Driffield, M., et al. (2018). “The determination of monomers and oligomers from polyester-based can coatings into foodstuffs over extended storage periods.Food Additives & Contaminants: Part A 35:1200-1213.

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