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FDA Bans the Use of Three Specific Perfluoroalkyl Ethyl Substances in Food Packaging

FDA Bans the Use of Three Specific Perfluoroalkyl Ethyl Substances in Food Packaging

YY TSANG

(CMA Testing and Certification Laboratories)



Perfluoralkyl Ethyl Substances

Perfluorinated compounds (PFCs) refer to a group of synthetic and stable chemical compounds, including perfluoroalkyl ethyl substances. Since PFCs can repel oil and water, they are commonly used in surface coating for food packaging materials (e.g. pizza box).


Image Source: Newswatch Report, 2016

http://newswatchreport.com/item/234346_fda-ban-pizza-boxes-could-cause-birth-defects


However, more and more evidences are showing perfluoroalkyl ethyl substances may be toxic. For example, perfluorooctane sulfonic acid (PFOS) and perfluorooctanoic acid (PFOA) can accumulate inside human bodies for many years, and affect our respiratory system and immune system, as well as lead to birth defect and other undesirable consequences. Peoples start to worry if perfluoroalkyl ethyl substances will migrate from food packaging materials to food, and then cause adverse health effects in humans.


Detection of PFCs in Food and Water

A U.S. report states that PFCs have been detected in different types of foods at reported concentrations ranging from 0.05 to 10,000 ng/g fresh weight 1. However, food packaging is not the major source of PFCs in food. Indeed PFCs have been used extensively as surface active agent and additive in industries. They are very stable in the environment (air, water and soil) after use. PFCs can pass up the food chain and bioaccumulate in food animals and plants.

1 Source of Information: CDC, 2015

http://www.atsdr.cdc.gov/toxprofiles/tp200-c2.pdf


On the other hand, an environmental group in Hong Kong has earlier reported that water samples from five local reservoirs storing drinking water were detected with PFCs. Among those reservoirs, Plover Cove Reservoir contained the highest amount of PFCs ranging from 8 to 15 ng/L 2. However, all the test findings were still far below the provisional advisory values of EPA (400 ng/L for PFOA and 200 ng/L for PFOS).

2 Source of Information: Greenpeace, 2015

http://www.greenpeace.org/hk/press/releases/toxics/2015/11/five-reservoirs-contain-pfcs/


Image Source: Appledaily, 2015

http://hk.apple.nextmedia.com/news/art/20151202/19395820


FDA Bans the Use of Three Specific Perfluoroalkyl Ethyl Substances in Food Packaging

In United States, several environmental and food safety groups once requested the government to prohibit the use of specific perfluoroalkyl ethyl substances in food packaging. After evaluation, FDA published a final rule on 4 Jan 2016 that three specific perfluoroalkyl ethyl substances (with long-chain) are no longer allowed to use as oil and water repellants for paper and paperboard in contact with aqueous and fatty foods 3.

3 Source of Information: Federal Register, 2016 https://www.federalregister.gov/articles/2016/01/04/2015-33026/indirect-food-additives-paper-and-paperboard-components


Regulatory Control of Food Contact Materials in Hong Kong

In Hong Kong, there are two departments sharing the responsibility to control food contact materials.


Customs and Excise Department (C&ED)

Under the Consumer Goods Safety Ordinance (Cap 456), it is not allowed to manufacture, import or supply consumer goods (e.g. food containers) not complying with the general safety requirements for consumer goods. C&ED will collect consumer goods supplied on the local market for safety testing (e.g. Bisphenol A migration)


Food and Environmental Hygiene Department (FEHD)

If food is rendered unfit for human consumption due to problematic food contact materials, it would be an offence to sell such food under the Public Health and Municipal Services Ordinance (Cap. 132). Moreover, the Food Business Regulation also stipulates that any person carrying on a food business shall ensure all equipment and utensils are kept clean and free from noxious matters.


However, both departments have not clearly specified whether food contact materials are allowed to contain aforementioned perfluoroalkyl ethyl substances and other PFCs, or the relevant tolerance levels. In order to enable stakeholders (e.g. food trade and consumers) to assess the safety of a food contact material “objectively”, Hong Kong government should adopt U.S. approach and clearly specify food contact material standards. This shall enhance food safety regulatory functions.

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