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Food packaging chemicals are not disclosed, and in many cases we don’t have toxicology or exposure data. Yet a core component of the FDA’s regulation of food contact materials is based on the assumption that these substances may migrate into and be present in food.
In fact, the FDA’s system for approving food contact materials, which it does on an individual basis, with approval granted to a specific company for a particular intended use, depends on how much of a substance is expected to migrate into food. This is assessed based on information a company submits to the FDA, the FDA may come back to a company with questions and do its own literature search,
But there’s more than the threshold of migration that needs to be considered when assessing food contact material safety. In addition to the materials themselves, these substances’ chemical breakdown and by-products need to be considered. This means that there are lots more individual chemicals that may be touching food, and therefore be detectable in food, than those present in the packaging as formulated. For polymers, these breakdown and by-products can be significant.
These additional breakdown and by-product chemicals also contribute to issues of chemical safety assessment. Chemical regulations typically consider chemicals one at a time, when in reality we’re exposed to multiple chemicals concurrently, including those present in food. So the individual chemical assessments that determine food contact material approvals may not capture all the ways in which a single substance may interact with food, human bodies or the environment.
Back in the 1950s, the scientific assumption was that the higher the level of exposure, the greater a chemical’s biological effect. The focus of concern then was acute effects: birth defects, genetic mutations and cancers. Since the mid-1980s, however, and especially in the last 10 to 15 years, scientific evidence indicating that low levels of exposure, particularly to chemicals that can affect hormone function, can have significant biological effects has been accumulating rapidly. So has evidence that such exposures can lead to chronic effects on metabolic, reproductive, neurological, cardiovascular and other body systems and can set the stage for health disorders that may take years to become apparent. Yet from an FDA regulatory perspective, such low dose effects are very much still under review as they are, for example, for bisphenol A, a building block of polycarbonate plastic that is used widely in food contact products, has become a focal point in the public debate over safety of food contact materials. More information, please visit: .