FCM are an underestimated source of food contamination

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Oswald Webb
7 years ago
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1 Gesundheitsdirektion Gregor McCombie, Kantonales Labor Zürich The FCM dilemma: Ideas for aligning reality with the requirements FCM are an underestimated source of food contamination Pesticides FCMs Number of Substances ~100 Possibly 100,000 Level of food contamination µg/kg mg/kg Toxicological evaluation yes mostly no 1

2 3 My job in a nutshell Enforce Article 3 of Regulation 193/00 Most importantly: FCM shall not release substances into food at amounts which could endanger human health This article applies to ALL FCM irrespective of whether there is harmonised legislation or not (non-harmonised) All consumers including babies and other extreme eaters This is an impossible task to fulfil Bridging the Gap There is a dangerous gap between reality and legal requirements! Currently neither enforcement nor the legislator nor industry can do their job without risk of being hurt.

3 Polyolefin extract by -dimensional gas chromatography (GCxGC) Oligomer content: 1000 mg/kg Number of substances >1 mg/kg: 9 Number of substances mg/kg: 0 Polyproylene POSH Polyolefine POSH internal standard 1 mg/kg Irgafos 168 Unknown monoglycerides internal standard 0.1 mg/kg 6 What next? (View from enforcement) Quantify migration of substances that are regulated in 10/011 List has ~900 substances but standards available for only ~0 EURL has no means to get hold of all standards (needed for many types of analysis) Lack of information on human exposure Quantify migration of other substances (NIAS) Analytically even harder Risk assessment not possible in many cases as identity unknown Ask manufacturer under 03/006 what is in the product and what has been assessed What can be done if manufacturer does not reply? What can be done if work from manufacturer is insufficient? What measures can be taken if non-compliance is found? Advise to correct; ban sales; ban import; compulsory recall from consumers or limited fines All act on local business 6 3

4 7 Effective solutions for the future? Compliance work based controls It is a requirement to provide information to enforcement Enforcement should routinely use this in their work and verify information obtained this way RASFF (lack of adequate compliance work) An easy measure to implement Was undesired in European enforcement campaign in 013 Fines for companies not addressing issues (also outside local enforcement area) Big change to food legislation! Would introduce a more effective enforcement measure Work plans Pragmatic solution to deal with the gap and large scale breaches of legislation Industry and risk assessment agree on a long term plan to fill the gaps for FCM materials As long as the plan is being executed and the situation improves for consumers the current situation is tolerated by enforcement 7 8 Take home messages Food contamination by food contact materials is an underestimated issue There is a huge gap between requirements and reality Existing resources can and must be used more efficiently but new concepts for legislation, enforcement and compliance in the area of FCM seem inevitable 8

5 9 Further reading Overview paper from 006 unfortunately there has been very little change since: Grob et al. Critical Reviews in Food Science and Nutrition, 6:9 3 (006) Paper from earlier slide with GCxGC plot: Compliance work compared to analytics in most common plastic McCombie et al. Food Control 9 (016) Europe wide enforcement campaingns: McCombie et al. Eur. Food Res. Technol. 01 McCombie et al. Food Control 0 (01) 6-71 How work plans could work: Grob; Food Control 6 (01) )

SWISS ORDINANCE ON MATERIALS AND ARTICLES IN CONTACT WITH FOOD (SR 817.023.21) Permitted Substances for Packaging Inks. Questions & Answers

SWISS ORDINANCE ON MATERIALS AND ARTICLES IN CONTACT WITH FOOD (SR 817.023.21) Permitted Substances for Packaging Inks Questions & Answers Page 1 of 5 The Swiss Federal Department of Home Affairs (FDHA)