The 8th Food Packaging Forum (FPF) workshop on “Improving the chemical safety of food contact articles: Linking policy-making with scientific research” took place on October 21-23, 2020. This year the FPF workshop was a web-based event only, which nevertheless provided a good opportunity for networking and discussions among the more than 200 registered participants. On October 23, 2020, six speakers gave short overviews of their topics, before all of them joined the general discussion on the advancement of scientific research and policy making to improve FCM safety.
In the first presentation, Jonathan Kaplan, Sustainability Specialist at the Compass Group, US, explained the single-use material scorecard that is being developed by a broad coalition of food service providers and non-governmental organizations (NGOs). Kaplan stated that the verification of claims made by packaging producers was identified as a difficulty in evaluating the best solution to tackle the problems caused using single-use packaging. Therefore, the group decided to build a free scorecard to educate the food industry about the impacts of disposables and to show how reusable alternatives compare. The scorecard is based on six metrics, i.e., climate, water, sustainable sourcing, recoverability, plastic pollution, and possible chemicals of concern. Detailing the latest matrix, Kaplan showed a tiered system based on different lists of chemicals of concern.
Ian Cousins, Professor at Stockholm University, Sweden, shared his insights into the essential use concept by using the example of phasing out hazardous substances. Because of the large number of hazardous substances and their broad range of uses, it is impractical to completely ban them in one step. Cousins and his colleagues examined the successful phase-out of substances depleting the ozone layer that was published in the Montreal protocol and applied this idea for per- and polyfluoroalkyl substances (PFAS). They defined and categorized the uses of PFAS as “essential”, “substitutable” and “non-essential”. For food packaging, Cousin’s group judged most applications to be non-essential or substitutable uses, which thus would not hinder a phase-out of PFAS but drive innovation.
State-level actions on hazardous chemicals in food contact materials (FCMs) in the US were the topic of the presentation by Lisa Cox who is a Senior Toxics Reduction Analyst at the Oregon Department of Environmental Quality, US. Cox shared the state government perspective by describing the federal regulatory scenario and the roles of the US Food and Drug Administration (FDA) and the US Environmental Protection Agency (EPA). In addition, she explained how federal agencies and states interact to implement and enforce laws. With respect to PFAS, most states have been focusing on drinking water and measured emissions into the environment rather than levels of these hazardous chemicals in products, Cox pointed out. However, some states, such as Iowa and Washington, took independent actions to reduce PFAS in food packaging (FPF reported).
Claudia Roncancio Peña, Head of Food Ingredients and Packaging Unit at the European Food Safety Authority (EFSA), introduced EFSA’s perspective on advancing research on food contact materials (FCMs) and their risk assessment. While preparing the publication of the European Green Deal (FPF reported), the European Commission asked ESFA for specific input on the EU Chemicals Strategy for Sustainability (CSS), Roncancio Peña reported. As a result, EFSA and the European Chemicals Agency (ECHA) published a joint position paper on the “one substance – one assessment” approach (OSOA) which is based on three pillars. The first of these pillars is a central coordination mechanism, the second a better distribution of tasks between the agencies, and the third pillar concerns access to available data in the same structured format. The starting point would be better coordination between all agencies, improved IT tools, access to the data and underlying studies. To facilitate the OSAO approach, similar expertise is needed in all agencies, Roncancio Peña pointed out. Pilot projects for the risk assessment of FCMs are planned to advance FCM research and risk assessment.
Xenia Trier, Expert on Chemicals, Environment and Health at the European Environment Agency (EEA), presented the EU CSS and its implications for FCMs (FPF reported). According to the CSS, chemicals shall be used and produced in a way that maximizes their benefits while avoiding harm to humans and the environment, Trier explained. In addition, it aims at the production of safe and sustainable chemicals that shall become the EU market norm and a global standard by strengthened legislation, simplifying and consolidation, and boosting innovation. Tools to reach these aims include the design of safe and sustainable chemicals, materials, products, and processes which are based on comprehensive knowledge. Trier illustrated these approaches by showing examples of FCMs that could be affected by the CSS.
In the last presentation of the session, Natacha Cingotti, Senior Policy Officer from Health and Environment Alliance (HEAL), reflected the efforts from an NGO coalition in revising the European FCM regulations. As a starting question, Cingotti asked how regulations can guarantee the safety of FCMs since several limitations are currently not addressed (e.g., no harmonized regulations for many types of FCMs, focus on starting substances but not final products, issues with chemical safety of recycled products). Cingotti described a significant gap between the claims and the reality that was already identified by the EC’s Joint Research Centre (FPF reported). Civil societies are calling for change, because they see the need for policy makers to increasingly take scientific evidence into account, Cingotti explained. In 2018, a group of 25 European civil society groups published five key principles for reform of the FCM legislation (FPF reported). Currently, there are more opportunities to suggest changes in the regulation, e.g., by contributing to the Inception Impact Assessment of the FCM legislation that is announced to be launched in November 2020, Cingotti concluded.
Claudia Roncancio Peña (October 23, 2020). “Advancing FCM research and risk assessment: A perspective from the European Food Safety Authority.” (recorded presentation not available)
Kathryn Carlson (October 22, 2020). “Clear ‘essential use’ definition key for safer chemical alternatives, says Envi vice-chair.” Chemical Watch
Leigh Stringer (October 22, 2020). “Essential use concept could lead to ‘unjustified’ regulatory measures, says AmCham EU.” Chemical Watch
Clelia Oziel (October 22, 2020). “Science team behind ‘essential use’ in EU strategy set to refine PFAS criteria.” Chemical Watch
Jean-Philippe Montfort (January 7, 2021). “Guest Column: How does the concept ‘essential use of PFASs’ fit the current legal framework in Europe?” Chemical Watch