The chemical toxicity of food contact materials (MOCAs) is a risk as well known as it is underestimated. 33 internationally renowned researchers-in a paper just published in Environmental Health-launch an appeal. (1) There is an urgent need to call together the entire scientific community and policy makers to correct regulations and protect the health of populations.
Chemical toxicity of packaging, the evidence
Migration of chemicals in food contact materials is certain. About 1,200 scientific studies (validated and published) have been devoted to this phenomenon, which has been the subject of research since the 1950s.
Chemicals that migrate into food through packaging, containers, dishes and any other food contact materials fall into two categories:
– Substances intentionally added in the manufacture of MOCA. Such as phthalates and BPA (bisphenol-A), which are used in many articles made of plastic materials,
– substances derived from additive reaction processes or impurities in materials, theNon-Intentionally Added Substances (NIAS). Factually unknown, untested molecules that go into mixes whose health impact ( cocktail effect) is generally devoid of risk analysis.
Thousands of chemicals in contact with food
There are 12 thousand substances globally authorized in MOCAs. In Europe, adding those listed by EU standards and others used in member states, 8030 are used. In the United States-of the 10,787 substances allowed as direct or indirect food additives-about half are for so-called FCMs(Food Contact Material).
In the U.S., all those substances not registered or notified to theFood and Drug Administration (FDA), whose use is tolerated based on the GRAS principle, Generally Recognized As Safe, are added. (2)
The dangerousness of these substances depends on toxicity and population exposure. Two data not always available. According to the authors of the paper under review, data on the toxicity of many substances currently used in MOCAs are partial or absent. And never do they refer to the toxic effects on the endocrine system, despite the correlations repeatedly pointed out by science.
Toxic molecules allowed in MOCAs in EU
Highly toxic are those substances that theRegistration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation qualifies as ‘extremely problematic’ (SVHC, Substance of Very High Concern), i.e. with an unacceptable risk profile. We refer to carcinogenicity, mutagenicity, reproductive toxicity, endocrine disruption.
The REACH regulation does not regulate the substances allowed in MOCAs. But it offers a comprehensive overview of chemicals authorized in the European Union, including those used in MOCAs. And some of these substances, when used in contact materials, migrate into food and beverages. The researchers cite various ortho-phthalates, PFAS (per- and polyfluoroalkyl substances), perchlorates as examples.
Toxic chemicals, an undercurrent evil
Population health risk assessment of substances used in MOCAs is commonly based on assumptions or estimates. However, the authors of the paper under review point out that to date the actual scenario is ignored. Exposure to toxic chemicals-as already highlighted in a recent British study-does indeed come from MOCAs but also from a myriad of everyday objects, including textiles and personal hygiene products.
Doctors and epidemiologists on the other hand have not yet been able to identify a direct causality between chemical offending and the onset of the most serious diseases. Outside of endocrine disrupting cases, linearly associated with some substances (e.g., BPA, phthalates). Yet, ‘the additional costs of diseases related to exposure to endocrine-damaging chemicals are significant, with annually $340 billion in the US and $217 billion in the EU,’ the researchers explain.
The agenda of experienced researchers
The appeal to policymakers, regulators, food packaging manufacturers, civil society and scientists all is‘to turn more attention to the safety assessment of food contact chemicals, an important opportunity for the prevention of chronic diseases associated with hazardous chemical exposures.’
7 areas of urgent action are indicated by experts:
1-remove hazardous chemicals from food contact materials. Therefore, review the list of authorized ones and eliminate the SVHC ones,
2 – develop safer alternative substances by conducting hazard identification and characterization before large-scale use of FCCs,
3- update the risk assessment criteria, based on current scientific knowledge. Substances authorized for food contact that are currently in use should be reevaluated accordingly, with transparent procedures,
4-include the risk of endocrine disruption in the evaluation of all chemicals migrating from MOCAs and those intentionally added,
5- ascertain the toxicity of mixtures of chemicals used in MOCAs for serious hazards, such as genotoxicity, mutagenicity and endocrine disruption,
6-strengthen regulations and equip supervisors with appropriate resources. (3) Migration of carcinogens into food must be absolutely ruled out,
7 – finding practical solutions, through a dialogue with all stakeholders(multi-stakeholders). In order to identify sustainable solutions, centered on the goal of protecting humans and the environment through packaging that is both safe and consonant with a circular economy.
Instead, the European Commission is latent. After delaying the dutiful measures on endocrine disruptors, it has just now postponed for two years the draft comprehensive review of the regulation of MOCAs. Chemical safety remains unprotected.
Marta Strinati and Dario Dongo
Notes
(1) Muncke, J., Andersson, A., Backhaus, T. et al. Impacts of food contact chemicals on human health: a consensus statement. Environ Health 19, 25 (2020). https://doi.org/10.1186/s12940-020-0572-5
(2) The GRAS principle(Generally Recognized As Safe)-adopted in the U.S. on contact materials (see https://www.fda.gov/food/food-ingredie nts-packaging/generally-recognized-safe-gras) and other substances that become part of food (e.g., food additives, pesticides) is emblematic of the radical dissimilarity of approach to food safety. Where GRAS in fact allows all substances that have not been determined to be hazardous to be placed on the market.
The precautionary principle that applies in the EU, on the other hand, involves banning the use of any material whenever there is doubt about its safety and there is a lack of scientific consensus that it poses no risk to food safety and the environment
(3) Controls and sanctions on Food Contact Materials and Objects are entrusted in Italy to the ASLs, through Legislative Decree. 27/17 (v. https://www. foodagriculturerequirements.com/archivio-notizie/moca-materiali-e-oggetti-a-contatto-con-gli-alimenti-le-sanzioni-in-italia_1). And by what means can inspection personnel be trained, ‘without any increased burden‘ on public finance, as stipulated in that decree?
Professional journalist since January 1995, he has worked for newspapers (Il Messaggero, Paese Sera, La Stampa) and periodicals (NumeroUno, Il Salvagente). She is the author of journalistic surveys on food, she has published the book "Reading labels to know what we eat".
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
