Dear Sir/Ma’am,
Well, one of my beloved European Commission tweeted
that “are EU rules on food contact materials fit for purpose? My answer is no
because of the large number of food contact materials (more than 100,000) are
present. It is also impossible to cover more than 100,000 FCMs. The most
important challenge is how we can trace of large number of food contact
materials? Thus, enforcement is very difficult on food contact materials not
only in Europe but all over the world. I am not an expertise on FCMs but as a Distinguished
Chemist I have some basic concept on FCMs. As an Independent Research Analyst,
I have observed most of the food manufacturing companies have too much clout.
They never inform to their customers or end users what they produce on FCMs
including plastics, ink, adhesives, coatings, paper, metal, glass etc. Hazardous
substances are leached from food packaging into packaged food items. They must
inform to their customers or end users on FCMs which have safe chemical,
microbiological quality and most importantly fulfill the European Commission
Framework Regulation No. 1935/2004. We need a broad discussion of how to ensure
the European Commission Framework Regulation No. 1935/2004 are controlled and monitored.
At present, there is a large gap between the European Commission Framework
Regulation No. 1935/2004 and FCMs. We should be bridged European Commission
Framework Regulation No. 1935/2004 and FCMs by introducing member states action
plan on the sustainable use of pesticides, establishment of member states
recycling collection service, packaging materials should contain at least 30 to
40 percent recycled plastics, increase recycling of plastic bottles and cans
through deposit refund scheme etc. Current data must be transferred along with
supply chain according to the European Commission Framework Regulation No. 1035/2004.
However, this regulation has not been properly implemented by authorities. I
conclude that the EU rules on FCMs are insufficient to protect the public
health. We need novel approach to protect the public health. We have
significant issues on FCMs that need to be addressed.
I propose some of the key recommendations on FCMs that
do not migrate into food to keep food safe.
Recommendations:
1. All FCMs designed for contact with food must meet
the European Commission Framework Regulation No. 1935/2004 safety requirements
before they are allowed to enter into the EU single market.
2. I have studied in Polymer Chemistry, I learned unidentified
chemicals were reported in all plastic samples. It indicates that we won’t be
able to predict the known chemicals including impurities while manufacturing
plastic FCMs. As a result, it is impossible to analyse the known composition of
the starting substance. This is one of the major obstacles for safety
assessments using plastic FCMs. It makes enforcement of regulatory levels
impossible. IMHO, plastic FCMs are dangerous for our citizens. We should ban
the use of plastic FCMs in food packaging.
3. Large number of chemicals is present in FCMs
because of that enforcement on FCMs is very difficult. Thus, we have to limit
the FCMs below 100 so that it can be effectively controlled by enforcement.
4. If any FCMs owing to lack of resources or safety assessments
or dangerous to our health we should ban the use of that FCMs in food
packaging.
5. European food manufacturing companies should be
required to certify that all food packaging is safe. The EU Food Information
for Consumers Regulation should simply have oversight to verify that FCMs do
not migrate into food. This should be done for all EU member states produced
food items and all foreign food items imported into the EU. This would be done
by private companies who have standing up for the public interest in the truth
and high societal responsibility. In addition, private companies should
strictly regulate hazardous substances that can be released into the
environment. Private companies should not ignore the European Commission
Framework Regulation and safety standards on all FCMs. Private companies should
not lie to the public. If private companies lied to the public on FCMs, it
creates needless hysteria. Thus, the EU Food Information for Consumers
Regulation keep an eye on private companies all time so that we can protect
public health.
6. The EU Reference Laboratory for FCMs do lot of
testing and blocks hazardous substances in food packaging. We should not allow
any institutional corruption in the EU Reference Laboratory for FCMs. If we allowed
big food companies paying many millions Euro on lobbying, it undermines
everything. I just mean it.
7. I have seen many grocery store has contract with
pesticide company to spray the whole area with insecticides once in a month or
once in two months to keep the bugs out of Vegetables, meats and other grocery
items. We can’t assume anything safe when we buy at grocery store. The EU Food
Information for Consumers Regulation keeps an eye on all grocery stores in
Europe. This will lead to better production of public health.
8. If we want to pursue toxicological testing, we
should have the knowledge of FCMs for instance, identity and availability of
FCMs. Moreover, we need sufficient quantity to perform toxicological testing. What
we are missing is systematic legally required methodology to ascertain what
chemicals are in food to determine their toxicity? How can we enforce the legal
migration limits if standard for analytical method calibration not available
for FCMs.? How can we do toxicological testing for Non-intentionally added
substance? If we wanted to does toxicological testing for Non-intentionally
added substance which has to fulfill some of the requirements like knowledge of
its identity and its availability and more quantity to perform its toxicological
testing. These requirements are not fulfilled for Non-intentionally added
substance. How can we assess safety for Non-intentionally added substance? Thus,
if any FCMs failed to provide supporting documentation such as Declaration of
Compliance and In house Documentation we should ban those FCMs. The
toxicological testing reported by food manufacturing companies should be
checked by the risk assessment and risk management authorities. Improving risk
assessment and risk management on FCMs will lead to better protection of public
health.
9. The European
Commission should publish what are the approved substances and materials on
FCMs so that European food manufacturing companies strictly use those FCMs.
Similarly, European Commission should publish what are the hazardous substances
on FCMS that migrate into food so that European food manufacturing companies
avoid those FCMs.
I have said so earlier, I am not an expertise on FCMs.
We need broad discussion in the wider scientific community to ensure that FCMs
do not migrate into food.
Thanking you.
Respectfully yours,
Athinarayanan
Sanjeevraja
Tamil Nadu
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