Table 2 Topics of concern (based on Table 2 [1]) and examples of activities addressing them. This is not a complete and comprehensive overview but rather a starting point for further discussions that essentially need to involve many stakeholders (see Table 1)
From: Impacts of food contact chemicals on human health: a consensus statement
Area | Topic | Description | Example |
|---|---|---|---|
A. DATA GAPS | 1. Information on chemicals used in food contact materials | Characterize types of chemicals used in the manufacture of FCMs and FCAs, their functions and levels | [67] |
2. Information on non-intentionally added substances | Compile existing information, develop strategies and work plans to fill data gaps | ||
3. Information on migration of food contact chemicals | Provide systematic overview of evidence for migration from FCMs and FCAs | [130] | |
4. Empirical exposure data | Measure migration into actual foods, assess intake for different demographics (age groups, ethnic and regional diversity) | ||
B. METHODOLOGY GAPS AND NEEDS | 5. Comprehensive definition of adverse effects | Expand the scope of toxicological testing requirements to include non-cancer related endpoints such as effects on the nervous, immune and endocrine systems, and cardiovascular and metabolic effects | |
6. Approaches to addressing non-monotonic dose response | Develop practical tools for use in chemical risk assessment of FCCs | [119] | |
7. Approaches to addressing mixture toxicity | Develop overall migrate testing for finished FCAs that can be used in the regulatory context, including standardized sample preparation | [141] | |
8. Develop a framework to address aggregate exposures | Integrate exposure information from different legislative areas when setting safe exposure thresholds | [142] | |
9. Develop a framework to address cumulative exposures | Assess the safety of exposures to different chemicals through the same or different exposure routes | ||
10. Modernize tiered approach for screening and prioritization | Include additional relevant endpoints for toxicity testing, include testing of finished FCA | ||
11. Compile information on human health outcomes of exposure to FCCs | Assess systematically the available evidence for how FCCs adversely impact human health; highlight data gaps showing the need for appropriate longitudinal studies that assess food contact chemicals | [130] | |
C. UPDATE REGULATORY PROCESSES | 12. Overall regulatory framework for evaluation beyond sector-specific regulations | Combine chemical hazard and possibly risk assessment for different sectors in one legal framework | |
13. Requirements for data on use of FCCs | Based on the principles of REACH, set legal requirement to provide information about chemical use for market access | ||
14. Need to reassess substances authorized for use and/or generally recognized as safe | Policy instruments for removing authorized chemicals e.g. indirect food additives, EU starting substances and additives for plastic FCMs | ||
15. Address bias in risk assessment | Ensure that scientific judgement is placed in context of personal values, acknowledge other sources of bias and balance expert groups accordingly | ||
16. Ensure transparency of decisions | Communicate potential or real bias of decision makers and experts making recommendations for decision makers | ||
17. Improve enforcement | Raise awareness to provide resources for enforcement authorities to expand activities | [136] | |
18. Multi-stakeholder dialogues on practical solutions | Address two key topics: 1.) Definition of safety for FCCs: update according to current scientific knowledge; 2.)Food packaging in the circular economy: chemical safety considerations | ||
19. Integrate food packaging waste and safety considerations | Policy must address both aspects simultaneously to avoid conflicting goals | [138] | |
D. REPLACING HAZARDOUS FCCs | 20. Developing safer alternatives | Based on revised definition of safety and updated toxicity testing; develop screening assays for endocrine disruption and other relevant endpoints | |
21. Testing finished food contact articles | Use combination of toxicity testing and chemical analysis (“Effect-directed analysis”) to screen for hazardous but unknown FCCs | [95] | |
22. Integrating human health with environmental considerations: life cycle approach | Develop integrative assessment for environmental and human health impacts, e.g. using life cycle analysis or other method | [144] | |
23. Update sustainable packaging concept | Define sustainable packaging to also include aspects of human health protection that are based on current scientific understanding |