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Post-consumer plastic food contact testing

The use of plastics that contact food are regulated by the US Food and Drug Administration (FDA), as well as under the Code of Federal regulations 21 CFR 177, which provides guidance for testing of polymers used to store, package, and hold foodstuffs. However, it is important to note these CFR codes are applicable only to virgin plastic materials. Post-consumer plastics present a unique challenge, given that the incoming waste stream from curbside pick-ups may involve bottles previously used to store pesticides, motor oil, or cleaning solutions. This problem is most severe for plastics recycling for which the majority of tertiary (end user) recycling comes from curbside pickups as opposed to paper recycling, for which most of the recycling involves printer paper from businesses (“office white”) rather than home scrap.

Surrogate testing for material recycling for food contact

The FDA recommends surrogate testing for all types of material recycling for food contact. This process involves contaminating the material with representative surrogates, running the material through the recycling process, and subsequently analyzing it for the presence of surrogate contaminants. The outcome should result in a product with a dietary exposure of less than 0.5 ppb of each contaminant in the diet, which corresponds to < 1.5 ug/day estimated daily exposure, as this is the level which produces no observable effect from both acute and long-term exposure, including risk of cancer.

For plastics, it is recommended to soak the plastic material with a cocktail of a mix of volatile polar, volatile non-polar, heavy metal, non-volatile polar, and non-volatile, non-polar materials. For example:

• 10% v/v Chloroform;
• 10% v/v Toluene;
• 1% v/v Benzophenone;
• 1% Tetracosane;
• 1% Copper (II) 2-ethylhexanoate, and
• The balance being 2-propanol and hexane.

The plastic should be soaked for 2 weeks at 40C, drained, rinsed and then tested for the surrogates.

Obtaining approval for post-consumer trash to re-enter the food chain in the US

The Agency will be confident that the recycling process will result in plastic which can safely re-enter the food chain in the US, regardless of variations in the incoming stream of post-consumer trash, if the surrogates are cleared by the process.