The FDA document, an update on the original 1994 report, addresses the need to safeguard against chemical contaminates in recycled plastic. The concern is that recycled plastics that once contained chemicals, such as cleaning supplies, may appear in the final food-contact packaging made from the recycled material.
The general trend in the packaging industry is to embrace recycling, which is defined by the FDA as the processing of waste into new articles. The switch has been driven by environmentally-conscious consumers and recycling regulations. The development is also being pushed by the constantly escalating price of oil, which has increased the price of traditional petroleum-based polymers.
The document deals specifically with plastics and ways to estimate chemical contaminate levels. Other recyclable materials such as glass, steel, aluminum and paper are either impervious to contaminates or are monitored thoroughly to make sure they meet FDA regulations regarding recycled packaging.
The most significant change made by the FDA from the original recommendations include a lowering of estimated daily intakes of chemical contaminates from 1 part-per-billion (ppb) to .5 ppb of a person's total daily concentration. This is the level contaminants that the FDA recognizes as a negligible amount, which can be highly dependant on the way a recyclable material is processed.
The processing of recycled materials is divided up into three sectors based on the techniques and materials involved, according to the FDA. Primary recycling is the use of industrial scrap to form new packaging articles. The FDA accepts that this form poses almost no threat to consumers.
Secondary recycling is the grinding, melting and reforming of plastic. The FDA states that processors must be able to demonstrate that contaminate levels in secondary products are negligible and that the material is pure. The FDA says that risks in this process can be averted by stringent sorting and material sourcing.
Tertiary recycling, type three, also poses a risk because it deals with regenerating purified starting plastic polymers through chemical reprocessing and blending.
FDA findings indicate that the risk from secondary and tertiary recycling does not pose a substantial risk to consumers. However, the FDA is worried that continued reprocessing of similar materials will allow potentially hazardous materials to collect in the recycling pool over time.
The FDA notes that the recommendations in their report are not legally enforceable responsibilities. Law regarding recycled plastic packaging is dealt with in the FDA Code of Federal Regulations.
The FDA document provides an extensive amount of equations and suggestions to be used by manufacturers and processors to calculate the safety of their packaging. The full report is available at:http://www.cfsan.fda.gov/%7Edms/opa2cg3b.html