Issue link: http://palletcentral.uberflip.com/i/1115386
FAQS iStockphoto.com/MaksimYremenko Q. If EPA regulates, what requirements does the chemical have to meet? A. EPA regulates these chemicals as "pesticide chemicals." In order to be used lawfully under FIFRA, the chemical must be registered with EPA as a pesticide, and its use must be consistent with – and cannot exceed –those uses that are authorized under the registration. Q. If FDA regulates, what requirements does the chemical have to meet? Does the chemical have to be GRAS? Does it have to be FDA-approved? What is the difference? A. FDA regulates these chemicals as "food additives." The FFDCA broadly defines "food additive" to include any substance whose intended use affects or could affect the characteristics of any food, including substances used in food packaging and in food contact materials. An antimicrobial that has an effect on a food contact article other than the surface meets the definition of "food additive." A food additive can only be used lawfully if FDA has issued a regulation that specifies the conditions under which use of the additive is safe. Substances that are "generally recognized as safe" for their intended use ("GRAS") are exempt from the definition of "food additive." In order to be GRAS, a substance must be generally recognized, among qualified experts, as having been adequately shown to be safe under the conditions of its intended use. Whereas FDA must issue a regulation to authorize the use of a food additive, no regulation is required if a specific use of a substance is GRAS. Importantly, while only FDA can issue a food additive regulation, private persons can determine that a use of a substance is GRAS. Importantly, it is not enough for the substance to be "generally recognized as safe;" rather, the substance must be "generally recognized as safe" for the particular intended use. So even if an antimicrobial chemical is GRAS for other purposes, it must also be GRAS for antimicrobial treatment of food contact articles in order to be used to treat pallets and crates. Q. How do I know if a chemical I'm interested in using is GRAS for my intended use? A. There are several means by which a chemical may be deemed GRAS. Some GRAS uses of substances are listed in FDA regulations Certification for Wood Packaging Wooden pallets are considered "transportation equipment" under the Food and Drug Administration (FDA) Final Rule on Sanitary Transportation of Human and Animal Food, and subject to the regulation. The Safe Quality Food (SQF) Institute offers certification for every supplier to the food industry, including packaging and shipping materials, to ensure that the pallets are meeting this FDA regulation. If your customers are requesting that you demonstrate compliance with the FDA rule, one option to explore is certification. There are different levels of SQF certifications for small businesses or large chain corporations. Learn more at: www.sfqi.com. An antimicrobial that has an effect on a food contact article other than the surface meets the definition of "food additive." 16 PalletCentral • January-February 2019 palletcentral.com