SCIENTIFIC PININ Scientific pinion on the safety evaluation of the substance, Methacrylic acid, 2,3-epoxypropyl ester, copolymer with acrylic and/ or, for use in food contact materials 1 EFSA Panel on Food Contact Materials, Enzymes, Flavourings and Processing Aids (CEF) 2,3 European Food Safety Authority (EFSA), Parma, Italy This opinion, published on 7 June 2012, replaces the earlier version published on 31 May 2012 4 ABSTRACT This scientific opinion of EFSA deals with the safety evaluation of the substance methacrylic acid, 2,3- epoxypropyl ester, copolymer with acrylic and/ or, REF. No 65841 and FCM Substance No 958, for use in PVC coatings for food cans. Migration tests with a representative substance, methacrylic acid, 2,3-epoxypropyl ester, copolymer with methacrylic acid, ethyl ester, showed that migration of the monomers was not detectable (detection limit below 0.02/6 dm 2 ) while the migration of oligomers with a molecular weight below 1000 Da was up to 0.016 mg/6 dm 2. No chlorinated species were detected. The oligomeric fraction and the corresponding chlorinated oligomers were tested in three in vitro and two in vivo genotoxicity tests and they were considred as non-genotoxic. Based on the available results of these genotoxicity tests, the Panel considered that there is no concern with respect to genotoxicity in vivo. The oligomeric fraction was also rested in a 90-day oral study in rat and the NAEL derived was 150 mg/kg b.w. per day. The CEF Panel concluded that there is no safety concern for the consumer if the substance is used as additive up to 25 % in PVC coatings for contact with all types of foodstuffs except for beer and beverages, under all conditions of time and temperature including sterilisation followed by long term storage. European Food Safety Authority, 2012 1 n request from the Ministry of Health, Welfare and Sport, The Netherlands, Question No EFSA-Q-2006-203. Adopted on 24 May 2012. 2 Panel members: Ulla Beckman Sundh, Mona-Lise Binderup, Leon Brimer, Laurence Castle, Karl-Heinz Engel, Roland Franz, Nathalie Gontard, Rainer Gürtler, Trine Husøy, Klaus-Dieter Jany, Catherine Leclercq, Jean-Claude Lhuguenot, Wim Mennes, Maria Rosaria Milana,Maria de Fátima Poças, Iona Pratt, Kettil Svensson, Fidel Toldrá, Detlef Wölfle. Two members of the Panel did not participate in the discussion on the subject referred to above because of potential conflicts of interest identified in accordance with the EFSA policy on declarations of interests. Correspondence: cef@efsa.europa.eu 3 Acknowledgement: The Panel wishes to thank the members of the Working Group on Food Contact Materials for the preparation of this opinion: Mona-Lise Binderup, Laurence Castle, Riccardo Crebelli, Roland Franz, Nathalie Gontard, Eugenia Lampi, Jean-Claude Lhuguenot, Maria Rosaria Milana, Karla Pfaff, Fatima Poças, Philippe Saillard, Kettil Svensson and Detlef Wölfle for the support provided to this EFSA scientific opinion. 4 Editorial changes have been made on pages 1. These changes do not affect the overall conclusions of this pinion. To avoid confusion the original version has been removed from the website. Suggested citation: EFSA Panel on food contact materials, enzymes, flavourings and processing aids (CEF); Scientific pinion on the safety evaluation of the substance, Methacrylic acid, 2,3-epoxypropyl ester, copolymer with acrylic and/ or, for use in food contact materials.. [13 pp.] doi:10.2903/j.efsa.2012.2744. Available online: www.efsa.europa.eu/efsajournal European Food Safety Authority, 2012
KEY WRDS Methacrylic acid, 2,3-epoxypropyl ester, copolymer with acrylic and/or methacrylic acid alkyl (C1- C4) esters; Ref. No 65841 and FCM Substance No 958; Food contact materials; Safety assessment; Evaluation. 2
SUMMARY The CEF Panel received a request from the Ministry for Health, Welfare and Sports, the Netherlands, for safety evaluation of a substance following a corresponding application from the company The Valspar Corporation, UK. The safety evaluation of the substance methacrylic acid, 2,3-epoxypropyl ester, copolymer with acrylic and/or, with the REF. No 65841, FCM Substance No 958, is requested for use as additive up to 25 % in organosol (PVC) coatings for contact with all types of foodstuffs except for beer and beverages under all conditions of time and temperature including sterilisation followed by long term storage. The methacrylic acid, 2,3-epoxypropyl ester contains an oxirane ring which reacts with (scavenges) any hydrogen chloride generated from the PVC during the thermal processing of the coating, forming corresponding chlorinated moieties. Migration and toxicity tests were submitted for a single polymeric additive (acronym EMA-GMA), methacrylic acid, 2,3-epoxypropyl ester (GMA) (20 %), copolymer with methacrylic acid, ethyl ester (synonym ethyl methacrylate, acronym EMA) (80%) which is considered representative of the copolymers of GMA with acrylic and methacrylic acids alkyl (C1-C4) esters. The migration of residual monomers (EMA, GMA and hydrolysis product of GMA) was not detectable in the intended conditions of use while the migration of low molecular weight oligomers (less than 1000 Da) containing the GMA unit was up to 0.016 mg/6 dm2. Chlorinated species were not detected in this fraction. Based on the available results of three in vitro and two in vivo genotoxicity tests, the Panel considered that that there is no concern with respect to genotoxicity in vivo of the oligomeric fraction below 1000 Da, o-ema-gma, and the corresponding chlorinated oligomers, o-ema-gma.hcl. A NAEL of 150 mg/kg b.w. per day was derived for o EMA-GMA, based on a 90-day oral rat study. The CEF Panel concluded that there is no safety concern for the consumer if the substance is used only as additive up to 25 % in PVC coatings, for contact with all types of foodstuffs except beer and beverages, under all conditions of time and temperature including sterilisation followed by long term storage. 3
TABLE F CNTENTS Abstract... 1 Summary... 3 Table of contents... 4 Background... 5 Terms of reference... 5 Assessment... 6 1. Introduction... 6 2. General information... 6 3. Data available in the dossier used for this evaluation... 6 4. Evaluation... 7 4.1. Non-toxicological data... 7 4.2. Toxicological data... 8 Conclusions... 9 Documentation provided to EFSA... 9 References... 10 Definition of the SCF lists... 11 Glossary and abbreviations... 13 4
BACKGRUND The company The Valspar Corporation, UK, has submitted a technical dossier to the Ministry for Health, Welfare and Sport, the Netherlands, with the request to evaluate the safety of the substance methacrylic acid, 2,3-epoxypropyl ester, copolymer with acrylic and/ or for use in can coatings. The dossier was compiled following the SCF guidelines for the presentation of an application for safety assessment of a substance to be used in food contact materials prior to its authorisation (EC, 2001). The substance methacrylic acid, 2,3-epoxypropyl ester, copolymer with acrylic and/or methacrylic acid alkyl (C1-C4) esters is intended to be used as stabiliser for organosol coatings for food cans. The coated cans are intended to be used with all types of food except for beer and beverages under all conditions of time and temperature including sterilisation followed by long term storage. For substances used in the manufacture of coatings there is no specific Community measure. Therefore no authorisation is foreseen at EU level for substances used in coatings. The Ministry for Health, Welfare and Sport, the Netherlands, transmitted this request for the safety evaluation of the substance to the EFSA. TERMS F REFERENCE The EFSA was requested by the Ministry for Health, Welfare and Sport, the Netherlands, to evaluate the safety of the substance methacrylic acid, 2,3-epoxypropyl ester, copolymer with acrylic and/ or methacrylic acid alkyl (C1-C4) esters with the REF. No 65841 and FCM Substance No 958, for use as stabiliser for organosol coatings for food cans. 5
ASSESSMENT 1. Introduction The European Food Safety Authority was asked by the Ministry of Health, Welfare and Sport, The Netherlands, to evaluate the safety of methacrylic acid, 2,3-epoxypropyl ester, copolymer with acrylic and/ or with a REF. No 65841 and FCM Substance No 958. The request has been registered in the EFSA s register of received questions under the number EFSA-Q-2006-203. The dossier was submitted on behalf of The Valspar Corporation, UK. 2. General information According to the petitioner, the substance is a polymeric additive made from methacrylic acid, 2,3- epoxypropyl ester (also called glycidyl methacrylate, acronym GMA) copolymerised with alkyl methacrylate and/or alkyl acrylate (alkyl = C1-C4). The substance is intended to be used as stabiliser at a level of 10-25 % (w/w) for PVC coatings for food cans. The GMA provides oxirane functionality on an inert polymer backbone. This oxirane functionality reacts with (scavenges) any hydrogen chloride generated from the PVC during the thermal processing of the coating, forming coresponding chlorinated species. Final articles are intended to be used in contact with all types of foodstuffs except with beer and beverages under all conditions of time and temperature including sterilisation followed by long term storage. The substance has not been previously evaluated by the SCF or EFSA. However, the monomers have been evaluated by the SCF and further authorised by the European Commission for use in the manufacture of plastics in contact with food. GMA (REF. No 20590, FCM Substance No 220) was classified in SCF list 4B (EC, 1999) and is included in Regulation (EU) No 10/20115 (EC, 2011) with a restriction of QMA = 0.02 mg/6 dm². In the remark from the SCF to the Commission about the classification of GMA in list 4B, reference is made to the use as an additive in PVC organosols. The monomers are included in the Regulation (EU) No 10/2011, with the same group migration restriction of 6 mg/kg food. 3. Data available in the dossier used for this evaluation The studies submitted for evaluation followed the SCF guidelines for the presentation of an application for safety assessment of a substance to be used in food contact materials prior to its authorisation (EC, 2001). Non-toxicity data: Data on identity Data on physical and chemical properties of the polymeric additive of methacrylic acid, 2,3- epoxypropyl ester, copolymer with methacrylic acid, ethyl ester (EMA-GMA) Data on intended uses and authorization of the polymeric additive Data on specific migration of residual monomers and hydrolysis products 5 EC (European Commission), (2011). Commission Regulation 10/2011 on plastic materials and articles intended to come into contact with food; http://eurlex.europa.eu/lexuriserv/lexuriserv.do?uri=j:l:2011:012:0001:0089:en:pdf 6
Data on the migration of the oligomeric fraction (o-ema-gma) with molecular weight below 1000 Da Data on overall migration Toxicity data: Bacterial gene mutation test of o-ema-gma and of the hydrochlorinated derivative, o-ema- GMA.HCl In vitro mammalian cell gene mutation test with o-ema-gma and o-ema-gma.hcl In vitro mammalian chromosomal aberrations test with o-ema-gma and o-ema-gma.hcl Unscheduled DNA synthesis test with mammalian liver cells in vivo with o-ema-gma and o- EMA-GMA.HCl In vivo Comet assay on o-ema-gma and o-ema-gma.hcl 90-day oral rat study on o-ema-gma 4. Evaluation Although the application stands for a broader range of copolymers, the data submitted for this evaluation refer to a single polymeric additive (acronym EMA-GMA): methacrylic acid, 2,3-epoxypropyl ester (GMA) (20 %), copolymer with methacrylic acid, ethyl ester (synonym ethyl methacrylate, acronym EMA) (80%). From the point of view of physical, chemical and toxicological properties, The Panel considered that the tested substance (EMA-GMA) is representative of copolymers of GMA with acrylic and methacrylic acids alkyl (C1-C4) esters. 4.1. Non-toxicological data Chemical formulae: [X] m [Y] n [Z] p [X] m methacrylic acid, 2,3-epoxypropyl ester, m = 0.05 0.45 mol [Y] n acrylic acid, alcohols aliphatic, monohydric, saturated (C1-C4) esters. [Z] p methacrylic acid, alcohols aliphatic, monohydric, saturated (C1-C4) esters Sum of n+p 0.55 0.95 mol (0.8 mol for a typical product). Chemical structure: R R m n p R = n-c 1-4 H 3-9 7
The weight average molecular mass and number average molecular mass of EMA-GMA are 33.000 Da and 8.400 Da respectively. The fraction with molecular weight below 1000 Da is 2.3 %. Free monomers are specified as less than 0.015 % for GMA and less than 0.1% for EMA. EMA-GMA is poorly soluble in 3% acetic acid, in 15% ethanol and in isooctane. It is well soluble in 95% ethanol and in olive oil. The calculated logpo/w is 3.5. During curing (at temperatures up to 210 C), the coating is crosslinked and the epoxide groups of the polymeric additive react with the HCl liberated from the PVC resin, giving chlorohydrate moieties (EMA- GMA.HCl) attached to the backbone of the polymeric additive. Migration tests were conducted on a coating formulation applied on a panel for 2 hours at 121 C followed by 10 days at 40 C. 10% and 50 % ethanol were used as food simulants. These test media are considered to give a representative migration figures for all types of foods. The time and temperature conditions applied simulate adequately the sterilisation of cans followed by long term storage at ambient temperature. Migration of low molecular weight oligomers, containing GMA or hydrolyzed GMA unit, into 10 % ethanol and into 50 % ethanol was up to 0.016 mg/6 dm² each. In this fraction chlorinated oligomeric moieties were not detected at a detection limit of 0.0005 mg/6 dm². The migration of residual monomers was not detectable at detection limits of less than 0.02 mg/6 dm² for EMA, 0.00005 mg/6 dm² for GMA and 0.0005 mg/6 dm² for the hydrolysis product of GMA (glycerol). At this level of migration of residual GMA, and assuming the same HCl scavenging rate as observed for oligomers, significant migration of GMA chlorohydrins is not to be expected. 4.2. Toxicological data The oligomers below 1000 Da, o-ema-gma, of the polymeric additive and the corresponding chlorinated oligomers, o-ema-gma.hcl, were tested in the three requested in vitro and in two in vivo genotoxicity tests. In the bacterial reversion mutation assays using the Salmonella typhimurium strains TA98, TA100, TA1535, TA1537 and the E. coli strain WP2 uvra both test substances o-ema-gma and o-ema-gma.hcl induced gene mutations with and without metabolic activation. In the forward mutation test using mouse lymphoma L5178Y cells without metabolic activation, the substance o-ema-gma induced a dose related increase of the mutant frequency above 33 µg/ml while no relevant reproducible increase was observed using o-ema-gma.hcl, under the same conditions. In contrast, using the latter substance o-ema-gma.hcl, with metabolic activation, a dose related increase of the mutant frequencies was observed while no increase was induced by o-ema-gma, at any dose level under these conditions. In summary, the data demonstrated a mutagenic potential of the two substances in mammalian cells. In a chromosomal aberration test with mammalian cells (CH cells) there was no indication for a clastogenic potential of o-ema-gma and o-ema-gma.hcl with or without metabolic activation. 8
In order to clarify the in vitro results, in vivo UDS assays were performed on the two substances. These assays, for which the used doses were the maximum ones (2000 mg/kg bw), did not indicate a mutagenic potential of o-ema-gma and o-ema-gma.hcl. In addition, the two test substances were also tested in an in vivo Comet assay in colon performed with doses of 2000 mg/kg bw. Based on the negative results in these tests it was concluded that the two substances did not induce primary DNA damage in colon cells of male rats. The Panel noted that the Comet assay was only performed on a single organ. However, on the basis of the available data, the Panel considered that there is no concern with respect to the genotoxicity of o-ema-gma and o-ema-gma.hcl EMA, in vivo. In a 90-day oral rat study, the isolated fraction (<1000 Da) of EMA-GMA oligomer (o-ema-gma) was administered to Wistar rats at 30, 150 and 750 mg/kg b.w./day. At necropsy, terminal body weights were statistically significantly decreased in high-dose males. The overall feed intake was slightly increased in males and females of the high-dose group. Water intake was increased in males and females of the high-dose group (week 6 and 11). Decreased hemoglobin and mean corpuscular haemoglobin concentrations were statistically significant in high-dose males only. Histopathological findings in the mid-dose and the highdose groups in the kidneys of male rats, indicated as nephrosis, were associated with the accumulation of the male-rat-specific alpha2µ-globulin in the proximal tubules and are not considered to pose any risk to humans. However, increased liver weights and changes in clinical chemistry (increased alkaline phosphate and gamma-glutamyl transferase activities, decreased alanine aminotransferase activity and increased cholesterol concentrations) at the high dose level indicate a hepatotoxic adverse effect of the test substance. Based on these findings, the NAEL for o-ema-gma is considered to be 150 mg/kg b.w./day. CNCLUSINS The CEF Panel considers that the substance methacrylic acid, 2,3-epoxypropyl ester, copolymer with acrylic and/or is not of safety concern for the consumer if the substance is used as an additive in PVC coatings up to 25 %. The restrictions for the monomers as set in the Regulation (EU) No 10/2011 should be respected. DCUMENTATIN PRVIDED T EFSA Dossier referenced: AR-11-1129/SIT. Dated: ctober 2011. Submitted on behalf of The Valspar (UK) Corporation, UK. Dossier referenced: AR-1583/SIT. Dated: December 2010. Submitted on behalf of The Valspar (UK) Corporation, UK. Dossier referenced: AR-10-0754/SIT. Dated: June 2010. Submitted on behalf of The Valspar Corporation, UK. Dossier referenced: AR-08-0093/SIT-schm. Dated: February 2008. Submitted on behalf of The Valspar Corporation, UK. 9
Dossier referenced: AR-06-0699/SIT-mem. Dated: November 2006. Submitted on behalf of The Valspar Corporation, UK. REFERENCES EC (European Commission), (2001). Guidelines of the Scientific Committee on Food for the presentation of an application for safety assessment of a substance to be used in food contact materials prior its authorisation; http://ec.europa.eu/food/fs/sc/scf/out82_en.pdf. EC (European Commission), 1999. pinion of the Scientific Committee on Food on an additional list of monomers and additives for food contact materials; expressed on 17/6/1999; http://ec.europa.eu/food/fs/sc/scf/out37_en.pdf. 10
DEFINITIN F THE SCF LISTS The classification into a SCF_List is a tool used for tackling authorisation dossiers and do not prejudice the management decisions that will be taken on the basis of the scientific opinions of the CEF Panel and in the framework of the applicable legislation List 0 List 1 List 2 List 3 Substances, e.g. foods, which may be used in the production of plastic materials and articles, e.g. food ingredients and certain substances known from the intermediate metabolism in man and for which an ADI need not be established for this purpose. Substances, e.g. food additives, for which an ADI (=Acceptable Daily Intake), a t-adi (=temporary ADI), a MTDI (=Maximum Tolerable Daily Intake), a PMTDI (=Provisional Maximum Tolerable Daily Intake), a PTWI (=Provisional Tolerable Weekly Intake) or the classification "acceptable" has been established by this Committee or by JECFA. Substances for which this Committee has established a TDI or a t-tdi. Substances for which an ADI or a TDI could not be established, but where the present use could be accepted. Some of these substances are self-limiting because of their organoleptic properties or are volatile and therefore unlikely to be present in the finished product. For other substances with very low migration, a TDI has not been set but the maximum level to be used in any packaging material or a specific limit of migration is stated. This is because the available toxicological data would give a TDI, which allows that a specific limit of migration or a composition limit could be fixed at levels very much higher than the maximum likely intakes arising from present uses of the additive. Depending on the available toxicological studies a restriction of migration into food of 0.05 mg/kg of food (3 mutagenicity studies only) or 5 mg/kg of food (3 mutagenicity studies plus 90-day oral toxicity study and data to demonstrate the absence of potential for bio-accumulation in man) may be allocated. List 4 4A 4B List 4 (for monomers) Substances for which an ADI or TDI could not be established, but which could be used if the substance migrating into foods or in food simulants is not detectable by an agreed sensitive method. Substances for which an ADI or TDI could not be established, but which could be used if the levels of monomer residues in materials and articles intended to come into contact with foodstuffs are reduced as much as possible. (for additives) 11
Substances for which an ADI or TDI could not be established, but which could be used if the substance migrating into foods or in food simulants is not detectable by an agreed sensitive method. List 5 List 6 Substances that should not be used. Substances for which there exist suspicions about their toxicity and for which data are lacking or are insufficient. The allocation of substances to this list is mainly based upon similarity of structure with that of chemical substances already evaluated or known to have functional groups that indicate carcinogenic or other severe toxic properties. 6A 6B List 7 List 8 List 9 Substances suspected to have carcinogenic properties. These substances should not be detectable in foods or in food simulants by an appropriate sensitive method for each substance. Substances suspected to have toxic properties (other than carcinogenic). Restrictions may be indicated. Substances for which some toxicological data exist, but for which an ADI or a TDI could not be established. The required additional information should be furnished. Substances for which no or only scanty and inadequate data were available. Substances and groups of substances which could not be evaluated due to lack of specifications (substances) or to lack of adequate description ( groups of substances ). Groups of substances should be replaced, where possible, by individual substances actually in use. Polymers for which the data on identity specified in "SCF Guidelines" are not available. List W "Waiting list". Substances not yet included in the Community lists, as they should be considered "new" substances, i.e. substances never approved at national level. These substances cannot be included in the Community lists, lacking the data requested by the Committee. 12
GLSSARY AND ABBREVIATINS verall migration: The sum of the amounts of volatile and non volatile substances, except water, released from a food contact material or article into food or food simulant Specific migration: The amount of a specific substance released from a food contact material or article into food or food stimulant ADI bw CAS CEF Da EC EFSA FCM LC-MS NAEL PET PVC REF No SCF w/w Acceptable daily intake Body weight Chemical Abstracts Service Scientific Panel on food contact materials, enzymes, flavourings and processing aids Dalton European Commission European Food Safety Authority Food Contact Material(s) Liquid chromatography with mass detection No-bserved Effect Level Poly(ethylene terephthalate) Polyvinyl chloride European Commission Reference Number Scientific Committee on Food Weight by weight 13