rrp cc.^ /iwr ^/v r> Q ig-7- I-ASV OFFICES Kei.ler l\d Heckman H Km-Llift JOSKPH JKHOM <; H HECKMAN CHARI }>> M MEEHAN H«r iri2 X STREET, N. W WASIIINCtTON, Tj.C. £0036 TELEPHONE wn u VM II UOHO li liSANl, JIl WAYS' 11 \ ' Ht.ACK David H 1 LL i ssoa It TTKRNAN roulkt MaTJUN w M A J-iC K i Hay c ih.rcovici TO: 2%-aroo CAJ3LE ADDRESS February 5, 1971 All Members of the SPI Food, Drug and Cosmetic Packaging Materials Committee. Gentlemen: Having just received a letter and the FDA suggested procedure for extraction testing on pigmented plastics mentioned at our January 13 meeting, I am writing to supply this information to you. At the same time, however, I thought I would take the opportunity to inform the Committee on an interim basis about two other subjects of interest so I hope you will not mind receiving something of an "omnibus" report. Firstly, we are enclosing herewith a copy of a February 2, 1971 letter from Al Holtz of the Food and Drug Administration, along with a copy of the extraction methodology men­ tioned therein. We would appreciate it if all of you with an interest in .the pigments situation would review the methodology and send us any comments you care to make at your earliest convenience. Since the comments are apt to be technical in nature, it would be helpful if you could send copies of anything you have to say to Bill Westveer, the Chairman of our Technical Information Committee and to George Ingle who is acting as Chairman pro tern of the Pigments Task Group. Depending on the nature of the comments received, we may well decide to meet with the Food and Drug Administration staff on this matter some­ time in March, probably on March 25, so that the ASI-PR 0001173 ’ifELMAN" February 5, Page Two 1971 entire situation can be discussed with Mr. Holtz and his associates. Thus, we do hope you can review the enclosed and give us your thoughts by no later than March 10, 1971. Regarding the minutes of the January 13 meeting, we had hoped to have them completed before now but we have been delayed while we were awaiting one of the liaison reports expected. We are now proceeding with the final typing so the minutes should be in your hands within the next two weeks, the additional time being required to accomplish reproduction and distribution by the SPI office. Finally, and as what I hope will be nothing more than an interim report, we did have a meeting with members of the Food and Drug Administration staff on the so-called "Ramsey proposal" on February 3, as scheduled. You will recall that this meeting was set up at the suggestion of Tom Brown of the Food and Drug Administration during our question and answer session on January 13. At that time, Mr. Brown indicated that he thought we could move the Ramsey proposal ahead if we could delegate two or three people to work with the staff promptly. Thereafter, we cleared the Frawley-Wulfsberg-Heckman delegation with the Inter-Industry Committee representing all of the major packaging association interests and notified the Food and Drug Administration that we were prepared to get together on February 3. At the session with FDA, those in attendance from the Administration were Les Ramsey, Lou Buckley, A1 Holtz, and Joe McLaughlin. To our great surprise--I might even more properly say shock--although we had lengthy discussions during which it was generally agreed that the Ramsey proposal remains, in Mr. Ramsey's opinion, "scientifically sound" we were told that Mr. Ramsey ASI-PR 0001174 February 5, Page Three 1971 did not believe it could be published as a final amendatory regulation to Section 121.2500, nor even as a proposal at this time because "it would not be administratively [or to use my word, politically] advisable under current general conditions." As we read it, what Mr. Ramsey is saying is that he does not believe the Food and Drug Administration should have the courage to proceed with a helpful rules revision despite its scientific soundness at a time when FDA is under such fire because of situations like those involving the GRAS list review. To put it mildly we were very disappointed with this advice. Furthermore, I am still unable to believe that this result is what Tom Brown had in mind when he suggested at our meeting that we work together to further our mutual interests. For this reason, and especially since Mr. Brown was not in attendance on February 3, I am now planning to be in touch with him on this very important subject once again, hopefully when he returns to Washington on Monday or Tuesday of next week. All I can add at the moment is that I hope this effort to move past Mr. Ramsey will be fruitful. In any case, this interim report should serve to bring all of you completely up to date for the' time being. If anyone receiving a copy of this letter has a question about any of the subjects discussed before we are in touch once more, please do not hesitate to call or write. Enclosure ASI-PR 0001175 DEPARTMENT OF HEALTH. EDUCATION. AND WELFARE PUBLIC HEALTH SERVICE FOOD AND DRUG ADMINISTRATION WASHINGTON. D.C. 2023* February 2, 1971 Mr. Jerome H. Heckman 1712 N Street, N.W. Washington, D.C. 20036 Dear Jerry: Attached is a copy of our suggested procedure for extraction testing on pigmented plastics which yon requested (1/15/71). This is the method which was mentioned at the recent SPI meeting and is essentially the one which Eastman evaluated for their petition. This version includes some modifications introduced to answer some of Eastman's questions and which they considered desirable. Our interest in submitting the above through you to several other interested parties is to derive the benefit of varied trials and/or view­ points towards providing a standard acceptable procedure. Our August 1966 Guidelines should also be consulted for any pertinent information relating to this special extraction subject. If any questions arise concerning this tentative method we will be glad to discuss them. Thank you for your help and cooperation. Sincerely yours Attachment A. Holtz, Chemist Food Additives Petition Evaluation Branch Division of Food Chemistry and Technology ASI-PR 0001176 :cttq-; color A. teet for roi/rr-'mc i:\TniAT" Extraction of rigid or semi-rigid food-contact containers, (i) Equips 2111 (1) (2) (5) CCC :.l bunkers with watch glass covers Tarc.d 250 ml beak or 2-1/2 inch square stainless steel screening sufficient for the replicates needed. (4) Paper clip or other clipping device to hold screen and cample sandwich together. (5) Suspending wire to hold sample sandwich in beaker. (6) longs (7) Hot air oven (8) Thermostatically controlled waterbath to - 1.0° F., variable from 80° F. to 135* F., capable of holding 800 ml beakers. (9) Hood and hot plate, facilities (10) Analytical balance of suitable sensitivity (0.1 mg) and capable of handling the 250 ml beaker. (11) Desiccator (ii) Reagents. (1) (2) (3) (4) Freshly deionized distilled water Freshly redistilled, reagent grade n-heptane b. pt. 208° F. 95 percent (by volume) ethyl alcohol, diluted with deionized distilled water to 8 percent and 50 percent by volume, Freshly distilled acetic acid diluted to 3 percent (by volume) with deionized distilled water. 0001177 asi~pr •Y* Page 2. L. Buckley, ¥,7-i20 (iii) Test mater,'.ala Select a sufficient number of rigid nr semirigid containers so ;u, to be able accurately to cut eight 2-1/2 inch square samples or other desirable samples from the formed products for the test material. (iv) Procedure (a) Total nrn-volatile extractives (1) (2)(a) (b) Determine the appropriate solvents and oxtractabili t.y conditions for the intended uses as described in section 121.2526(d) Tables 1 and 2. For the nqrmnl packaging of thermoplastics we consider 120-30® F a suit-limiting temperature. Using the tongs, carefully prepare two sandwiches consisting of screen, sample, screen, sample, screen, sample, screen, sample, screen. Clip each sandwich together by moans of the clipping device. Introduce 100 ml o.f the appropriate food simulating solvent in an LOO ml beaker* usinu each of the four food J ii..ul,;Li:. solvents u:.;..uJ ..Love (wat^r, 2% acetic acid, alcohol (8,1 or 60,1) and n-heptanc, cove:; with a watch glass, and place in the constant temperature hath and condition at the desired temperature. (c) After conditioning, carefully introduce the sample sandwich into the appropriate extracting liquid. (d) Extract using the appropriate solvents and timetemperature conditions. (3) If tie procedure under (2) is not readily applicable then use the following immersion method. E>tract the samples as necessary (by film or plaque immersion etc.) with proper aliquot sampling at optimum intervals until equilibrium (i.e. no change in extraction level) as gauged hy at least 3 periodic tests at the same tem­ perature covering at least 72 hours for aqueous and 6 hours for heptane. ASI-PR 0001178 Page 3. L. Buckley, IiP-320 (4) At the conclusion of the extraction period, carefully suspend the sandwiches by the wire to drain into the beaker. (5) After draining, pour the food simulating solvent solution into the fared beaker. Rinse the 800 ml beaker three times with the required solvent, using a total of not more than 50 ml. (6) Evaporate the liquid to a few milliliters on a low temperature hot plate, transfer to an oven at 2^f 1° F. and evaporate to dryness. Allow to cool in a ' desiccator to room temperature and weigh the residue to the nearest 0.1 mgrn. Calculate the total ex­ tractives in milligrams per square inch of container surface. . (7) Whan running the acidic and alcoholic extractions, the sampling and analyses on these need not be started until the point where the. water extraction reaches equilibrium. If those extractives are of the same type and equal or less than the voter value level then wo can consider these at equilibrium. If however, Luulr ranges are 10-137* greater, then the acidic and/or alcoholic extractions should be eontinuna ro emitii.hH.tim. (b) Amount of colorant extracted. ^ Dissolve Mil? '’cighad residue in deionised water or requires, concuntrati-ch -o£ reagent grade nitric acid, if necessary, neutralizing the acid with reagent grade sodium hydroxide solution after the residue is dissolved. Proceed as described for flexible surfaces. B. Extraction of flexible polymeric food-contact surfaces. (!) Equipment (1) Extraction test cells described in Methods of Analysis, AOAC, sec. 7,035, 7,037. (2) Oven rack for extraction test cells (3) Hot air oven (4) Graduated cylinder (5) Fritted glass filter / O/1 ASI-PR 0001179 Page 4. L. Buckley, RF-320 (6) PL-.Uir.um evaporating dish (7) Stearn bath (8) Desiccator (9) Analytical balance of appropriate sensitivity (0.1 mg) (ii) Reagents (1) Freshly del onized distilled water (2) Freshly redistilled, reagent grade n-heptane, b.pt. 208° F. 95 percent (by volume) ethyl alcohol, diluted wi.tln deionized distilled water to '8 percent and 50 percent by volume. Freshly distilled acetic acid diluted to 3 percent (by volume) with deionised distilled water, (3) (4) (iii) Test materials Select samples of flexible food-contact films and protect from exposure to liquids nr contact v;ith other materials and from wrinlfling or -b’-n ;ior., Cut in rectangle,; equal m ul exceeding thu dimensions of the extraction cell with 1 dimension at least equal to or greater than the S" width, of the cell, and Sufficient for 2 rectangles to each cell and for 2 cells por determination. (iv) Procedure (a) (1) (1) Total non-volatile extractives: Determine the appropriate solvents and extractability conditions for the intended use(s) as described in section 121.2526(d) Tables 1 and 2. For normal packaging of thermoplastics we consider 120-130° F a self-limiting temperature (2)a. (b) Follow the test procedures set forth in Official Methods of Analysis of the AOAC 7.037, 7.033, and 7.039, using the appropriate solvents and temperature conditions. If the procedure under (2)(a) is not readily applicable then use the following immersion method. ASI-PR 0001180 Page 5. L. Buckley, BF-320 Extract the samples as necessity (by film nr plaque immersion etc.) with proper aliquot sampling at optimum intervals until equilibrium (i.e. no change in extraction level) as gauged by at least 3 periodic tests at the same temperature covering at least 72 hours for aqueous and 6 hours for heptane. (3) When running the acidic and alcoholic extractions, the sampling and analyses on these need not be started until the point where the water extraction reaches equilibrium. If these, extractives are of the sane type end equal or less than the water value level then we can consider these at equilibrium. If however, their ranges are 10-157, greater, then the acidic and/or alcoholic extractions should be continued to equilibrium. (4) (a) Calculate the total extractives in milligrams per square inch of container surface. (b) In calculating migrations of milligraw.s per square inch, the. area of the- exposure used 'is only that of one side if the film used is less than 5 mils. (b) rti.iounc of colorant extracted. Dissolve the weighed residue in deionised water or required concentration of reagent grade nitric acid, if necessary, neutralining the acid with reagent grade sodium hydroxide solution after the residue is dissolved. ,-l'- If the colorant is a metallic compound carefully evaporate the solution to about three drops and examine for the metal by means of suitable quantitative techniques with a maximum detection limit of about 0.05 micrograms of the metal. Calculate amount extracted per square inch of contact surface. : If the colorant Is an organic substance, the residue solution j should be made up to a standard volume with deionised dis­ tilled water or other appropriate solvent and the concentration of colorant determined chromatcgraphic.ally or spectrophotomatrically by comparing the results from an uncolored film under test. The sensitivity of the technique use should be shown. ,, —X / Or ASI- PR 0001181 Pa-e b. L. Buckley, BF-320 The results of the total extractive determination are to be used as a check on the equilibrium conditions and v;here appropriate to determine the compliance of the base film with the existing regulations. Our suggested general analytical procedures are not necessarily binding. Any satisfactory validated method and sensitivity will be accepted. cc: BF-100, BF-112, BF-301, BF-117, BF-143, BF-350(Mr. Spilier). AHoltz:mas 9/23/70 D/Init: MTrochazka 9/23/70 ■rs..~e Tf.m. * *y~<■* y - ✓'***' ~t~~‘ *' .A ASI-PR 0001182 » « Additives Food Additives 123 .before using, at rate of 15 ml tide soln for washing.__ .iot <2.5% NH, by wt. A RATION OF SOLUTION e with little Mg(NO,), soln, lissolve in HC1 (1 +2.5), and In aliquot of soln det. P,0, as stermination prepd loin into 250 ml beaker; ftht excess and barely dissolve ■w drops HNOi, stirring vigorjSO, has been used as solvent, , NH4NOi or soln contg that oln add 70 ml molybdate soln, 100 mg P,0, present. Digest 1 it for complete pptn of P,0, by ulate soln to clear supernatant, ith cold H,0 or preferably with . Dissolve ppt on filter with nd hot HiO, and wash into > 100 ml. Neutralise with HCI, r or bromothymol blue as indiFrom buret add slowly (ca I . vigorously, 15 ml of the mag* g PiOi present. After 15 min. H and let stand until super* tally 2 hr); filter, wash ppt with il washings are practically Cl* heat, and ignite to constant •nace at 950-1000°; cool w,. as MgjPjO,. Report as 4 'alive Test—Official, Final Action ) to 1-2 g sample in 150 ml t acid with HNO», filter, take e and NHi molybdate soln, m at 40-50®. Yellow ppt indiihosphate. [10)—Official, Final Action 1.5 hr with mixt. of 300 ml HaO Iter, wash filter thoroly with hot d filtrate and washings, and dil. 3. Det. sulfate in 100 ml aliquot lia—Official, Final Action in distn flask add 300-400 ml >f NaOH soln (1+1), connect id distill into measured vol. ltd »cid in distillate with std alkali, Arsenic—Official, Final Action FOOD ADDITIVES Place 5 g sample directly in generator, 24.007(a); add 10 ml HtO, little at time to prevent foaming over, and then 15 ml As-free HCI, adding it dropwise until foaming ceases. Heat on steam hath until drop of mixt., when dild and treated •iih I soln, does not show blue. Then dil. to ca 10 ml with HtO and continue as in 24.010, begin­ ning "add 5 ml of the KI reagent. .. ” Prep, blank and stda for comparison, using As-free HCI of sane concn as that used in detn. Exposing Flexible Barrier Materials for Extraction 7.0JI 7.012 Vlnorine—Official, Final Action— See 24.029-24.035 ASTM-AOAC Method (11)—Official, First Action 7.034 7.033 7.011 Lead—Official, Final Action— See 24.041-24.031 principles Method provides std liquid extn method for flexible barrier materials, singly, coated, or com­ bined, including extns thru flexible barrier mate­ rials of surface coating ingredients by food-simu­ lating solvents. Specimens of flexible barrier mate­ rials are exposed to extg liquids in test cell and amount of nonvolatile extractives remaining after exposure is measured. APPARATUS (a) Test cell.—See Fig. 7:2. Consists of two SXllixr No. 310 stainless steel plates, de- ASI-PR 0001183 124 7. Baring Powders, Baking Chemicals, and Food Additives greased; one JX J1" U-shaped virgin TFE-fluorocarbon (Teflon) gasket, grooved on both sides os shown; twelve 1X1' stainless steel bolts with wing nuts; one J X1X 8* TFE-lluorocarbon gasket plug tapered to provide tight fit. (Available from Scientific Products, Inc., Div. of American Hos­ pital Supply, Evanston, 111., No. 6200.) To prep, app. for use, wash plates and gaskets in aq. de­ tergent soln. Rinse with HjO and dry at 1008. Wash with n-heptane and redistd acetone. Im­ merse new gaskets in n-heptane overnight. Rinse gaskets with fresh n-heptane and dry at 100s. (b) Own rack—Set Fig, 7:3. To hold oxtn tost cells. (c) Hoi air oven.—With safety provisions for flammable solvents. Vac. oven or autoclave is suitable. 7.030 REAGENTS Use solvents (usually HtO, dil. alcohol, and nheptane) specified in regulations (Cods of Federal Regulations, Title 21, Sec. 121.2514(d)(2); 121.2526(d)). Solvent for blanks and detn should be from same container. 7.037 ■ i preparation op cells Select samples of flexible barrier material and protect from exposure to liquids or contamination by migration from contact with other materials, and from wrinkling or abrasion. Samples shall equal or exceed dimensions of cell where possible. and shall in all coses have 1 dimension equal to or greater than width (8*) of coll. Place 1 stainless steel plate of cell on flat surface with bolts protruding up thru holes in plate. Place prepunched specimen (side to contact liquid up) on plate with 1 edge aligned with bottom of plate, 2 edges aligned with sides of plate, and bolts pass­ ing thru prepunched holes. Place gasket on speci­ men with outer edges of gasket aligned with cell bottom and sides. If desired, place second pre­ punched specimen (side to contact liquid down) on top of gasket. If only 1 sheet is used for test, place inert barrier sheet sueh as Teflon or electro* lytically cleaned tinfoil in place of second sheet. Place second stainless steel plate on top of assem­ bly. Place wing nuts on bolts and tighten. Preheat assembly (including TFE-fluorocarbon gasket plug) to test temp, and retighten nute so that assembly is liquid-tight. 7.038 determination Place measured vol., A, of extg liquid, pre­ heated to test temp., into assembly. Use vol. of liquid such that top of liquid is 0.5' below top of specimen. In no case should vol. of extg liquid be >200 ml. Insert gasket plug in top of cell. Expose eeJl in rock in oven to conditions of time and temp, specified by regulations. If roc. oven is used, operate it at atmospheric pressure. Align cells in rack in oven parallel with air flow. i \ tm mmsmmm ASI-pr 0001184 s. t OniTIVl!# ive 1 dimension equal to or |of cell. I I' i of cell on flat surface it j holes in plate. Place (side to contact liquid up) igned with bottom of plate, les of plate, and bolts passolcs. Place gasket on speciof gasket aligned with cell desired, place second pree to contact liquid down) ly 1 sheet is used for test, t such a» Teflon or eleetroI in place of second sheet, itecl plate on top of aesemi bolts and tighten, chiding TFE-fluorocarbon mp. and retighten nuts so tight. brmination , A, of extg liquid, prento assembly. Use vol. of liquid is 0.5' below top of ould vol. of extg liquid be plug in top of cell. Expose ) conditions of time and ulations. If vac, oven is noepberic pressure. Align alls! with air flow. Nmim After exposure, remove cell from rack, remove gasket plug, and immediately pour out extg liquid into graduate. (If solids flake from specimen and it is desired to det. only sol. materials, filter thru fritted glass filter from ceil into graduate.) If vol. of extg liquid is <90% of original vol., investigate cause. Det. total nonvolatile extractives by evapg total vol. extg liquid to apparent dryness in weighed Pt evapg dish on steam bath. Dry in oven 30 min. at 100°. Cool 30 min. in desiccator and weigh. Perform at least 2 blank detns with 200 ml extg liquid each and glassware that will bs used in detn. Preclean glassware with chromic acid soln followed by H,0 rinse. Place equal vol. extg liquid into each of blank-receiving containers. If filter is used on extg liquid from exposed samples, include contact of solvent of blank with filter. Wt blank must be <2.0 mg/200 ml and <30% of wt ex­ tractives. 7.039 calculation With 2 sheets in cell, ratio of exposure area to vol. extg liquid used to fill cell is 2 ml/sq. in. Calc, mg extractives/sq. in. exposed sample =» (mg ex­ tractives—mg blank) /sq. in. exposed sample. Acetone Peroxides {It)—Official, Final Action 7.040 In Baking Premize* Weigh accurately ca 8 g sample into flat-bot­ tom centrifuge bottle, pipet 100 ml H,0 onto sample, and stir 10 min. after making sure no lumps remain. Centrifuge at ca 1500 rpm ca 10 min. Pipet 25 ml supernatant into erienmeyer, add 25 ml H1SO4 (1 -4-4), and let stand at least 3 min., swirling occasionally. Titr. to light pink that lasts >20 see, with std 0. IN KMnO« soln, 42.023~42.024. Total peroxides in g H1O1 equiv./lOO g premix — ml KMnO4XnormalityX0.0170Xl00/0.25Xg sample. 7.041 In Milling Premize* Weigh accurately ca 200 mg sample into erien­ meyer, add ftO ml H1SO4 (1+9), let stand >3 min., stirring occasionally, and titr. with std 0.1 AT KMnCh, 42.023-42.024, to light pink that persists >20 sec. Total peroxides in g H,0, equiv./lOO g pre­ mix - ml KMnO,X normality X0.0170X 100/g sample. Qualitative Teet (Acetone peroxides are extremely expioeive. Do not ext. more org. peroxides from adsorbents than necessary for test.) 7.042 APPARATUS (a) Recording infrared epectropkotometer.—Suit­ able for work from 2 to 10 a. 13ft (b) Rock tall plate.—Or other support stable to acetone and acetone peroxides and transparent in 2-16 it region. 7.043 TEST Weigh sample contg ca 10 mg H1O1 equiv. of acetone peroxides into g-s. flask. Add ca 1 g anhyd. NaiSO, and 10 ml acetone for every g adsorbate. Shake 3 min., filter (Whatman No. 12 paper has been found satisfactory) or centrifuge (for baking premix), and carefully evap. clear soln to ca 1 ml under vac. at room temp. Under wgrm light and gentle current of dry warm air, add coned acetone ext. dropwise to rock salt plate. When film of viscous liquid is visible on plate, place it in infrared light path and, with­ out recording, check transmittance of peak at ca 12.1 it. If necessary, add enough addnl portions of ext. to give 20-25% transmittance. Set spectro­ photometer at acetone peak at ca 9.2 44. Let radia­ tion pass thru sample on plate until raised pen reaches max. transmittance (acetone has evapd). Then record spectrum of film on salt plate from 2 to lft ». Compare curve to one obtained from reference acetone peroxides treated in same manner. Nitrites {13)—Official, First Action (Applicable to dry cure mix or curing pickle) 7.044 APPARATUS Bend piece of glass tubing 250 mm long, 0 mm o.d,, to form right angle ca 60-70 mm from one end. Connect short end with rubber tube to outlet of pressure regulator on COi tank. 7.045 PREPARATION OP SAMPLE (a) Dry cur* mix.—Weigh 50.0 g sample and dissolve in 1 L HtO. Transfer 25 ml aliquot to 250 ml erienmeyer. (b) Pickle eoln.—Filter thru dry paper. Weigh 60.0 g filtrate into 260 ml erienmeyer. 7.046 DETRBMINATION To soln in flask, add 20 ml colorless 15% KI soln and ca 2 ml starch soln, 17.001 (g). Insert long end of gas inlet tube and adjust flow of COi to ca 5 bubbles/sec. Continue flow of COi thruout detn. After ca 5 min., add 20 ml HtSO, (1 +7) from buret, and mix thoroly. Titr. with stdxd 0.0725N NatStOt to first complete disappearance of atarchI color. 1 mi 0.0725W NnStO, = 0.0050 g NaNOt. SELECTED REFERENCES (/) J. Aseoo. Offio. An. Chemiete6,463(1923). (t) Ibid. 10, 30(1927). (3) Ibid. 31,278(1948); 32, 83, 269(1949); 33. 77(19601. ASI-PR 0001185