Agreed that FSANZ’s analysis of control measures and market The Victorian Departments of Noted. information accurately represents how CMPF is being Health and Human Services controlled in Australia and New Zealand. and Economic Development, Jobs, Transport and Resources. Nestle Scion The Society of the Plastics Industry Sealed Air Risk management options (general comments) Raised by FSANZ response We suggest FSANZ adopt Option 1: Status quo in combination Dupont FSANZ publishes the results of all its surveillance activities on its with Option 3a: Education/ awareness/ information programs website and communicates outputs (and their significance) at a range and Option 3b: Industry self-regulation by industry standards of fora. or code of practice. In more detail, this see management of chemicals used in food packaging primarily addressed by maintaining the status quo and still referring to US and EU positive lists. By also implementing Options 3a and 3b, FSANZ can improve the awareness of all stakeholders (in particular SME’s which were identified as the stakeholders with potential gaps in the regulatory knowledge and awareness of regulations from CMPF), and deliver the key information to downstream users through Declaration of Compliance (DoC). Finally we suggest FSANZ conducts risk-based assessments on high risk substances which are identified through routine surveillance or high topic tracking. Training/awareness and risk-based decisions should be included with management of CMPF. Consumers should also be made aware of regulatory and risk mitigation measures enforced by FSANZ, along with general outcomes of surveillance and monitoring outcomes, to support compliance efforts completed by industry. Option 1: Status quo Not supported. AFGC Noted. The data collected by FSANZ has demonstrated that chemical migration from packaging into food is low, albeit with further has completed further work characterising potential health risks work required to characterise any potential public health risks posed by the phthalates DEHP and DINP (see SD3 of this report). posed by the phthalates DEHP and DINP. The AFGC agrees that Therefore, following application of the graduated risk management the initial consultations have highlighted gaps in knowledge of chemical migration from packaging into food and approach, FSANZ has not identified any chemicals that meet the understanding of how to address it. As such, the AFGC criteria for a high risk chemical nor any evidence that the Code needs strongly supports option 3a of providing education, awareness to be strengthened. To improve awareness and knowledge about
Agreed that FSANZ’s analysis of control measures and market information accurately represents how CMPF is being controlled in Australia and New Zealand. The Victorian Departments of Health and Human Services and Economic Development, Jobs, Transport and Resources. Nestle Scion The Society of the Plastics Industry Sealed Air Noted. Risk management options (general comments) Raised by FSANZ response We suggest FSANZ adopt Option 1: Status quo in combination with Option 3a: Education/ awareness/ information programs and Option 3b: Industry self-regulation by industry standards or code of practice. In more detail, this see management of chemicals used in food packaging primarily addressed by maintaining the status quo and still referring to US and EU positive lists. By also implementing Options 3a and 3b, FSANZ can improve the awareness of all stakeholders (in particular SME’s which were identified as the stakeholders with potential gaps in the regulatory knowledge and awareness of regulations from CMPF), and deliver the key information to downstream users through Declaration of Compliance (DoC). Finally we suggest FSANZ conducts risk-based assessments on high risk substances which are identified through routine surveillance or high topic tracking. Training/awareness and risk-based decisions should be included with management of CMPF. Consumers should also be made aware of regulatory and risk mitigation measures enforced by FSANZ, along with general outcomes of surveillance and monitoring outcomes, to support compliance efforts completed by industry. Dupont FSANZ publishes the results of all its surveillance activities on its website and communicates outputs (and their significance) at a range of fora. Option 1: Status quo Not supported. The data collected by FSANZ has demonstrated that chemical migration from packaging into food is low, albeit with further work required to characterise any potential public health risks posed by the phthalates DEHP and DINP. The AFGC agrees that the initial consultations have highlighted gaps in knowledge of chemical migration from packaging into food and understanding of how to address it. As such, the AFGC strongly supports option 3a of providing education, awareness AFGC Noted. has completed further work characterising potential health risks posed by the phthalates DEHP and DINP (see SD3 of this report). Therefore, following application of the graduated risk management approach, FSANZ has not identified any chemicals that meet the criteria for a high risk chemical nor any evidence that the Code needs to be strengthened. To improve awareness and knowledge about
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