EDF Health

New Updates to Understanding Packaging Scorecard Spur a Safer & More Sustainable Foodservice Industry

By EDF Blogs / Published: December 1, 2023

By Cassie Huang, MPH, Project Manager, Consumer Health

Mixed greens salad in a paper container

Note: This blog is cross-posted from the EDF + Business blog.

Products, Packaging & Waste

Amid growing concerns about the environmental impact of single-use plastics, consumers have increasingly sought out alternatives made with renewable materials—as demonstrated by the rise in popularity of the paper straw. Unfortunately, this summer many eco-conscious consumers were devastated to learn of a recent analysis of drinking straws that detected PFAS in paper straws.1

These toxic chemicals, often referred to as “forever chemicals” for their persistence in the human body and the environment, have been linked to serious health concerns and environmental contamination leading to additional exposures beyond the original PFAS-containing article.

The plant-based straw controversy serves as a poignant reminder that even seemingly sustainable and eco-friendly alternatives can harbor hidden health and environmental risks. It also underscores the urgency of tools like the Understanding Packaging (UP) Scorecard in helping foodservice companies navigate the complex landscape of sustainable food packaging to make choices that both protect human health as well as the environment.

Consumers are both wary of toxic chemicals in their food and more environmentally aware than ever. In a 2022 survey (PDF, 2.6MB) of U.S. consumers, it was found that “cancer-causing chemicals in food” are still the second most important food safety issue to Americans, right after foodborne illnesses. Further, 82% of consumers across age demographics are willing to pay more for sustainable packaging, according to a 2023 survey of 9,000 consumers spanning Europe, North America and South America. With the ever-growing demand for sustainable packaging, companies need tools to help advance their planet-forward goals.

The UP Scorecard is a science-based online tool designed to assist foodservice companies in choosing foodware and food packaging that not only meets demands for safety but also aligns with their sustainability goals. One of the world’s leading foodservice companies, Compass Group, uses the UP Scorecard to help prioritize sustainability goals and drive down plastics and PFAS in their product offerings, as demonstrated in their case study.

The latest version of this sustainability tool, released [November 28, 2023], takes a significant leap forward: by improving its scoring system for toxic chemicals, the UP Scorecard offers a more comprehensive view of the health impacts of different packaging materials and how to choose healthier options for customers and the environment.

A Deeper Dive into the Updates

1. Enhanced Scoring System: The updated scoring system considers various factors, including food temperature, fat content, acidity, and more, when assessing the potential human health impacts of a certain packaging material. For instance, certain toxic chemicals may migrate into food at higher temperatures or have a higher affinity for fats. The UP Scorecard accounts for this, providing a lower score for packaging containing such chemicals when used to hold hot or high-fat foods. This nuanced approach ensures that procurement professionals can make more precise decisions based on specific use cases and product requirements.

2. User-Friendly Portfolios: One of the most significant improvements in this version is the ability for users to save and score portfolios representing entire business units. Now, foodservice companies can easily assess the sustainability and safety of their entire product lineup, making the decision-making process faster and more efficient for their procurement teams. And it makes it easier to see big-picture progress and advance toward longer term goals.

3. User Accounts: The addition of user accounts allows professionals to manage their tool preferences, save customized products and portfolios for future reference, and even collaborate by sharing their projects with others. This feature promotes teamwork and knowledge sharing within organizations.

4. Benchmarking Capabilities: The updated UP Scorecard introduces a benchmarking system that enables users to compare different portfolios. This function is invaluable for companies looking to continuously improve their sustainability efforts.

By leveraging the UP Scorecard, foodservice companies can make well-informed decisions that not only benefit their bottom line and meet consumer demand and expectations for safe food packaging, but also contribute to a safer and more sustainable food industry.

About the UP Scorecard

The UP Scorecard measures commonly used foodware and food packaging materials with a single yardstick to offer the first-ever, free, and comprehensive tool for making sustainable purchasing decisions for these products based on the latest available science. Scores are provided for plastic pollution, chemicals of concern, climate, water use, sustainable sourcing, and recoverability. Developed through an unprecedented collaboration of leading food service companies, NGOs and technical experts, the UP Scorecard provides an authoritative resource for businesses as well as for environmental and human health advocates.

Environmental Defense Fund is a proud partner on this collaborative effort to help foodservice companies both achieve climate goals while also protecting consumer safety. With the latest enhancements, it’s easier than ever to select food packaging that aligns with the highest standards of safety and sustainability.

NOTES

1 The study detected PFAS in paper, plastic, bamboo, and glass straws.

Posted in BPA, Food, Food contact materials, Food packaging, Markets and Retail / Tagged , , , | Authors: / Leave a comment

ICYMI: Secret GRAS determinations may outnumber those FDA reviews

By Tom Neltner, Senior Director, Safer Chemicals Initiative and Maricel Maffini, PhD, Consultant / Published: November 22, 2023

Quote from FDA Commissioner Robert Califf, MD. "I want to throw in chemical safety as another really, really important area for the future—for humankind, really—and where science is evolving rapidly."

NOTE: This blog was originally published on our Deep Dives blog on April 13, 2023. It predates the recent reorganization efforts at FDA.

What Happened?

FDA estimates that, each year, food companies designate 82 new food chemicals as “GRAS” (Generally Recognized as Safe) for use in food. On average, FDA reviews only 64 of those new chemicals for safety. For the remaining 18 chemicals in FDA’s estimate, the companies making and marketing them for use in food or in the food-production process choose not to seek a voluntary review by FDA.

In comments to the agency, we said we think FDA’s estimate may be too low – and the number of new chemicals added to food that bypass FDA review may be as high as 130 new food chemicals a year (significantly higher than 18). This is based on searches of company marketing claims. In an 8-week period, we identified 10 chemicals claimed as GRAS without a submitted notice to FDA seeking voluntary review. (Please see our comments for a full explanation of our estimate.)

Why It Matters

FDA’s review of GRAS safety determinations is critical to ensure food chemicals are safe. When agency scientists receive GRAS notices, they closely review them and ask notifiers tough questions about the safety of the chemical alone—and the potential consequences when that chemical is combined with other chemicals on the market.

But FDA allows companies to withdraw their notices – which they do in about 17% of cases. Sometimes companies fix the problems and resubmit the notice. FDA does not require companies to do this, however. Too many simply continue to market the chemical for food uses as GRAS without seeking further FDA review.

This is in addition to the GRAS safety determinations companies choose never to file, which leads to chemicals entering our food system without any FDA notice or review at all.

Our Take

While the GRAS system is clearly broken (something we’ve blogged about at length and the Washington Post covered in-depth back in 2014), FDA does retain the ability and the duty to monitor the marketplace to ensure unsafe chemicals that food companies claim as GRAS are kept off the market.

Unfortunately, the agency appears to lack any system to ensure that monitoring takes place. The only examples of agency action to pull industry-certified GRAS products off the market have been caffeinated alcoholic beverages and partially hydrogenated oils (aka artificial trans fat). Both were prompted, in part, by state and media calls for action.

Examples of inaction, however, are numerous and include: tara flour, COZ corn oil, Apocynun ventron, gamma aminobutyric acid (GABA), aquaequorin/Prevagen, and many more.

One of the key breakdowns that contributes to FDA’s failure to monitor is the lack of coordination between the regulatory programs in the Center for Food Safety and Applied Nutrition (CFSAN) and the inspection/enforcement programs in the Office of Regulatory Affairs (ORA).

Next Steps

In January 2023, FDA Commissioner Califf announced a proposal to reorganize the food safety program in response to stakeholder calls for action after the infant formula debacle and to a recent review of the agency by the Reagan-Udall Foundation. This review noted that one key step is to appoint a new Deputy Commissioner for Human Food. This person would have greater responsibility to coordinate efforts between CFSAN and ORA. The Commissioner’s proposal has been strongly criticized since there would be no clear line of authority between the new Deputy Commissioner and ORA.

But Commissioner Califf has stated that chemical safety is a priority, telling a reporter that “I want to throw in chemical safety as another really, really important area for the future – for humankind, really – and where science is evolving rapidly.”1

Fixing GRAS is an important step to rebuild consumer confidence and reduce the ongoing risk to public health. Until the broken GRAS system is fixed, FDA will continue to be hamstrung in preventing health risks posed by chemicals of unknown safety. Until the system is fully fixed—which includes ensuring that no chemicals enter our food system without notice to, and review by, the agency—FDA needs to be coordinating with ORA and CFSAN to proactively monitor and enforce GRAS evaluations on chemicals entering the market to ensure they are actually safe.

Go Deeper

You can learn more from these resources:

 

NOTES

1 FoodFix, January 31, 2023, edition.

Posted in Broken GRAS, Chemical regulation, FDA, Food, Health policy, Industry influence, Public health, Regulation / Tagged , , , | Authors: , / Leave a comment

EPA’s TCE Ban: A Vital Step for Public Health

By Maria Doa, PhD, Senior Director, Chemicals Policy / Published: November 17, 2023

Right-to-Know sign for trichloroethylene, or TCE. Lists the health hazards of TCE.

What Happened?

The Environmental Protection Agency (EPA) has recently taken a significant step in safeguarding public health by proposing new regulations under our nation’s primary chemicals law, the Toxic Substances Control Act (TSCA) that would protect people from exposure to trichloroethylene (TCE), a highly toxic chemical that causes serious health risks. The proposed rule would ban the production, import, processing, and distribution in commerce for all uses of TCE.

Yet, despite the known dangers of TCE and the undeniable scientific evidence supporting the need for this action, the chemical industry is trying to undermine this critical regulation by incorrectly claiming the proposed rule is “inconsistent with the science.”

Why It Matters

TCE causes so many different harms at such low levels that, when finalized, this action will bring widespread benefits to countless individuals.

TCE can cause multiple types of cancer – kidney cancer, liver cancer, and non-Hodgkin’s lymphoma cancers. In addition, exposure to TCE can cause kidney, liver, and neurological damage, harm the immune system and reproduction, and result in heart defects in developing fetuses.

What is particularly concerning is that some of the harm TCE causes—such as to the immune system and fetal heart development—occurs at extremely low levels that often go unnoticed.

People can be exposed in many ways: from chemical plants producing and releasing TCE into the environment; facilities using it for degreasing parts; and the intrusion of TCE into people’s homes, schools, and workplaces from industrial contamination of soil and groundwater.

“The only inconsistency with the science lies in the chemical industry’s misleading claims.”—Maria Doa, PhD, EDF Senior Director for Chemicals Policy

Our Take

We applaud EPA for taking this long-overdue action.

The extensively peer reviewed science clearly demonstrates the high toxicity of TCE and that exposure to even small amounts of TCE can harm a person in multiple ways. The only inconsistency with the science lies in the chemical industry’s misleading claims.

Once again, the chemical industry is resorting to the same tired playbook—attempting to downplay the dangers of TCE—all in the interest of protecting their profits. There is no valid justification to continue subjecting people to the perils posed by this pernicious chemical.

It is imperative that EPA expeditiously finalize its ban of TCE.

Go Deeper

Read our previous blogs on TCE.

Download a PDF of this blog post.

Posted in Adverse health effects, Chemical exposure, Chemical regulation, Developmental toxicity, Health hazards, Industry influence, Neurotoxicity, Public health, Reproductive toxicity, Rules/Regulations, TSCA / Tagged , , | Authors: / Read 1 Response

Unleaded Food: FDA acts quickly on contaminated cinnamon applesauce

By Liora Fiksel, Project Manager, Healthy Communities and Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: November 17, 2023

What’s Happening?

The North Carolina Departments of Health & Human Services and Agriculture & Consumer Services identified WanaBana cinnamon applesauce pouches as a source for elevated blood lead levels in multiple children. They found extraordinarily high concentrations of lead (1,900- 5,100 ppb) in the products, leading to the identification of at least 34 cases of elevated blood lead levels across 22 states to date.

On October 28, 2023, FDA issued a safety alert advising that “parents and caregivers of toddlers and young children who may have consumed WanaBana apple cinnamon fruit puree pouches should contact their child’s healthcare provider about getting a blood test.” Three days later, the company issued a voluntary recall.

As the recall expanded, FDA transferred the investigation to its Coordinated Outbreak Response & Evaluation (CORE) Network to determine the source of lead contamination and whether additional products are linked to illnesses.

Brands under a voluntary recall. Photo credit: FDA

Brands under a voluntary recall. Photo credit: FDA

Why It Matters

Lead levels in the puree ranged from 1,900 to 5,100 parts per billion (ppb). A single serving with 2,000 ppb exposed children to a lead level 64 times greater than FDA’s maximum daily intake of 2.2 micrograms/day (µg/day) for a child and 11 times greater than the 12.5 (µg/day) for an adult.

We will continue to note that there is no safe level of exposure to lead—making it toxic at any age, with heightened concern for children aged six and below. In homes without lead pipes or lead paint, diet is the primary source of lead exposure for young children. Read More »

Posted in Chemical exposure, FDA, Food, Health hazards, Public health / Tagged , , , | Authors: , / Read 1 Response

FDA’s approach to systematic review of chemicals got off on the wrong foot

By Maricel Maffini, PhD, Consultant and Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: November 16, 2023

Scientist working on a digital tablet showing data on the chemical element Cadmium

What Happened?

Last month, FDA’s scientists published the toxicological reference value (TRV) for exposure to cadmium in the diet. This value is the amount of a chemical—in this case cadmium—a person can consume in their daily diet that would not be expected to cause adverse health effects and can be used for food safety decision-making. The TRV was based on a systematic review FDA scientists published last year. We will turn to the TRV itself in an upcoming blog but are focusing on the systematic review here.

In a May 2023 publication, experts in systematic reviews from the University of California San Francisco (UCSF) raised concerns about FDA’s “lack of compliance” from established procedures.

We discussed these concerns with FDA. They said:

  • “The systematic review and the TRV” publication “have both undergone external peer review by a third-party and experts in the field.” The agency expects to publish the reviews on its website, and
  • FDA “is working on developing a protocol for a systematic review of cardiovascular effects of cadmium exposure that will be published.”

Why It Matters

Systematic review is a method designed to collect and synthesize scientific evidence on specific questions to increase transparency and objectivity and provide conclusions that are more reliable and of higher confidence than traditional literature reviews. In particular, the National Academies of Sciences, Engineering, and Medicine have recommended the use of systematic reviews to establish values such as the TRV that may be used to inform regulatory decisions.

The National Toxicology Program (NTP) and others have developed specific methodologies to conduct systematic reviews. FDA’s authors said they followed NTP’s Office of Health Assessment and Translation (OHAT) handbook.

Unfortunately, FDA’s adherence to the methodology fell short on both transparency and objectivity grounds, undermining the credibility of its conclusions. Credibility is crucial because FDA’s authors stated that “this systematic review ultimately supports regulatory decisions and FDA initiatives, such as Closer to Zero, which identifies actions the agency will take to reduce exposures to contaminants like cadmium through foods.”

Read More »

Posted in FDA, Health science, Public health / Tagged , , , , , | Authors: , / Comments are closed

EPA’s New Chemical Regulations: Backtracking on PBTs

By Maria Doa, PhD, Senior Director, Chemicals Policy / Published: November 15, 2023

NOTE: This is the fifth in a series about EPA’s regulation of new chemicals. See:

What Happened?

The Environmental Protection Agency (EPA) recently proposed new regulations for its safety reviews of new chemicals under our nation’s primary chemicals law, the Toxic Substances Control Act (TSCA). One of the proposed provisions would govern which persistent, bioaccumulative,1 toxic chemicals (PBTs) should undergo a full safety review.

Why It Matters

This proposed approach would exclude certain PBTs from a full new chemical safety review. This is a concerning step backward in addressing the risks from these chemicals.

PBT chemicals do not break down readily from natural processes and raise special concern because of their ability to build up in both the environment and in people and other organisms. Even small releases of these long-lived and bioaccumulative toxic chemicals can pose long-term risks to human health and the environment. Notable PBTs—such as DDT, which affects reproduction, and methyl mercury, which is a powerful neurotoxin—impacted whole ecosystems across the United States, including the Great Lakes.

View of Lake Michigan

View of Lake Michigan Photo credit: Maria Doa

Read More »

Posted in Adverse health effects, Chemical exposure, Chemical regulation, Health hazards, Health policy, Neurotoxicity, PBTs, Regulation, Risk assessment, Rules/Regulations, TSCA / Tagged , , , , , | Authors: / Comments are closed