Dossier Biocides And Food Contact Materials

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DOI: 10.5281/zenodo.33520Dossier – Biocides andfood contact materialsJuly 2014Birgit GeuekeThe second reason for the application of biocides is the prevention offood spoilage which causes significant economic damage at all stagesof the food production chain. Spoilage is one reason why one third ofall food produced in Switzerland is wasted and not consumed [3].1 Definition of biocidesBiocides are chemical substances or microorganisms that are appliedto kill living organisms. Alternatively, biocides can be used to suppressharmful properties or control the growth of organisms. They aim toprotect different organisms (e.g. animals, humans, plants) or alsoproducts (e.g. food, wood, drinking water) from being negativelyaffected by the organisms in question. Biocides are classified by theirtarget organism as e.g. bacteriocides, fungicide, herbicides,insecticides, and rodenticides. In contrast, disinfectants act onlyagainst microorganisms and are exclusively used on surfaces. Theterm pesticide is often used with a similar meaning. It refers tochemicals or other agents that protect organisms (e.g. plants, animals,humans) from nuisance or diseases caused by other organisms (e.g.microorganisms, nematodes). In general language use, the termpesticide is often misleadingly treated as synonymous with morespecific terms such as insecticides or plant protection products.There are slight differences between the general and legal definitionsof these terms with latter requiring a precise use. Under Europeanlegislation, biocides are defined as “chemicals used to suppressorganisms that are harmful to human or animal health, or that causedamage to natural or manufactured materials” [1]. Plant protectionproducts are excluded under this definition, because they specificallyrefer to substances protecting plants from damaging influences. In theU.S., biocides are rather named antimicrobial substances, which areregulated either as food additives or pesticide chemicals.3 Classes and applications of biocides3.1 Examples and mechanisms of actionWidely applied biocides include alcohols, organic acids and theiresters, aldehydes, amines, quarternary ammonium compounds(QATs), halogen compounds, ionic silver and nanosilver, oxidizingagents, isothiazolones, phenols and biguanides (Table 1, Figure 1). Allthese groups of biocides are also used in FCM-related areas [4].Table 1. Classes of biocides2 Relevance of biocides in FCMsBiocides are commonly applied to reduce the number ofmicroorganisms on the food itself and on any material coming intocontact with the food. Other commonly used methods reducing the cellcount on food and food contact materials (FCMs) include heattreatment, acidification, and irradiation. In contrast, cooling decreasesand freezing stops the growth of microorganisms, but they are notkilled under these conditions.During food processing and storage, the eradication of microorganismsserves two main purposes: the prevention of food-borne illnesses andspoilage. Perishable food including meat, dairy products, ripe fruits,fish and seafood is especially susceptible to contamination withpathogenic and non-pathogenic microorganisms. Thus, special carehas to be taken when handling these food items.In the context of disease prevention, a reduction in the number ofmicroorganisms is desirable, as an infectious dose usually has to beexceeded for disease outbreaks. In the U.S., food-borne illnesses aremainly caused by the microorganisms norovirus, nontyphoidalSalmonella, Clostridium perfringens, Campylobacter ssp. andStaphylococcus aureus [2]. These pathogens mainly causegastrointestinal infections, which may be of differing severity. Duringthe last century the spectrum of food-borne illnesses has changed.Previously also severe infectious diseases such as typhoid fever,tuberculosis and cholera were commonly transferred via food andwater. However, better hygiene has strongly decreased the incidenceof these diseases in industrialized countries in the course of the 20thcentury.GroupExamplesaMain targetAlcohols Ethanol 2-Propanol 2-Phenoxyethanol Membrane uncoupler Protein denaturationAldehydes Glutaraldehyde Formaldehyde Glyoxal Cell wall Protein denaturationAmines Diethylamine Glucoprotamin Cell wall CytoplasmicmembraneBiguanides Polyhexamethylenbiguanid (PHMB) CytoplasmicmembraneHalogencompounds(oxidizing) Sodium hypochlorite Chlorine dioxide Calcium hypochlorite Nucleic acidsIsothiazolinones Chlormethylisothiazolinone / Methylisothiazolinone(CMIT/MIT) Inhibition of keyenzymesOrganicacids andesters Parabens Propionic acid Formic acid Benzoic acid Salicylic acid Cytoplasmicmembrane Transport inhibitionOxidizingagents Hydrogen peroxide Sodium persulfate Nucleic acidsPhenolics Triclosan Cytoplasmicmembrane Inhibition of keyenzymesQuarternaryammoniumcompounds(QATs) Benzalkonium chloride(ADBAC) Didecyldimethylammoniumchlorid (DDAC) Cell wall Cytoplasmicmembrane Silver and silver zeolite Enzymes NanosilveraAll examples are under review for authorization as biocides in the foodand feed area (PT4) of the European Biocidal Product Regulation.Silvercompounds1

ClSOHOSNO1O2ClOHNOO34OHCl5-O ClNCl76Figure 1. Chemical structures of biocides: 2-propanol 1, glutaraldehyde 2, MIT 3, CMIT4, benzoic acid 5, triclosan 6, and DDAC 7.Often biocidal products contain mixtures of chemicals with differentmechanisms of action. Some biocides are membrane-active agentsand thus destroy the envelope of the cells (Table 1) [5-7]. Others reactwith functional groups of proteins and/or nucleic acids and as a resultinhibit metabolism and cell growth. 3.2 Process biocidesIn the context of FCMs process biocides are used to prevent microbialcontamination during the production of the materials, but also todisinfect or sanitize an FCM surface before it comes into contact withfood. A few examples of the application of process biocides are listedhere: Slimicides are commonly used to in paper production to preventthe formation of biofilms [8]. Mainly oxidizing agents, e.g. chlorinedioxide and sodium hypobromite, have been reported to be usedas slimicides [8, 9]. Echeverry and colleagues validated intervention strategies toprevent microbial contamination of beef. The authors illustrativelydescribed the procedure of equipment cleaning using differentQAT solutions [10]. Lee et al. compared the performance of three process biocides inthe disinfection of low density polyethylene (LDPE) films, metalcans and an aseptic packaging machine [11]. They showed theefficacy of all three biocidal products when applied in the cleaningof the commercial packaging machine. 3.3 Surface biocides and biocides in activepackaging According to article 3 of Commission Regulation (EC) No 450/2009active food packaging is used with the intention “to extend the shelf-lifeor to maintain or improve the condition of the packaged food” and it is“designed to deliberately incorporate components that would releaseor absorb substances into or from the packaged food or theenvironment surrounding the food” [12].Biocides are incorporated in such active materials with the intention tobe released into the food or to act on the surface of the food product.In the scientific literature of the past years many highly specific biocidalapplications were described. In the following we list some examples ofactive packaging containing biocides. Martínez-Abad and colleagues published a study on silvercontaining and beeswax coated polylactide films. The thickness ofthe coating controlled the release rate of silver into the food orfood simulant. Bacterial growth was found to be inhibited by thiskind of active packaging [13]. In 2011, the protease subtilisin was immobilized onpolycaprolactone and its effect on microbial growth was investigated. The microbial contamination of meat samples storedin this active packaging was reduced, while the cell count ofcontrol samples increased over the same time [14].In 2013, Liu et al. incorporated bionanocomposites, composed ofthe two natural polymers chitosan and cellulose, and the biocidebenzalkonium chloride in alginate films, [15]. The inclusion of thebionanocomposites into the alginate polymer improved themechanical and biocidal properties of the material.The controlled release of the strongly oxidizing, gaseous agentClO2 from active packaging materials was described in twoillustrative studies. Ray and colleagues incorporated sodiumchlorite and citric acid into polylactide acid films. Moistureoriginating from the packaged product (e.g. any fresh produce)was able to catalyze the formation of ClO2 which then acted asbiocide on the surface of the product [16]. Li and colleaguesdescribed a coating in which ClO2 was polymer-encapsulated in awater-oil-water double emulsion [17]. Within 28 days 30% of thebiocidal gas was released from the coating and killed differentbacterial species.Lahmer and colleagues investigated the antimicrobial activity ofarginine-chitosan derivatives, water-soluble, modified polymersbased on a natural glucosamine. They suggested the inclusion ofthe derivatives in packaging materials or their use as coating toprevent microbial growth in meat juice [18].Jin et al. provided a delivery system for the antibacterial peptidenisin that was based on polylactide. The authors could proveantibacterial activity especially against gram-positive bacteriawhen nisin was released from the polylactide films [19].Amphiphilic QATs were incorporated into hydrophilicpolyurethane resins. The biocides concentrated at the polymer-airinterface. Hereupon, the material exhibited antibacterial function.Moreover, no migration of QATs from this active material wasmeasured by high-pressure liquid chromatography and bioassays[20].Muranyi and colleagues coated glass with titanium dioxide andshowed antimicrobial properties after irradiation [21].4 Regulation of biocides4.1 United StatesIn the U.S., antimicrobial substances used in or on any FCM whichmay result in residues in or on food are either categorized as foodadditives or as pesticide chemicals [22]. The two terms are definedunder § 321(q) and (s) of the Federal Food, Drug, and Cosmetic Act(FFDCA; 21 U.S.C., Chapter 9) [23]. Depending on their application,these substances are regulated by two different authorities (Table 2).2

Table 2. U.S. Legislation for biocidesRegulated asfood additivepesticide chemicalby FDA under § 348, FFDCAby EPA under § 346a,[23]FFDCA [23]Antimicrobials used in or on foodFood contact substancespackaging, e.g.:with an antimicrobial effecton permanent or semi Surface sanitizing antimicrobialpermanent food-contactsolutions.surfaces (except food Antimicrobials impregnated into thepackaging), e.g.:packaging (to protect either the Surface sanitizingpackaging or the food).antimicrobial solutions.Antimicrobial food contact Antimicrobials impregnatedsubstances (except food packaging)into the food contactwith no intended ongoing effect onsurfaces such as counterany portion of the object. Thesetops, table tops, foodchemicals are non-functionalprocessing equipment,components of the final product, e.g.:cutlery, dishware or Antimicrobial substances used in thecookware.production of water-basedassessed separately from the bulk material. Biocidal products containapproved active substances and require authorization during a secondphase of the regulatory process. The biocidal products are groupedinto 22 product types (PT), which are divided into four main groups(disinfectants PT 1-5, preservatives PT 6-13, pest control PT 14-20and other biocidal products PT 21-22).Treated articles have come in contact with or contain biocidal productsor active substances and require labeling under certain conditions (e.g.when a claim of biocidal properties is made on the product or when thelabeling of a specific active substance is legally required).Types of biocidesIn the context of FCMs, biocides are used for different purposes. Theycan be grouped into process biocides, surface biocides and foodpreservatives [29]. Depending on the application of the biocide,different regulatory actions are required. Process biocides are applied during manufacture of FCMs toprevent microbial contamination during production, storage orhandling. These compounds are not intended to be carried overinto the final product, but residues could still be present in theFCM. The manufacturer of FCMs has to adhere to article 3 ofRegulation (EC) 1935/2004 guaranteeing that FCMs “do nottransfer their constituents to food in quantities which couldendanger human health” [30]. The setting of default limits forprocess biocides is currently being discussed (e.g. 10 ppb in thefinal product [29]). During the production of plastics, thesechemicals are regarded as polymer production aids, which do notrequire authorization under Regulation (EU) No 10/2011. Underthe BPR, process biocides need to be authorized for the use indifferent product types (PT 6: preservatives for products duringstorage; PT 7: film preservatives; PT 12: slimicides), but they willnot be approved under PT 4 (food and feed are). Surface biocides added with the intent to exert an antimicrobialeffect on the surface of plastic FCMs are authorized as additivesand listed in Annex I of Commission Regulation (EU) No 10/2011[31]. No such harmonized, positive lists exist for non-plasticFCMs. Non-plastic FCMs with intentionally added biocidesnevertheless require additional approval as treated article underPT4 (food as feed area) of BPR. Food preservatives are biocides intended to be released from thepackaging into the food or onto the food’s surface. They areexplicitly excluded from authorization under the BPR, but coveredby Commission Regulation (EC) No 450/2009 on active andintelligent materials and articles [32]. Food preservatives need tobe authorized under Regulations (EC) No 1333/2008 and (EC) No1334/2008 [33].adhesives or coatings. Slimicides applied during paperproduction.Material preservatives used tomanufacture food contact articles(except food packaging). Theseantimicrobials are intended topreserve the final material or article,but do not have contact with the fooditself, e.g.: Polymeric resins for themanufacturing of food contactarticles. Coatings on conveyor belts.Antimicrobials used in or on food packaging, material preservativesand non-functional antimicrobial components in food contact articlesare regulated as food additives by the U.S. Food and DrugAdministration (FDA) under FFDCA, § 348. Food contact substanceswith an antimicrobial effect in or on permanent or semi-permanentfood-contact surfaces are regulated by the U.S. EnvironmentalProtection Agency (EPA) under FFDCA, § 346a. A comprehensive listof food additives extracted from different parts of 21 CFR can beaccessed on the FDA’s homepage [24]. The regulatory and datarequirements for pesticides including antimicrobials are regulatedunder 40 CFR Part 158 [25]. Maximum residue levels and exemptionsof pesticide chemicals in food are listed under 40 CFR Part 180 [26].More background information on the U.S. regulation of antimicrobialsin food packaging can also be retrieved from a recent article by Misko[27].Open questions regarding the responsible authoritiesThe different types of biocides in FCMs are regulated under differentlegal frameworks. Depending on the type of biocide, the riskassessment has to be carried out by ECHA or EFSA or by bothagencies. No clear process has been defined so far on how to performa combined risk assessment covering the provisions of Regulation(EC) No 1935/2004 [30] and BPR [1], but the European Commissionpublished a discussion document in 2013 [29] and an amendment ofthe BPR was recently drafted [34]. The development of such a processwill require further legal modifications of both above mentionedregulations.4.2 European UnionBiocidal product regulation (BPR)On September 1, 2013, the Biocidal Product Regulation (BPR,Regulation (EU) No 528/2012) came into effect in the EU [1]. It repealsthe earlier Biocidal Products Directive (BPD, Directive 98/8/EC) [28].The BPR aims at establishing a Union list of approved biocides (activesubstances) (Annex I of BPR). Companies have to submit a dossiersubsequently evaluated by the European Chemicals Agency (ECHA).Based on an opinion prepared by ECHA, active substances may theneither be approved, excluded or suggested for substitution by theEuropean Commission. The approval of an active substance does notcover its nanoform. Active substances in nanoform need to beApproved biocidesA total of 64 active substances are approved in accordance with theBPD and BPR [1, 28]. They do not contain any chemicals authorizedfor food and feed (PT 4), but only biocides applied in other producttypes. Currently, 57 active substances are still under review and may3

be authorized for PT 4 [4]. They include organic acids, alcohols,halogenated compounds, aldehydes, amines, substituted phenolicsubstances, QATs, silver, and strong oxidizing substances such assilver dioxide, sodium hypochlorite and hydrogen peroxide.6 Migration, exposure andcontaminationIn the case of active substances, the migration of biocides into the foodmay be intended for protecting food from contamination withmicroorganisms. In 2013, packaging that intentionally hinders microbialgrowth was reviewed by Larson and Klibanov. The authorsdifferentiated between biocide releasing packaging and surfaceimmobilized biocides. Highly specific active packaging solutions usinge.g. ClO2, antimicrobials and antifungals were illustrated in the paper.Migration of biocides may also occur non-intentionally resulting in thecontamination of food. One example is the transfer of processbiocides, e.g. isothiazolinones that are used in adhesives [43] or asslimicides in paper production [44]. In 2006, Coelhan and colleaguesinvestigated 61 different beer cans from different countries andmeasured the biocide ortho-phenylphenol (OPP) in 40 of the samples[45]. The concentrations varied between 1.2 and 40 g/L and it wasassumed that OPP originated from the sealing of the cans. Furtherexamples are conceivable, but our literature search did not reveal anysystematic scientific study on the migration of biocides from foodpackaging.As a consequence, exposure assessment is difficult. A comprehensivestudy about the exposure to biocides originating from products usedfor cleaning, washing, personal care, home improvement and pestcontrol was published in 2010 [46]. Dermal exposure, inhalation andaccidental oral exposure were considered as main exposure routes.The authors concluded that “exposure to biocides from householdproducts may contribute to induction of sensitization in the population”.The study did not include any exposure to biocides originating fromfood. A comparable study focusing on this topic could fill currentknowledge gaps.Biocides in PT4Several biocides that may be used in plastic FCMs in Europe are listedon a Provisional List [35]. They were assessed by EFSA, but onlyauthorized in individual Member States, not at the Community level.These substances include triclosan and ten silver-based chemicals.Silver zeolite A and silver sodium hydrogen zirconium phosphate arecurrently also under the biocides review program for approval in PT 4.Applications for the other biocides of the Provisional List will have to besubmitted by 1 September 2016; otherwise they cannot be placed onthe market anymore.5 Market dataSeveral comprehensive market studies on biocides were recentlyissued, but they are not publicly available [36-41]. The informationsummarized in this dossier was obtained from press releases andpublished digests of these market studies that refer to only limiteddata. Thus, it just gives a first impression of the figures, but for moredetailed data, the original reports have to be purchased. In 2013, Biocide Information Limited estimated the global biocideconsumption at nearly US 5.4 billion for active substances andUS 12.4 billion at the formula

Some biocides are membrane-active agents and thus destroy the envelope of the cells (Table 1) [5-7]. Others react with functional groups of proteins and/or nucleic acids and as a result inhibit metabolism and cell growth. benzalkonium chloride . 3.2 Process biocides . In the context of FCMs process biocides are used to prevent microbial

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