ARCHIVED - Health Canada Requests Information from Industry on the Use of Aluminum-Containing Food Additives

The following letter was distributed to key industry stakeholders on July 03, 2008, with responses expected by August 22, 2008:

Re: Request for information on aluminum-containing food additives

In 2006, the Joint FAO/WHO Expert Committee on Food Additives (JECFA) reduced the Provisional Tolerable Weekly Intake (PTWI) of aluminum from all sources, including food additives, from the previous value of 7 mg/kg body weight per week to 1 mg/kg body weight per week. This has resulted in increased scrutiny at an international level of aluminum-containing food additives. Health Canada’s Bureau of Chemical Safety, in the Food Directorate, has committed to a review of aluminum-containing food additives in order to:

• Ensure that dietary exposure to aluminum among Canadians is not unacceptably high;
• Identify an appropriate numerical Maximum Level of Use for those aluminum-containing food additives that are currently permitted to be used in Canada at levels consistent with Good Manufacturing Practice;
• Verify whether the current numerical Maximum Levels of Use are still appropriate.

Aluminum is also being reviewed in relation to the Priority Substances Lists of the Canadian Environmental Protection Act, 1999 (CEPA 1999), which identify substances that may be harmful to the environment or constitute a danger to human health. In 1995, aluminum salts, and in particular aluminum sulphate, chloride and nitrate, were added to the Second Priority Substance List (PSL2). A State of the Science report on these aluminum salts was published in 2000, at which time the file was suspended for six years to allow for additional research. Environment Canada and Health Canada are currently preparing the PSL2 draft assessment on aluminum salts for publication by November 29, 2008.

Although aluminum sulphate, chloride and nitrate are of particular concern in the PSL2 draft assessment, the review includes information on the use of all aluminum salts to which the general Canadian population may be exposed via air, drinking water, soil or food.

Aluminum in food may be natural, or the result of aluminum-containing additives. In an effort to better quantify Canadian exposure to the different aluminum salts used as additives in food items produced or sold in Canada and to help inform the updates to the regulatory provisions for aluminum-containing food additives, we are requesting your assistance in providing us with responses to the following questions:

1. Of the three aluminum salts of particular concern in the PSL2 draft assessment, only aluminum sulphate (including its potassium and sodium salts) is permitted to be used in Canada as a food additive. If you have such information, could you please provide us with the following:
   
   
   • a list of the food items which contain added aluminum sulphate, potassium aluminum sulphate, and/or sodium aluminum sulphate;
   • the amount (or range) of these aluminum salts that are normally used (on a weight per weight basis) to achieve the intended technical effect in each food item
   • the approximate total quantity of each of these aluminum salts used in Canadian food products; and/or
   • considering the total use of aluminum-containing food additives, the proportion of the total that would be attributed to aluminum sulphate and its potassium and sodium salts.
2. Of the remaining aluminum-containing food additives permitted for use in Canada (see Table 1), could you please provide any information that you may have on the current use levels of any of these additives in your specific foods and a technological justification for the use level required?
   
3. For those aluminum-containing food additive uses with which you are familiar, are you aware of other alternative food additives that achieve the same technical effect? Please provide details.

We have attached for your reference a table listing those aluminum-containing food additives that are currently enabled for use in retail foods in Canada.

We would welcome any responses by August 22, 2008 via mail or electronically to bcs-bipc@hc-sc.gc.ca. If you send information electronically, please use the word aluminum in the subject box of the email. If you have any questions regarding this initiative, please feel free to contact the Bureau of Chemical Safety.

Table 1
Aluminum-containing food additives that may be used in Canada under certain conditions
Excerpted from Division 16 of the Canadian Food and Drug Regulations^***

* GMP = Good Manufacturing Practice
** in accordance with other sections (standards of identity/composition) contained in the Food and Drug Regulations.
*** the provision for sea urchin roe is through an Interim Marketing Authorization (IMA) pending regulatory amendment.