Environmental Decision Memo for Food Contact Notification No. 1751

Return to inventory listing: Inventory of Environmental Impact Decisions for Food Contact Substance Notifications or the Inventory of Effective Food Contact Substance Notifications.

FINDING OF NO SIGNIFICANT IMPACT

A food-contact notification (FCN) 1751, submitted by SABIC Innovative Plastics to provide for the safe use of carbonic dichloride, polymer with 2,3-dihydro-3,3-bis(4-hydroxyphenyl)-2-phenyl-1-H-isoindol-1-one and 4,4’-(1-methylethylidene)bis[phenol], bis[4-(1-methyl-1-phenylethyl)phenyl] ester (CAS Reg. No. 503834-43-3). The food contact substance (FCS) is intended for use as a component in the manufacture of articles intended to contact food.

The Office of Food Additive Safety has determined that allowing FCN 1751 to become effective will not significantly affect the quality of the human environment and, therefore, an environmental impact statement (EIS) will not be prepared. This finding is based on information submitted by the notifier in an environmental assessment (EA), dated March 9, 2017. The EA is incorporated by reference in this Finding of No Significant Impact (FONSI), and is briefly summarized below. The EA was prepared in accordance with 21 CFR 25.40.

The FCS may be used under FDA conditions of use A through H and J. Adjuvant substances permitted for use in polycarbonate resin complying with 21 CFR 177.1580 may be used in the polymer that is the subject of this notification, subject to any limitations in the authorizing regulation or notification. The FCS is not for use in contact with infant formula and human milk. Such uses were not included as part of the intended use of the substance in the FCN.

The FCS is needed to provide good strength and rigidity at elevated temperatures, and to provide practical toughness and flame resistance.

Impacts to the Environment as a Result of Use and Disposal
The FCS will be sold to manufacturers engaged in the production of food-contact articles; therefore, food-contact articles containing the FCS will be widely distributed across the country. Post-consumer disposal of the articles which contain the FCS will be to landfills or municipal solid waste (MSW) combustors complying with 40 CFR Parts 258 and 60, respectively. Recycling is not anticipated. No significant effect on the concentrations of and exposures to any substances in air, water or soil are anticipated, including those from bisphenol A (BPA). Due to EPA’s regulations governing landfills at 40 CFR Part 258, leaching into the environment of the FCS or its components as a result of land disposal of articles manufactured with the FCS is not anticipated. The FCS is comprised of carbon, oxygen, hydrogen and nitrogen so will not significantly alter the emissions from properly operating MSW combustion facilities. Further, incineration of the FCS will not cause municipal waste combustors to threaten a violation of applicable emissions laws and regulations at 40 CFR Parts 60, regulations for mandatory emissions reporting at 40 CFR 98, and/or relevant state and local laws. Based upon an analysis using market volume information provided in the confidential attachment to the EA there are no significant impacts with respect to greenhouse gas emissions resulting from incineration of materials containing the FCS. Thus, the use of the FCS as proposed is not reasonably expected to result in significant environmental impacts.

Use of Resources and Energy
The FCS will replace similar materials now on the market for use in the same food-contact applications. Use of the FCS will consume energy and resources in amounts comparable to the manufacture and use of these other polymers. As such, replacement by the FCS is not expected to have any significant impact on the use of energy and resources.

Mitigation Measures
No significant environmental impacts are expected to result from the use and disposal of food-contact materials fabricated from the FCS. Therefore, mitigation measures are not required.

Alternatives to the Proposed Action
No significant environmental impacts were identified in the EA that would necessitate alternative actions for the proposed use in this Food Contact Notification. If the proposed action is not approved, the result would be the continued use of the materials that the FCS would replace. Such action would have no significant environmental impacts.

As evaluated in the EA, the proposed use of the FCS as described in FCN 1751 is not expected to significantly affect the human environment; therefore, an environmental impact statement will not be prepared.

Prepared by __________________________________________Date: digitally signed 05-17-2017
Antonetta Thompson-Wood
Physical Scientist
Office of Food Additive Safety
Center for Food Safety and Applied Nutrition
Food and Drug Administration

Approved by __________________________________________Date: digitally signed 05-17-2017
Mariellen Pfeil
Biologist, Acting Environmental Team Lead
Office of Food Additive Safety
Center for Food Safety and Applied Nutrition
Food and Drug Administration