by Iris Kang

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Currently, regulation in the US regarding endocrine disrupting chemicals (EDCs) is based entirely on a risk-based approach. Both the Environmental Protection Agency (EPA) and Food and Drug Administration (FDA) in the US utilize this risk-based approach to consider certain aspects of a chemical (Kassotis, et al., 2020). In this approach, the hazards of a chemical and the anticipated exposure to that chemical is assessed. How does this broad approach apply to EDCs in food packaging specifically?

 

The Food, Drug, and Cosmetic Act of 1938 (FDCA) is a law that requires products to be manufactured “safe, pure, wholesome, and labeled without deception,” under FDA regulation (Kassotis, et al., 2020). With this law and the risk-based approach, however, there are many loopholes in US regulation. 

 

For example, chlorpyrifos is a neurotoxic drug that continues to escape regulation in the US. Chlorpyrifos is a drug that was withdrawn voluntarily by manufacturers in its use as an indoor pesticide (Kassotis, et al., 2020). This was due to the newfound evidence of chlorpyrifos having neurotoxic effects. However, the EPA reversed their decision to prohibit the use of chlorpyrifos in food products. This is because the EPA suggested that there was insufficient evidence on adverse health impacts (Kassotis, et al., 2020). Although this chemical is not used in food packaging but rather in pesticides, this neurotoxic chemical in food products can interact with chemicals in food packaging and cause further unknown effects.

 

Despite these failures, there are examples of times when the US policy makers stepped in to protect their people from EDC exposure in food packaging. The Title 21 Code of Federal Regulations in the FDA legal code calls for the regulation of polychlorinated biphenyls (PCBs) in food packaging and manufacturing sites (Title 21 Code of Federal Regulations). This legal code also called for testing on alternative substances that are being used instead of PCBs. The California Safer Food Packaging and Cookware Act also banned food packaging that contained per-and polyfluoroalkyl substances (PFAS) (Breast Cancer Prevention, 2021). This bill also shows how the government is taking action to address the specific issue of EDCs in food packaging.

 

However, this kind of approach to regulating EDC exposure through food packaging does not seem the most effective. There are so many different chemicals that are being used in food packaging, and banning them one at a time through separate bills only when their toxicity is verified with plenty of research may not be the most effective and timely. Thus, in order to address the issue of EDC exposure in food packaging, the actions taken need to go beyond these regulations that are currently in place. We hope to provide further solutions to this issue with partnerships and services that can help increase access to healthy foods without excess packaging.