Migration of bisphenol A from can coatings into food - Detailed points raised in the consultation

Monday 17 September 2001

Some factual points or questions on related issues were also provided (comments from the Food Standards Agency are in bold).

• G&G Food Supplies Ltd.: Is the migration of bisphenol A affected by damage, long-term storage or temperature, & what is the effect on household pets of eating canned food? Damage, long-term storage or elevated temperatures may increase the amount of chemicals that migrate into food from cans. The Pet Food Manufacturers' Association has advised that no links have been found between bisphenol A in pet food cans and any adverse effects in pets.
• WWF commented on the estimation of bisphenol intake made in the report of the survey. The estimates made in the report of the survey were fair estimates of exposure, including ranges of intake for both infants and adults. The main problem for all scientists in considering such estimates is the lack of an up-to-date Tolerable Daily Intake (TDI) for bisphenol A. The current EU-wide review of the TDI will hopefully overcome this. WWF also noted the study on polycarbonate bottles by Earls et al. (2000). This study used simulants and not food. As noted in the survey report migration from can coatings into simulants is not an exact guide as to whether there will be migration into food and drink.
• WWF also commented on the size of the survey but they also considered that there are sufficient good quality data to support restrictions on the use of bisphenol A. They also asked why the survey found no detectable levels of bisphenol A leaching into the beverage cans tested. The survey was well carried out and interpreted effectively. Indeed it has provided the opportunity for the Food Standards Agency to start pressing for new controls across the European Union, on chemical migration from can coatings. The specific point about beverages is not completely accurate, as there was evidence of migration in one product. It is understood that bisphenol A is not used in the coatings of most beverage cans.
• WWF also commented on the statement by the independent Committee on Toxicity of Chemicals in Food, Consumer Products and the Environment on the survey. That Committee has considered WWF's points.

'The Committee's attention was drawn to WWF's comments on the COT's statement on bisphenol A (BPA). The Committee's statement was drafted in response to the results of a survey by the Food Standards Agency (FSA) on the migration of BPA from can coatings into retail samples of canned food.

The Committee noted that uncertainties exist in the scientific understanding of potential endocrine effects of BPA and therefore paid particular attention to this activity in their risk assessment. The WWF response to COT's statement points to a number of risk management issues. The remit of the COT is risk assessment and does not generally extend to advice on risk management.

The Committee recognised from the outset that, the Scientific Committee for Food's (SCF) TDI for BPA was set during 1986 on the basis of long-term studies before the potential endocrine modulating activity of this compound was proposed. The SCF is due to review the TDI for BPA in the near future.

In order to inform its review of scientific data, the COT was made fully aware of the draft report of the Health and Safety Executive (HSE) on BPA and the new study which provides the basis for classification of BPA as toxic to reproduction. The Committee was also made aware of the report of NTP's Peer review of low dose effects of endocrine disrupters. It is noteworthy that most of the studies referred to by WWF as not being included in the Committee's review were addressed at paragraph 11 of the statement.

Notwithstanding reports of apparent low-dose effects of BPA, the COT took the view, supported by the best scientific evidence available at the time of its review, that it is not appropriate to base human health risk assessment on the current reports. The Committee conclusions were based on four reasons which were explained in detail in the statement. In summary these were;

• it was not clear whether the reported low-dose effects are a transient or irreversible change in the mouse model used for these studies,
• the functional significance of the reported effects is unknown,
• the findings could not be reproduced in a number of competent laboratories,
• other chemicals that can induce subtle effects on the developing reproductive organs inevitably cause more gross defects at higher doses, whereas BPA shows no such gross developmental toxicity.

These points were also noted in NTP's peer review of low-dose effects, which concluded "the Subpanel is not persuaded that a low dose effect of BPA has been conclusively established as a general reproducible finding".

In conclusion, the COT fully acknowledged the uncertainties that exist in the scientific understanding of potential endocrine effects of BPA. Nevertheless, on the basis of all the available evidence, the Committee saw no reason for consumers to change their source of foodstuffs as a result of the survey findings. However as a matter of prudence, the Committee noted that this toxicological advice should be reviewed as further scientific evidence emerges on possible low-dose effects of endocrine modulating substances.'