Food

Environmental Decision Memo for Food Contact Notification No. 000070

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

See also Environmental Decisions.


Date:June 26, 2000

From: Environmental Chemist, Environmental Review Team (ERT)
Division of Product Manufacture and Use (HFS-246)

Subject: FCN No. 70 - Polyolefin-carbon monoxide copolymers

Notifier: Shell Chemicals Company
c/o Keller and Heckmann
Washington, DC 20001

To: Division of Petition Control (HFS-215)
Attention: Vir Anand, Ph.D.
Through: Team Leader, ERT (HFS-246)

Attached is the Finding of No Significant Impact (FONSI) and a Supplemental Environmental Assessment (EA) for this premarket notification. When this notification becomes effective, these two documents and the notifier's EA may be made available to the public. When preparing the notifier's EA for the public, be sure to collect the information referred to in the EA, e.g., the numbered tabs and the attachments that were provided in FAP 3B4373. Be sure not to include the Confidential Business Information attachment provided with the May 10, 2000 EA.

Please let us know if there is any change in the identity or use of the food-contact substance that would be inconsistent with the identity and use described in the FONSI.

Elizabeth Ann Cox

2 Attachments


Finding of No Significant Impact

Premarket notification FCN No. 000070, submitted by Shell Chemicals Company, to provide for the safe use of carbon monoxide-ethylene copolymer and carbon monoxide-ethylene-propylene terpolymer containing no more that 8 mole-percent of propylene for use in articles intended for repeated-use in food processing establishments, for multilayer flexible packaging for refrigerated food products, and for reheatable or microwaveable rigid retort packaging for food.

The Environmental Review Team has determined that allowing this notification to become effective will not significantly affect the quality of the human environment and therefore will not require the preparation of an environmental impact statement. This finding is based on the notifier's environmental assessment dated May 10, 2003, and on a supplement to the environmental assessment prepared by an environmental chemist on the Environmental Review Team

Prepared by ________________________________________ Date: June 26, 2000
Elizabeth Ann Cox, Environmental Chemist
Environmental Review Team
Division of Product Manufacture and Use
Office of Premarket Approval
Center for Food Safety and Applied Nutrition
Food and Drug Administration

Approved by ________________________________________ Date: June 26, 2000
Buzz L. Hoffmann, Ph.D., Team Leader
Environmental Review Team
Division of Product Manufacture and Use
Office of Premarket Approval
Center for Food Safety and Applied Nutrition
Food and Drug Administration


Supplement to the Environmental Information for Food Contact Notification No. 70

This document incorporates by reference the notifier's environmental assessment (EA) dated May 10, 2000 and its attachments.

A. Potential for impact on the resources associated with landfills

If a new food packaging material will compete with and replace a currently recycled packaging material and will not be recycled itself, more landfill space will be needed for disposal. When more landfill space is needed, there is potential for effects on the resources associated with landfill volume. These effects include the impacts associated with land that otherwise would remain in an undisturbed state or could be put to some other use and that now must be used for the landfilling of solid waste.

The notifier's EA states that articles made with the subject copolymers are expected to compete with and replace other, similar polymeric containers. Our review of these applications along with information on recovery for recycling from the Environmental Protection Agency (EPA) shows that there is little or no current recycling of containers for these applications. Further, we believer that recycling of articles made with the subject copolymers is also very unlikely to occur. Thus, when the articles made with the subject copolymers compete with and replace other similar polymeric containers, there is little or not potential for impacts on resources associated with landfills because the new containers and the replaces ones will occupy essentially the same amount of landfill space. However, Table 1 of the EA lists cans as one of the types of packaging currently used in applications expected for the subject articles. Thus, we conclude that eh subject copolymers will, to some extent, be competing with and replacing a currently recycled material, steel food cans and will not themselves be recycled. Furthermore, the notifier's EA does not evaluate the potential for this replacement to impact landfill volumes. Therefore, we evaluated this potential by comparing the volume that articles made with the subject copolymers could occupy in landfills to the landfill volume of steel cans. We estimated these volumes as detailed in the attached appendix. To summarize out findings on landfill volumes, we found that the space that could be occupied by containers made with the subject copolymers was about 43,000 cubic yards. We further found that the competing steel cans occupied about 27, 000 cubic yards. Comparing, these two figures shows that the subject containers will require more space that the competing cans require, i.e., 16,000 cubic yards more. We evaluated this increased need for landfill space by comparing it to the landfill space requirements of the United States. We estimate that the landfill space requirement for the U.S. is about 550 million cubic yards. Dividing the 16,000 cubic yards increased need estimated for this action by the total requirement yields a fraction of 0.000029, or, expressed as a percentage, 0.0029%, which rounds to 0.003%. This estimate is likely to be an overestimate because 1) when making the assumptions for the calculations described in the attached appendix, we always chose to use the most conservative assumptions and 2) the notifier states that the articles made with the subject copolymers will be specifically targeted to compete with and replace other multilayer plastic articles but in some applications may replace steel cans. From this evaluation we conclude that the agency's action to allow this notification to become effective will not have a significant adverse impact on the resources associated with landfill volumes.

B. Potential for impact on steel can recycling from this action

As outlined above there is potential for articles made with the subject copolymers to replace steel cans, which are currently being recycled successfully. As shown in the attached appendix, we estimate (and likely overestimate as explained above) that the subject articles may replace 50 million pounds of steel cans. This amount is a small fraction of the total amount of steel cans recycled in the most recent year for which information is available, i.e., this amount represents about 1.4% of steel cans recycled. This means that this notification becoming effective will result in, at most, only a small reduction (as a percentage) in the numbers of steel cans available for recycling. Thus, there is a very limited potential for impact on recycling of steel cans.

Prepared by: ____________________________________ Date: June 26, 2000
Elizabeth Ann Cox, Environmental Chemist
Environmental Review Team
Division of Product Manufacture and Use
Office of Premarket Approval
Center for Food Safety and Applied Nutrition
Food and Drug Administration


Appendix to the Supplemental EA for FCN No. 70
Estimating the landfill volumes of the subject articles and of competing steel cans.

In order to evaluate the potential for the replacement of steel cans with articles made with the subject copolymers to impact landfill volumes, we estimated the landfill volumes of these articles as follows.

1. Landfill volume of the subject containers

First, we converted the market volume of the subject copolymers to a market volume of articles, as follows. The EA forecasts a market volume of 4 million pounds in the paragraph (on page H-1) where single use articles are discussed. However, it is not clear if this market volume is for packaging just reheatable/ microwaveable foods or is for both these foods and the refrigerated meat, cheese and vegetables. For this analysis, we assumed that the 4 million pounds market volume is just for packaging foods currently packaged in steel cans. Further, the EA states that, when used in these application, the subject copolymers will be one of either 3 or 5 layers. If we assume that all these layers are approximately the same weight, then the poundage volume of the articles made with the subject copolymers will be either 3 or 5 times the 4 million pounds. For this analysis, we assumed that the poundage volume of these articles will be 5 times the 4 million pounds, or 20 million pounds. Next, the poundage volume of the subject articles is converted to a space-occupied volume.

To convert poundage volume to a space-occupied volume, we first needed a disposal pattern for the subject articles, i.e., we needed to predict what percentages will be landfilled, combusted and recycled. We then used these percentages to calculate the poundage volumes being handled by each of these specific waste management technologies. As discussed in Paragraph A of the main text of this supplement, we expect little or no recycling after disposal of the multilayer articles to be made with the subject copolymers. Assuming no recycling, we calculated the landfilled and combusted percentages from information in an EPA report on municipal solid waste. These calculated percentages are 76.5% landfilled and 23.5% incinerated. We applied these percentages to the poundage volume of the subject articles and calculated the amounts expected to be combusted: 15.3 million pounds landfilled and 4.7 million pounds combusted.

We converted the landfilled poundage volume of the subject containers to a space-occupied volume by dividing the poundage amount by the predicted density of the subject articles in landfills. The previously cited EPA solid waste report gives the density factors of many components of municipal solid waste in Table B-9 on page 151. The value for plastic containers in 355 lb/cu yd. We assumed that the subject containers will have a landfill density of 355 lb/cu yd and divided the poundage volume by this density, calculating a space-occupied volume of 43,000 cubic yards.

We estimated the space-occupied volume of the subject containers after combustion in municipal waste combustors based on the fate, during combustion, of the elements that make up the subject copolymers, i.e., carbon, hydrogen and oxygen. During combustion these elements can be assumed to be completely converted to gases that are emitted by municipal waste combustors. Thus, no landfill space will be needed after combustion of the subject articles.

The total landfill space to be occupied by the subject containers is the sum of the volume directly landfilled and the volume landfilled after combustion. In this case the total landfill space is 43,000 cubic yards + 0 cubic yards which sums to 43,000 cubic yards.

2. Landfill volume of steel cans to be replaced by subject containers

The next step is to predict the landfill space occupied by the articles expected to be replaced by the subject containers. Making this prediction requires estimating how much competing material will be replaced by the subject containers. We made this prediction by first comparing the capacity for food and the weight of the subject containers to the same parameters for the competing steel cans. This comparison gives a conversion factor that we applied to the poundage volume of the subject containers to obtain a poundage volume of the competing cans.

Table 1 of the notifier's EA describes the subject containers as weighing 10 - 15 grams and holding 0.5 lbs of food. For information on the competing steel food cans, we purchased, at a local grocery store, a steel can that contained 8 oz of sliced peaches. After emptying and washing this can, we weighed it, finding that it weighed 38 rams. Using the conservative end of the range of weights of the subject containers to competing containers, we calculated a value of 2.5 for the factor to convert the poundage volume of the subject containers to a poundage volume for steel cans. Multiplying the poundage volume of the subject containers, 20 million pounds, by this conversion factor, yields an estimate for the poundage volume of the competing steel cans of 50 million pounds.

To continue the analysis of landfill space occupied by steel cans, we needed a disposal pattern for these steel cans. Steel food cans are currently recycled at 60.5%. We then used the percentages of solid waste landfilled and combusted with no recycling (calculated above) to estimate the disposal pattern of the remaining percentages of steel cans (39.5%). Thus, we estimated the disposal pattern for the steel cans that are not recycled as 30.2%, landfilled and 9.3%, combusted. We used these landfilled and combusted percentages with the poundage volume of the competing steel cans, 50 million pounds, to estimate the poundage volumes landfilled and combusted, i.e, 15.1 million pounds will be landfilled directly and 4.65 million pounds will be combusted.

As above, we converted the poundage volume to a space-occupied volume by dividing the poundage volume by the landfill density. The landfill density of steel cans is given in Table B-9 of the current EPA solid waste report, as 560 lb/cu yd. Using this density to convert the poundage volume yields a space-occupied volume of 27,000 cubic yards.

Assessing the landfill volume of the steel cans after they are combusted is somewhat more complicated. We assumed that steel containers will have the same mass before and after combustion and that this mass will become part of combustor ash. The ash that forms from combusted steel will have a much lower volume that the steel had before combustion because there will no longer be any containers to trap air. Because of the air trapped inside the containers, the weight of a given mass of steel containers is much lower than the same mass of steel when not formed into containers. In other words, the density of steel cans will be much greater after combustion. In fact, we assumed that the landfill density of the ash from combusted steel containers is the theoretical density of steel, i.e., 13,250 lbs/cu yd is the density of cold rolled steel sheet. We used this density with the combusted poundage volume, 4.65 million pounds, to estimate the space occupied by the ash from steel cans. We divided the poundage by the density to obtain a space-occupied volume of 350 cubic yards.

The total landfill space occupied by the competing steel containers is the sum of the space occupied by the cans that are directly landfilled, 27,000 cubic yards, and space occupied by the ash that forms from combusted cans, 350 cubic yards or a total of 27,350 cubic yards.

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