• Decrease font size
  • Return font size to normal
  • Increase font size
U.S. Department of Health and Human Services

Food

  • Print
  • Share
  • E-mail

Environmental Decision Memo for Food Contact Notification No. 000927

 

Date:January 19, 2010
From:Biologist, Environmental Review Team (ERT)
Office of Food Additive Safety (HFS-246)
Subject:FCN No. 927 - Melamine-urea-formaldehyde resins as binders used to assemble composited wood blocks for construction of pallets transporting produce in hydrocooling and related processes.
Notifier:CHEP USA
8517 South Park Circle
Orlando, FL 32819
 
To:Division of Food Contact Notifications (HFS-275)
Attention: Kenneth McAdams
Through: William H Lamont, Acting Supervisor, ERT
 

Attached are the Finding of No Significant Impact (FONSI) and our supplement to the environmental record for FCN 927. After this notification becomes effective, copies of the FONSI and the notifier's environmental assessment, dated October 14, 2009, may be made available to the public. We shall post digital transcriptions of the FONSI and the environmental assessment on the agency's public website.

The supplement to the environmental record contains confidential business information that should not be released to the public. A redacted copy of the document may still serve to inform the public, and we shall make it available on the agency's public website.

Please let us know if there is any change in the identity or use of the food-contact substance.

 

Hoshing W. Chang, Ph.D.

 

Attachment:
Finding of No Significant Impact
Supplement to the Environmental Record for Food Contact Notification No. 927


Finding of No Significant Impact

A food contact notification (FCN No. 927), submitted by CHEP USA, to provide for the safe use of melamine-urea-formaldehyde resins as binders used to assemble composited wood blocks for construction of pallets transporting produce in hydrocooling and related processes.

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 information, submitted by the notifier, in an environmental assessment, dated October 14, 2009, our supplement to the environmental record for FCN 927, and other information known to the agency.

 

Prepared by __________________________________________Date: January 19, 2010
Hoshing W. Chang, Ph.D.
Environmental Review Team
Office of Food Additive Safety
Center for Food Safety and Applied Nutrition
Food and Drug Administration

Approved by __________________________________________Date: January 19, 2010
William H Lamont, Acting Supervisor
Environmental Review Team
Office of Food Additive Safety
Center for Food Safety and Applied Nutrition
Food and Drug Administration


Supplement to the Environmental Record for Food Contact Notification No. 927

This document incorporates by reference the notifier's environmental assessment (EA), dated October 14, 2009, and a business projection, submitted in a letter, dated November 6, 2009, from CHEP USA to the agency, about the quantity of engineered composited wood blocks used for pallets. This supplement contains confidential business information that SHOULD NOT be released to the public.

Confidential business information [cbi] has been removed from the public version.

The purpose of this supplement is to ensure the accuracy and completeness of the environmental record and to assist the public in understanding the agency’s basis for preparing a finding of no significant impact (FONSI).

Clarification of Information in the EA

Under topic 6B, the EA states, "Thus, the principal potential route for introduction of the FCS is from the disposal of liquid wastes through the sewage system into waterways." We understand the statement refers to "oligomers that were measured in the migration experiments" but not to the food contact substance (FCS) itself. Given the conditions of exposure to hydrocooling water and the properties of the cured FCS in the engineered composited wood blocks, we believe that the cured FCS is insoluble to a degree that is unlikely to cause significantly its introduction into the environment from disposal of hydrocooling water after contact with the blocks. The discussion in topic 6B was focused on the environmental introduction of minor residues or oligomers that are concomitant to the FCS.

Salient Environmental Considerations of the Proposed Use

We expect that the principal environmental considerations stemming from the proposed action are about recycling and combusting of the wood pallets. Based on the information provided in topic 4.c, which is consistent with the life cycle inventory (LCI) report referenced in footnote 7 of the EA, about 35% of pallets are salvaged for reusable wood, and about 65% of pallets are chipped into mulch or disposed in municipal solid waste (MSW) at the end of the service-life of pallets. (The LCI reported that 90% of the wood from pallets at the end of their service life is reused, if possible, to repair other pallets or is recycled into mulch. The remaining 10% is managed as MSW, of which 20% is burned. Implicitly, the EA reported that about 93.5% of the wood is reused (35%) or recycled (90% of 65%) and that about 6.5% (10% of 65%) is managed as MSW.) Thus, oligomers and degradation products of the cured FCS; specifically, products of formaldehyde, melamine, and urea, can be emitted, as the result of weathering and microbial attack, from mulch into the environment. Also, nitrogen oxides (NOx) are anticipated to be formed and potentially released into the environment from combustion of blocks disposed in MSW.

Formaldehyde, Melamine, and Urea or Their Decomposition Products from Mulch

The environmental introduction, fate, and effect of formaldehyde emissions were already discussed in the EA and supported with confidential information. Urea and its biodegradation products are naturally occurring substances in the environment; therefore, urea components of substances emitted from mulch pose no significant environmental concerns. Melamine, if any emitted, or its oligomers and decomposition products may leach into the terrestrial environment through rainwater. Nonetheless, based on the information provided in Table 1 of the EA, "Maximum Concentration of Constituents from MUF Migration Test," we infer that the amount of melamine-based substances possibly migrating from the wood blocks into an aqueous solution is very small (in the range of parts per billion). (As reported in the EA, the measured migrations of substances were simulated on the basis, in part, of contact with 1000 gallons of water continuously recirculated for a period of 12 hours. Chipping the wood blocks, containing the cured FCS, into mulch is not expected to alter the solubility of the FCS.) Therefore, the release of melamine-based substances transported by water into soils or receiving waters of the environment is not likely to pose a significant impact based on aquatic ecotoxicity data provided in the EA.

NOx Emissions

In the last paragraph under topic 7, the EA states, "It is not possible to precisely back out the [NOx] emission estimate for municipal waste combustion (MWC) from the [Life Cycle Analysis] LCA." Notwithstanding the absence of information in the LCA (or LCI, as entitled in the reference provided by footnote 7 in the EA), the notifier provided to the agency additional confidential information about a business projection of the engineered composited wood blocks used for pallets to allow us to estimate NOx emissions from MWC. The computational considerations follow.

The nitrogen content of the FCS

The FCS represents a family of variable compositions. The estimated nitrogen content is 51.9% computed by using the “Empirical formula” provided in the EA. However, we understand that the composition expressed by the formula merely represents the components of the FCS and that the nitrogenous content depends on the relative contribution of the formaldehyde and the ratio of the sum of nitrogen-containing melamine and urea to the formaldehyde. Therefore, the computation of nitrogen content from the empirical formula does not provide an exact magnitude.

Formaldehyde-rich typical compositions of the FCS reported in public sources show that the nitrogenous content can differ by being 10% less than that derived from the empirical formula. Confidential data provided in the notification show that the nitrogen content of the FCS is [cbi]%.

The NOx emissions of the FCS from MWC of wood blocks

Elsewhere in the notification, the notifier stipulated that the FCS is about [cbi]% of the composited wood blocks. Furthermore, the notifier reported that the maximal annual quantity of blocks using the FCS is [cbi]tons. At the end of service, based on the EA, as mentioned earlier in the supplement, about 6.5% of blocks are disposed into MSW. Customarily, 20% of the disposed blocks in MSW is combusted. Therefore, we compute the potential maximum emissions of NOx from combustion of unrecycled disposed FCS as follows:

[cbi]tons blocks/year x 6.5 tons blocks disposed/100 tons blocks x 20 tons blocks managed by combustion/100 tons blocks disposed x [cbi]tons FCS/100 tons blocks x 51.9 tons nitrogen/100 tons FCS x 46 tons NOx (as NO2)/14 tons nitrogen = [cbi]tons NOx emissions/year.

We compare the annual amount of NOx emissions from combustion of disposed FCS with that from large MWC units, which is 49,500 tons/year (EPA, 2005). We find that the NOx generated from the FCS is about [cbi]% of the annual amount of NOx emitted from MWC units. We conclude that the environmental impact posed by combustion of the FCS to form NOx emissions is not significant.

Under topic 7, the EA discusses emissions of nitrogen oxides (NOx) based mainly on combustion of vehicular fuel used for the transportation of the pallets in commerce. That information is incidental and does not pertain to the environmental fate resulting from combustion of the FCS content in disposed blocks managed in MSW.

 

Prepared by __________________________________________Date: January 19, 2010
Hoshing W. Chang, Ph.D.
Environmental Review Team
Office of Food Additive Safety
Center for Food Safety and Applied Nutrition
Food and Drug Administration