No Objection Letter for Recycled Plastics #0041
April 4, 1996
Mr. Wilfred A. Sumner II
Scientific Certification Systems
1611 Telegraph Avenue
Oakland, California 94612-2113
Dear Mr. Sumner:
This is in partial response to your letters of March 1 and 4, 1996, for your client, Enviroplastics, regarding the production of produce bags and fruit and vegetable trays and baskets from recycled HDPE milk jugs. You have submitted information on the source of the recycled plastic and the ability of the recycling process to remove potential contaminants on February 26, 1993, December 13, 1993, April 22, 1994, May 6, 1994, and September 14, 1994 for a previous request. We are responding to your request for the use of produce bags in this letter; your request for use in fruit and vegetable trays and baskets will be evaluated separately.
We have previously stated that grocery bags are an acceptable use of recycled plastic. This decision was based primarily on the fact that food that is in direct contact with the bags would only be in contact for short periods of time and usually at ambient temperatures (or cooler). We have no reason at this time to expect that the conditions under which food would be in contact with produce bags would be substantially different from this previously considered use. In addition, much of the produce in contact with the bags would be washed before being consumed. Therefore, we have determined that Enviroplastic’s use of produce bags made from recycled HDPE milk jugs is acceptable.
Although we have concluded that Enviroplastic’s intended use of recycled HDPE in produce bags is acceptable, you should be aware that we are currently developing a formal policy on the use of post-consumer recycled plastics in contact with food. Thus, the decisions set forth in this letter may need to be modified due to future deliberations on this matter.
If we can be of any further help, please do not hesitate to contact us.
Sandra L. Varner
Indirect Additives Branch
Center for Food Safety
and Applied Nutrition