Food Additives

Dear folks,

This is my first time to add the new topic. I find this forum was very useful for my work. I was a food safety auditor and I can find many opinions which can enrich my interpretation on the food safety standard.

Sorry to say that my English was not very good as my native language was Mardarin.

During the recent, I find some issue on the usage of food additive which bother me a lot.

"How to ensure the compliance of the regulation for the individual country or region as different country and region had different classification on the functionality of different additives." I used Sodium Acetate as a case.

From EU, Sodium Acetate was treated as preservatives ,
From UK FSA-it was not classified as preservatives
From FAO/WHO-JECFA, it was classified as acidity regulator
From FDA, this ingredient used as a flavoring agent, adjuvant and as a pH control agent.

How can we treat it as defined functional group during research and development?, i.e. preservatives, acid regulator, flavouring agent in order to prevent the violation of the food regulation.
If we treated Sodium Acetate as preservatives in Hong Kong, it would be violated the food regulation as this was not in the positive list of the regulation.

Can anyone make some input on this issue?

Regards,
Pine

Pine,

A courrageous question and I am sure there are a lot of people out there having the same thought as you.

IMO, unless there is an International Harmonised Food Standard, you should not bother with what and how the other countries treat Sodium Acetate......at least while you are preparing to implement your FSMS.

Consequently, your direct and immediate reference would be your own country's "food law" guided by Codex Standards / etc if your local food law does not mention anything at all on the status of how Sodium Acetate should be governed or treated.

When it comes to compliant to other countries' treatment, this is where the ISO 22000 standard requires you to comply to a country's specific regulatory and legislative requirements (including allegenic management or GMO if applicable). Every product when exported must be compliant to each and every differing country's legislative and regulatory specifics......in other words, know their food laws.

Hope this explains it.

Charles Chew

Dear Charles

Thank you for your response!

The case was little bit complex. The delimma is that there is not clear definition of the on Sodium Acetate's functional properties in Hong Kong regulation and this Sodium Acetate was shiped from Japanese as the active ingredient in Anti-bacterium. The anti-bacterium was added in to the dumpling and may export to other countries. Our Hong Kong regulation was only covered the negative and positive list of the preservatives but the Sodium Acetate was not included in both list.

The definition of the this Sodium Acetate had different functional properties in different countries. Before we had the international harmonised food standard, what we can do right now?

Regards,

Pine

Pine,

A courrageous question and I am sure there are a lot of people out there having the same thought as you.

IMO, unless there is an International Harmonised Food Standard, you should not bother with what and how the other countries treat Sodium Acetate......at least while you are preparing to implement your FSMS.

Consequently, your direct and immediate reference would be your own country's "food law" guided by Codex Standards / etc if your local food law does not mention anything at all on the status of how Sodium Acetate should be governed or treated.

When it comes to compliant to other countries' treatment, this is where the ISO 22000 standard requires you to comply to a country's specific regulatory and legislative requirements (including allegenic management or GMO if applicable). Every product when exported must be compliant to each and every differing country's legislative and regulatory specifics......in other words, know their food laws.

Hope this explains it.

Charles Chew

Hello Pine,

The description from the exporter of the food additive as an anti-bacterium essentially describe it as a form of preservative. (Of course there are several functional uses of S. Acetate)

Since nothing is mentioned in the HK Food Act or the Codex with this regards, there is therefore no direct governance (does not mean that the EU has no regulations on this!). I would simply regard it as what is intended for use by the Manf. (risk assessment would support this) and IMO the quantity to food shall be limited by GMP or the lowest possible level to accomplish the desired effects.

I am attaching the Codex Std 192-1995 Rev. 5 on the "General Standard for Food Additive" for your reference but not forgetting country's specifics.

Regards
Charles Chew

From EU, Sodium Acetate was treated as preservatives ,
From UK FSA-it was not classified as preservatives

Hi - not sure if this will help, but for the UK and the rest of the EU Sodium Acetate E262(i) is permitted for use as a miscellanous food additive. The regulations don't specify that it is a preservative, although that is the normal function of this additive. The regulations used to classify additives into categories but this changed in 1995 and now all permitted additives except colours and sweeteners are listed in the Miscellanous Food Additive Regulations.

Hope it does help, and I hope everyone will forgive me if I have missed the point entirely

This thread has nearly gone dead, however just in case anyone is interested... whether Sodium Acetate works as a preservative or not is largely dependent upon the product pH. The Sodium part you can forget (unless your consumers want a low Sodium diet) as the salt will dissolve and dissociate in the water phase of the product (assuming the product isn´t dry, like potato chips). The concentration of undissociated acetic acid that results from the dissolution of acetate will increase with lowering pH (more H+ to fix onto the acetate anion); undissociated acetic acid has a much greater antimicrobial acitivity than the dissociated acetate. Hence I guess the differences in funcional uses of Sodium Acetate (as an additive (salt-like flavour enhancer and/or desiccant) at high pH or preservative at low pH (for instance in acid sorces and mayonaises)) and the consequent variation in international categorization.

Best regards,
Chris.