The United States Food and Drug Administration (FDA) regulates
about 80% of the US food supply. The administration is
likewise in charge of analyzing
not only the ingredients of the food product but the packaging as well. There are
ingredients that do not affect the food product’s taste or
makeup and exist because they affect
components of the product such as
shelf preservation, color and aroma.
These additives are classified Generally
Recognized As Safe (GRAS). Industrial
gases that are used in the food industry for Modified
Atmosphere Packaging (MAP) and refrigeration are
classified as such.
History
In 1958 Congress implemented the Food
Additives Amendment to the Federal Food, Drug and Cosmetic Act. The amendment defined food
additive as:
“Any substance the intended use for which results or may reasonably be
expected to result, directly or indirectly, in its becoming a component or
otherwise affecting the component of food.”
Excluded are like gas mixtures that are
classified as additives and not considered GRAS.
In the late 60’s cyclamate salts, which were utilized
as an artificial sweetener in soft drinks and considered GRAS, began to be questioned. The results prompted
then President Nixon to call on the FDA to reevalute the components that were considered
GRAS. In 1997, the FDA claimed that they did not have adequate resources to address all the demands
that they were receiving for substances to be classified.
Since then, the materials that were originally considered
GRAS were upholding their classification and can
be found in the Code of Federal Regulations (21 CFR). All substances after 1997 requesting
classification are granted a GRAS Notice which is concluded
by individual experts outside the
government. To explain simply, a GRAS classification earlier
than 1997 was sanctioned by the FDA and later than
1997 by accord of recognized experts then quickly
approved by the FDA.
How does this apply
to gases used in MAP?
The essential point
to take away is that there is no federal certification
given to industrial gases employed
for food processing be it freezing, formulation or packaging. The gases that are considered GRAS are carbon dioxide, helium, nitrogen, nitrous
oxide and propane. The Code of Federal
Regulations section 184.1 explains each of these gases,
with respect to suitability, with the same phrasing. This, in part, is:
·
The
ingredient must be of a purity suitable for its intended use.
·
In
accordance with 184.1--- (last three numbers identify the gas), the ingredient is used in food with no
limitations other than current good manufacturing practice. The affirmation of this ingredient as
generally recognized as safe (GRAS) as a direct human food ingredient is based
upon the following current good manufacturing conditions of use:
o
The
ingredient is used in food at levels not to exceed current good manufacturing
practice.
o
Prior
sanctions for this ingredient different from the uses established in this
section do not exist or have been waived.”
As stated, gas suppliers are
only accountable for the purity of the gas and the other sanctions (i.e. … adequate manufacturing practices…) are goverened
by the food processor or the gas supplier’s customer.
Likewise, hydrogen, carbon
monoxide and argon were recognized as ingredients
after 1997 and are not listed in 21 CFR.
Since then, they
been given a GRAS Notice under the heading of “No Questions” which indicates
that the FDA had no questions as to the validity of
the outside expert’s decision.
The main objective to take
away is that the any gases with
the label “Food Grade” have been certified in house by the manufacturer and
not by the FDA.
The certification is by purity determined by adequate handling and manufacturing practices until the product reaches
its final package (cylinders, micro-bulk vessels, transports and large cryogenic
vessels). Food processors have learned to look
for food grade products and prefer to see clean packages
with clear labels. So having separate
“food grade” cylinders and/or tanks is necessary
to succeed in this market as is demonstrated
by the successful companies naming and trademarking their
respective lines of food grade gases.
More
information on food grade gases and MAP applications can be found through PurityPlus. If you would like to purchase food grade gases
or other specialty gases for various industries in Denver, contact
Rocky Mountain Air Solutions at (303) 777-6671 or contact us via email at pevans@rockymountainair.com.
Written by John Segura.
John Segura is a licensed Professional Engineer and a seasoned
executive in the industrial gas industry.
He has 30+ years of experience in areas involving sales,
marketing, and operations both domestically and internationally. He has been in charge
of teams of engineers and technicians as an R & D manager for major gas
companies. His work eventually
led him to lead the marketing
efforts of technology worldwide for industrial gas suppliers. He now consults to
the industry on the business specializing in operations, applications and
marketing.