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by lolinder 733 days ago
Your second paragraph is a very good argument against requiring that everything used in food packaging be shown to be safe before it can be used.

Can we reasonably run such a study to prove that wax paper is safe? What about plain paper? Do we just require all food producers to use no packaging at all until these controlled longitudinal studies are completed? If we allow them to use packaging, how do we define in a principled way what packaging is allowed while there are still unknowns?

One possibility would be to say that if something is currently widely used in some significant (think 5%) portion of the industry then we allow it, but that has two problems: First, it wouldn't exclude phthalates anyway, so it doesn't address the current concern. Second, it might exclude future packaging materials that we think might be safer than our current materials but which have yet to be tested.

4 comments

> Can we reasonably run such a study to prove that wax paper is safe?

We don't need to. We have a "Generally Recognized as Safe" standard that is well known and widely applied.

> widely used in some significant (think 5%) portion of the industry then we allow it

How about we just label things so consumers know whether or not the packaging contains phthalates? That way the market can decide if they want it in their package or not.

I'm not convinced labeling regulations work. Producers don't label accurately, and consumers aren't realistically in a position to make the choice being described. I live in California, where we have Prop 65 warnings on everything. The motivation there was quite similar -- people should be aware if a product or space is exposing them to substances which can cause serious harm. But I have never met a single person who refuses to enter a space with a Prop 65 warning because you basically couldn't function in society that way. When you buy a product with a Prop 65 warning, it's generally not actually feasible to know which chemical(s) (if any) prompted the warning. (Some companies may put the warning on all of their products even if only some of them actually contain such a substance.) Further, labeling for the nominal presence of some substance is not enough to make decisions -- you need to know what your actual exposure is likely to be. The system ends up being pretty useless.
In addition to what others have said, note that companies already voluntarily label their products as "phthalate free", so the market is already positioned to decide.

In the absence of concrete evidence of harm from phthalates I'm not convinced mandating yet another label would do more good than harm—it would potentially just further reduce the signal that labels provide by watering it down with yet another mandatory compliance label.

Labeling isn't bad, but it doesn't scale. It works for e.g. allergens because people who are allergic are aware of the rather rapid harm done if/when they consume allergens.
> but it doesn't scale.

Why not?

You don't even necessarily need to put all disclaimers directly on the package. Just put some kind of reference number on there, like an MSDS number, and let users go look up all the packaging information online if necessary.

The manufacturer has this information. They must in order to produce the product. The requirement would be they just have to publish it now when used to wrap food.

How does that not "scale?"

It doesn't scale in the sense of "How can I determine which of the 27 things on the label are likely to be bad for me?"
Cellulose and algae are considered safe for human consumption and are also biodegradable; but is that an RCT study?

CO2 + Lignin is not edible but is biodegradable and could replace plastics. "CO2 and Lignin-Based Sustainable Polymers with Closed-Loop Chemical Recycling" https://onlinelibrary.wiley.com/doi/10.1002/adfm.202403035

What incentives would incentivize the market to change over to sustainable biodegradable food-safe packaging?

> One possibility would be to say that if something is currently widely used in some significant (think 5%) portion of the industry then we allow it,

We could say "if it was used in the ancestral environment for similar purposes, and is not known to be harmful". Much of that stuff is bad, but our bodies have mitigations for it. (e.g. tannins leached from wooden bowls: harmful in principle, but we can metabolise them so it's fine)

Ideally rigorous testing should happen before something becomes common, but it isn’t the only option. Nothing stops you from a temporary ban say 20 years to allow for testing. Doing this for every chemical at the same time is impossible, but we can also cycle through existing chemicals.

Hypothetically, if phthalates exposure was responsible for 5% of cancer deaths that’s 30,000 dead Americans per year and we might not notice without a ban. It’s unlikely for this specific chemical to be that bad, but we don’t know.