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Issue Number: Council I 027
Title
Issue you would like the Conference to consider
Restricting the use of galvanized metals from contact with food except by local variance for the specific process it is intended to be used for.
Per the 2009 FDA Food Code Public Health Reasons for 4-101.15, zinc may leach into acidic foods if they contact galvanized metal. However, the solubility of zinc is subject not only to pH but also temperature and the corrosive environment of inorganic salts. The inorganic salts can come into contact with the metal from the food or disinfectants used as part of the process.
Public Health Significance
Setting this guideline would place the requirement of providing data to the regulatory authority in order to acquire a variance.
Recommended Solution: The Conference recommends...
that a letter be sent to the FDA requesting the 2009 Food Code (as modified by the Supplement issued in 2011) be amended as follows (new language shown with underline):
4-101.15 Galvanized Metal, Use Limitation.
Galvanized metal may not be used for UTENSILS or FOODCONTACT SURFACES of EQUIPMENT unless, it is shown that zinc does not transfer to FOOD under its specified use.P