Document 1ZRrjRbw7k6VaZJYBKZgzKgj

Monsanto Industrial Chemicals Company St. Louis, Missouri cc: R. W. Bucknell J^A. Cannon <J. R. Darby D. J. Denby A. G. Eades M. W. Farrar E. H. Fording R. E. Lamkin A. W. Morgan , J. H. Orem . W. E. Schalk N. W. Touchette df: U.S.D.A. B3NB 1760 1760 B3NC B3NH R2E B3NJ B3NC 1760 B3ND B3NJ 1760 COMMERCIAL DEVELOPMENT CALL REPORT NO. 72-67 fi.'S.' DEPARTMENT OF AGRICULTURE Consumer ^and marketing service ^WASHINGTON, D. C. Date of Call; October 4, 1972 For U.S.D.A.: Mr. John W. Sloan -- -- i -J For Monsanto: K. W. Easley P. R. Graham Objectives: 1. Clarify interaction of USDA with 1AStelative | to meat packaging regulations. Summary: 2/ Determine requirement for USDA approval for t Santicizer 334F and Santicizerl60. The USDA regulates materials used in packaging for meat and poultry. The criteria for acaeptance is essentially the same as those in FDA regulations. Sloan, however, regards the ex terior ply of a multi-laminate film as requiring the same ex traction resistance as the inside ply which contacts the food surface. The FDA considers the outside ply to require less severe extraction tests. This discussion was prompted by Oscar Mayer's request for clarification. is F. DSW 588179 STLCOPCB4093515 COMMERCIAL DEVELOPMENT CALL REPORT NO. 72-67 USDA CONSUMER AND MARKETING SERVICE Page 2 USDA regulation of plasticizers can be obtained by providing a letter containing its chemical name or description and the FDA regulation under which it is covered. The USDA will then outline similar coverage under their rules via letter. We plan to obtain this additional regulation for Santicizer 334F and Santicizer 160. Details; The USDA considers compliance with the FDA regulations for food packaging materials to be the basis for USDA clearance for meat and poultry packaging. The mechanism is a letter from/to the USDA spelling out the chemical name and pertinent FDA re gulation including any limitations. The letters are provided on an individual basis and no list of regulations such as those contained in the Federal Register are published. Although the FDA regulations are used, in some instances these regulations are extended by the FDA. An example is multi laminate film. The FDA considers the exterior ply, which does not come in contact with the food, to require less strenuous migration tests than the interior surface contacting the food. The USDA feels that the housewife does not always re-wrap the meat exactly as packed but may turn the package inside out. Oscar Mayer, uses multi-laminate films composed of Saran (in side) and plasticized PVC (DOA/S-160/ESO) as the outside layer. Depending upon the S-160/DOA ratio some question may arise as to the amount of migration which might occur if the outside layer was placed next to the meat. The USDA classifies meat and poultry packaging as follows: 1. Room Temperature & Freezer storage (below 150F.) 2. Boil in Bag (up to 250F.) > 3. Oven Temperature (above 250C. or at oven temperature) l i i DSW 588180 STLCOPCB4093516 COMMERCIAL DEVELOPMENT CALL REPORT NO. USDA CONSUMER AND MARKETING SERVICE Page 3 72-67 The USDA uses FDA 121.2514 to cover continuous use applications such as coriveyer belts and other meat processing equipment. They have no immediate concern regarding the phthalate question. They do not have any jurisdiction over milk tubing. Action: . PRG - Request USDA coverage (via letter) for S-334F and S-160 P. R. Graham DSW 588181 STLCOPCB4093517