The use of structure-activity relationship analysis in the food contact notification program

Food contact substances (FCS) include polymers, paper and paperboard, and substances used in their manufacture, that do not impart a technical effect on food. Moreover, FCSs are industrial chemicals generally consumed at dietary concentrations (DC) of less than 1 mg/kg food (ppm), and more commonly at less than 0.05 ppm (50 ppb), in the daily diet. As such, many industrial chemicals have been analyzed for toxicological concern, some of which may share structural similarity with FCSs or their constituents, and the majority of these studies are available in the public domain. The DCs of these compounds lend themselves to using structure-activity relationship (SAR) analysis, as the available “expert systems” and use of analogs allows for prediction and management of potential carcinogens. This paper describes the newly implemented food contact notification (FCN) program, the program by which FDA reviews FCSs for safe use, the administrative review of FCSs, the SAR tools available to FDA, and qualitative and quantitative risk assessments using SAR analysis within the regulatory framework of reviewing the safety of FCSs.