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The objective of this project was to determine whether recycled pulp is safe for direct contact with fatty and aqueous foods. Current federal regulations (CFR 176.260) forbid direct contact between recycled pulp products and foods which are high in fat or moisture unless the absence of poisonous or deleterious materials can be shown.
California's Safe Drinking Water & Toxic Enforcement Act of 1986 (Proposition 65) has identified hundreds of carcinogens and reproductive toxicants which must be restricted to State proscribed 'No Significant Risk Levels'. However, the presence of lead in recycled paperboard is known to exist at levels which would surpass the proposition 65 reproductive toxin restriction of 0.5 µg/day assuming 100% migration into food. During the first year, analysis protocols were developed to quantify lead in paperboard and fatty and aqueous food extracts. The second and final year of the study found that recycled paperboard will not impart any meaningful level of lead to fatty or aqueous foods held in direct contact with paperboard containers filled and used at ambient temperature. It appears that lead migration concerns will scientifically, be a non-issue.