
MIGRAPASS™ is the online version of the
well-established software MIGRATEST Lite 2001 developed by Fabes
Research Company from Munich , Germany . The reliability of this software
developed in accordance with the legislation requirement and its user
friendliness allows it to be recommended as the “ specifically tailored and
user friendly” Migration Modelling software in the Practical Guide of the
European Directives.
Here are abstracts of the Practical Guide for FOOD CONTACT
MATERIALS :
A PRACTICAL GUIDE FOR USERS OF EUROPEAN DIRECTIVES .
(Updated to 15 April 2003)
File: Practical Guide SANCO D3/LR D (04.2003)
ANNEX I
MATHEMATICAL MODELS
1. Directive 2002/72/EC, Article 5, paragraph 4, provides the
following clause:
The verification of compliance with the specific migration limits
provided for in paragraph 1 may be ensured by the determination of the quantity
of a substance in the finished material or article provided that a relationship
between that quantity and the value of the specific migration of the substance
has been established either by an adequate experimentation or by the application
of generally recognised diffusion models based on scientific evidence .
To demonstrate the non-compliance of a material or article, confirmation of the
estimated migration value by experimental testing is obligatory.
2. A research project subventioned by the Commission (DG
Research) has established the mathematical equations to be applied and the
conditions for their application. The appendix 1 describes the result of this
research.
3. Commission guidelines
The Commission recommends to the enforcement authorities the application,
when appropriate, of the “modelling”, as a tool to avoid very long and
expensive analysis.
However it reminds also that if there is discrepancy between the results
obtained by experimental testing and by application of a generally recognised
diffusion model, the judgement for compliance should be based on the
experimental results.
Nota bene
Even if there is only a very low probability that the results of the
experimental testing exceed the value obtained by the application of the
“modelling”, any person that noted this discrepancy are invited to inform the
Commission.
APPENDIX 1 TO ANNEX I
ESTIMATION OF MIGRATION BY GENERALLY
RECOGNISED DIFFUSION MODELS IN SUPPORT OF
EU DIRECTIVE 2002/72/EC
(« Migration modelling »)
This document contains the conclusions of the European project
SMT-CT98-7513
‘Evaluation of Migration Models in Support of Directive 90/128/EEC'
(now 2002/72/EC)
[…]
Procedures, practical applications and examples
For migration modelling as described above corresponding home
made computer programs may be established and applied.
For conveniency reasons, it should be noted that a specifically tailored and user friendly computer program is available on the market (MIGRATEST Lite 2001, FABES GmbH Munich , Germany )
[…]
Two principal procedures can be followed with the model:
-
Based on knowledge of the existing initial concentration of a migrant of known
molecular weight in a polymer its specific time and temperature dependent
migration into a given food simulant or food can be calculated […].
-
Reversely, based on a given migration limit or SML value, the maximum initial
concentration (MIC) of a migrant of known molecular weight in a polymer that
can be used in a food contact can be estimated […].
As a general rule: In cases where the migration estimation
scheme outlined above leads to results which are above the legal limits (SML),
an experimental test of compliance is compulsory.
[…]
Optimising compliance control
Migration models can be used to optimise compliance control strategies. In
fact there is an infinite variety of packages to be tested, with different
geometry, size, type and thickness of polymer, food, shelf life of food,
temperature etc and the effort to check all these influences is huge. By using
the migration model one can find out relatively easily the worst case system,
(covering all the less severe situations) and then reduce the experimental
migration measurement just to those cases or samples where it is possible to be
in non-compliance at all.
[…]
Having the experimental result from one selected test, all the different
conditions and parameters, as mentioned above, are then modelled without a
supplementary experimental test. In this manner a significant increase of the
quality assurance is possible with many samples controlled during the same time
compared to one experiment without the additional tool of modelling. Of course,
the nature of the plastic material must be known as well as the initial
concentration of the concerned migrant (known or disclosed by producer or
experimentally tested). If not, a reasonable upper limit can be used.
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