A leading food gas supplier in Italy reports public health risks related to the illegal distribution of CO2, for carbonating water and tapping drinks.
The complaint was submitted to some regions, the Istituto Superiore di Sanità, the Antitrust Authority (AGCM), and theEuropean Food Safety Authority (EFSA). (1)
CO2, uses in the agribusiness supply chain
CO2-carbon dioxide or carbon dioxide-is an inert, odorless, colorless gas that occurs naturally in the atmosphere in limited concentrations. It is used in various stages and processes, throughout the entire food supply chain:
– greenhouse agriculture (and floriculture) for carbonic fertilization and pest control (as an alternative to the use of various chemicals, e.g., methyl bromide, phosphines, insecticides),
– Extraction of substances (e.g., caffeine, CBD) from plant raw materials (supercritical CO2),
– cold pasteurization (DPCD, Dense Phase Carbon Dioxide), in the liquid or supercritical state,
– Potabilization of water, for the purpose of recarbonation,
– refrigerated transport, dry ice production, cryogenic freezing (in liquid form, together with nitrogen),
–Modified Atmosphere Packaging (MAP), mixed with other gases, to extend the shelf-life of foods.
CO2, ingredient or food additive
Carbon dioxide is used as an ingredient or food additive (E 290), as appropriate:
– In the beverage industry, for their carbonation,
– In communities (bars, restaurants, canteens, catering,
food trucks
), for addition to non-prepackaged serving water, tapping of beer and soft drinks. (2)
CO2 outlawed, the complaint
The reported phenomena pertain to the refilling of CO2 cylinders by individuals who are not registered as food handlers (FBOs) with the ASL. As it should be, in order to guarantee public health and the effectiveness of official public controls that must be based precisely on the census of FBOs and the traceability of foodstuffs. (3)
The situation, if established, is very serious because such entities are clearly unable to ensure compliance with food safety requirements. Specifically with regard to:
– Self-control facilities and procedures (good hygienic practices, HACCP), (4)
– Purity of gases for human consumption. Which are to be considered food, since they are intended to be ingested, according to the General Food Law, (5)
– materials and objects in contact with food(MOCA). (6)
Carbonated water with fire-fighting CO2?
The carbonated water in some bars and restaurants is therefore reportedly made by sourcing non-food-grade carbon dioxide. That is, by refilling cylinders with technical-use gas such as that used for firefighting cylinders. The price of which, ça va sans dir, is well below precisely because the operating costs of gas without quality and purity guarantees are lower. (7)
Public health risks associated with the dietary use of carbon dioxide that does not comply with relevant legal requirements arise from multiple factors:
– impurities. CO2 used in fire extinguisher recharge centers does not meet the purity criteria established to ensure its food safety,
– contaminations. Cylinders for non-food uses do not guarantee protection of the gas from migration (of particles from the materials used in the containers) and external contamination.
Out with the rust!
Engineering cylinders lack the safety valve that, in allowing gas to escape, prevents other substances from entering the container. Thus, as the cylinder is gradually emptied, it incorporates air, which, once inside, creates condensation and can form liquid. Which mixes with the gas and, in case of defective blasting of the container interior, can cause rusting.
The blight of malfeasance must be removed from the Italian agribusiness supply chain. Enforcement authorities must conduct sweeping checks on the traceability of gas supplies to public establishments and canteens, trace the criminals and ensure their punishment. Without neglecting the responsibilities-including criminal liability-of public business owners who have used the dangerous CO2.
For further study, please refer to theebook‘Food Safety, Mandatory Rules and Voluntary Standards,’ at https://www.greatitalianfoodtrade.it/libri/sicurezza-alimentare-regole-cogenti-e-norme-volontarie-il-nuovo-libro-di-dario-dongo
Dario Dongo
Notes
(1) The complainants may have overlooked the magister magistrorum, the Ministry of Health, which is responsible for coordinating and planning official public controls over the agri-food chain in Italy. As well as participation in the European Risk Analysis Network. However, the Lazio region will have taken care to notify the ministry, hopefully
(2) The Legislative Decree. 231/17, in implementing reg. EU 1169/11(Food Information Regulation) and introduce appropriate penalties, requires the opposition of an appropriate sign on the tapping facility or in the immediate vicinity. Prescribing that the designation ‘treated and carbonated drinking water‘ be used when it is administered in its non-prepackaged state. V. https://www. greatitalianfoodtrade.it/etichette/alimenti-sfusi-e-preincarti-collettività (3) (3) Reg. EC 852/04, c.d. Hygiene 1, art. 6
(4) Reg. EC 852/04, Articles 3-5
(5) Reg. EC 178/02, Article 2(Definitions)
(6) Reg. EC 1935/04. Notable in this regard are:
– the recent change in requirements for stainless steel (see https://www.greatitalianfoodtrade.it/imballaggi/acciaio-inox-nei-moca-decreto-ministero-salute-e-lacune-in-europa),
– the criticality of toxic substances in MOCAs (see https://www.greatitalianfoodtrade .it/imballaggi/tossicità-chimica-dei-materiali-a-contatto-con-gli-alimenti-appello-dei-ricercatori)
– the reform-slug of MOCAs in the EU
(7) The purity requirements for food-grade CO2 (additive E290) are defined in terms of purity (99%), CO (<10 ppm), NVOC ( 0.1 mg/l), passing JEFCA tests on reducing agents (H2S, etc.) and acidity. V. Reg. EU 231/2012, laying down specifications for food additives listed in Annexes II and III of Regulation (EC) No. 1333/2008
(8) In blatant violation of reg. EC 1333/08, Article 4.1
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
