Health Canada 2008 - Aluminum-containing food additive request
Health Canada’s Bureau of Chemical Safety circulated this July 3, 2008 request to industry after JECFA reduced the aluminum provisional tolerable weekly intake from 7 to 1 mg/kg body weight per week. The request asked industry for food-by-food use information so Health Canada could quantify Canadian exposure, replace some Good Manufacturing Practice (GMP) listings with numerical maximum-use levels, and check whether existing numerical maximums remained appropriate. The source is useful because its attached Table 1 lists aluminum-containing food additives then enabled in Canadian retail foods and gives the relevant numerical maximum levels where Canadian regulations already stated them.
Key numbers
Regulatory-review context:
| Parameter | Value | Notes |
|---|---|---|
| JECFA aluminum PTWI before 2006 re-evaluation | 7 mg/kg bw/week | Health Canada states the 2006 JECFA review lowered this value |
| JECFA aluminum PTWI after 2006 re-evaluation | 1 mg/kg bw/week | Triggered Health Canada’s review of aluminum-containing food additives |
| Industry response deadline | August 22, 2008 | Request letter was distributed July 3, 2008 |
| CEPA PSL2 aluminum-salts draft assessment target date cited | November 29, 2008 | Aluminum sulphate, chloride, and nitrate were specifically named |
Canadian aluminum-containing food additive permissions listed in Table 1:
| Compound | Function | Food categories named | Maximum level in source |
|---|---|---|---|
| Aluminum metal | Colouring agent | Cake decoration and food-colour preparations as aluminum lakes | GMP |
| Aluminum sulphate | Firming agent | Canned crabmeat, lobster, salmon, shrimp, tuna, pickles, relishes, unstandardized foods | GMP |
| Aluminum sulphate | Starch modifying | Starch | GMP |
| Aluminum sulphate | Stabilizes albumin during pasteurization | Liquid or frozen whole egg, egg white, egg yolk | 0.036% |
| Sodium aluminum sulphate | Firming agent | Pickles, relishes, unstandardized foods | GMP |
| Sodium aluminum sulphate | pH-adjusting agent | Baking powder, unstandardized foods | GMP |
| Sodium aluminum sulphate | Carrier of benzoyl peroxide | Flour, whole wheat flour | 900 ppm |
| Potassium aluminum sulphate | Firming agent | Pickles, relishes, unstandardized foods | GMP |
| Potassium aluminum sulphate | Firming agent | Roe of sea urchins | 350 ppm |
| Potassium aluminum sulphate | pH-adjusting agent | Ale, baking powder, beer, light beer, malt liquor, oil-soluble annatto, porter, stout, unstandardized foods | GMP |
| Potassium aluminum sulphate | Carrier of benzoyl peroxide | Flour, whole wheat flour | 900 ppm |
| Ammonium aluminum sulphate | Firming agent | Pickles, relishes, unstandardized foods | GMP |
| Ammonium aluminum sulphate | pH-adjusting agent | Baking powder, unstandardized foods | GMP |
| Sodium aluminum silicate | Anticaking agent | Salt | 1.0% |
| Sodium aluminum silicate | Anticaking agent | Fine-grained salt | 2.0% |
| Sodium aluminum silicate | Anticaking agent | Icing sugar | 1.5% |
| Sodium aluminum silicate | Anticaking agent | Dried whole egg, dried egg white, dried egg yolk, dried whole egg mix, dried egg yolk mix | 2.0% |
| Sodium aluminum silicate | Anticaking agent | Garlic salt, onion salt | 2.0% |
| Sodium aluminum silicate | Anticaking agent | Unstandardized dry mixes | GMP |
| Calcium aluminum silicate | Anticaking agent | Salt | 1.0% |
| Calcium aluminum silicate | Anticaking agent | Fine-grained salt | 2.0% |
| Calcium aluminum silicate | Anticaking agent | Garlic salt, onion salt | 2.0% |
| Calcium aluminum silicate | Anticaking agent | Unstandardized dry mixes | GMP |
| Magnesium aluminum silicate | Dusting agent | Chewing gum | GMP |
| Sodium aluminum phosphate | Emulsifying salt | Cream cheese spread, processed cheese, processed cheese food, and processed cheese spread categories | 3.5% |
| Sodium aluminum phosphate | pH-adjusting agent | Unstandardized foods | GMP |
Methods (brief)
This is an archived Canada.ca copy of a Health Canada industry request letter, not a laboratory or exposure-modelling paper. Health Canada asked industry to identify foods containing aluminum sulphate and related salts, normal use amounts or ranges on a weight-per-weight basis, total quantities used in Canadian foods, proportions attributable to different aluminum salts, technological justifications, and possible alternative additives. The attached table was excerpted from Division 16 of the Canadian Food and Drug Regulations and therefore records regulatory permissions and maximum-use conditions rather than measured aluminum concentrations.
The source uses GMP where the regulation allowed use at the minimum amount necessary to achieve the technical effect rather than a stated numeric ceiling. Those GMP entries are routeable as regulatory context, but they should not be treated as quantified concentrations. Numeric values in the table are maximum-use levels or identity/composition-standard values for additive use in named food categories.
Implications
Certification: This source documents Canadian regulatory maximum-use headroom for aluminum-containing additives in several food categories, especially flour/whole wheat flour at 900 ppm for alum salts as benzoyl-peroxide carriers, sodium aluminum phosphate at 3.5% in processed-cheese categories, and aluminum silicates at 1.0%-2.0% in salt, fine salt, dried egg products, and garlic/onion salts. These are not occurrence distributions and should not be pooled with measured aluminum concentrations in foods.
Courses: The document is a useful teaching example for the difference between a health-based intake value, a permitted additive use level, and measured finished-food contamination. It also shows why GMP-only regulatory provisions are hard to translate into exposure without industry use-level data.
App: Use only for regulatory context around aluminum-containing food additives in Canada. Consumer-facing language should avoid implying that all foods in these categories contain these additives or that maximum-use limits equal typical aluminum concentration.
Wiki pages this source may touch
- aluminum
- salt
- canned-tuna
- dill-pickles
- eggs
- processed-american-cheese
- seafood
- salt
- flour-non-rice
- canned-seafood
- eggs-product
- seafood
- efsa-aluminium-twi
Verification notes
The PDF was read from the June 3 manual-fetch folder, including the request letter and Table 1 of aluminum-containing food additives. Page count is 7. No DOI is assigned. The canonical raw file raw/Manual Fetch Kimi /June 3 Folder/ARCHIVED - Health Canada Requests Information from Industry on the Use of Aluminum-Containing Food Additives - Canada.ca.pdf and duplicate file raw/Manual Fetch Kimi /June 3 Folder/ARCHIVED - Health Canada Requests Information from Industry on the Use of Aluminum-Containing Food Additives - Canada.ca 2.pdf are byte-identical with SHA-256 4bbd82467ba30380bd7bfbf5d72d54d3c999bce392e50779b2fcf8dfc66bd65b; the duplicate is recorded in the tracker as a duplicate rather than a second source.
Scope note: this source does not report measured aluminum in foods, consumer exposure estimates, product brands, or compliance outcomes. It is ingested because Table 1 provides concrete regulatory maximum-use values for aluminum-containing additives in Canadian retail-food contexts. Any downstream route must preserve that regulatory-maximum-use basis and distinguish GMP-only entries from numeric maximums.
Page history
The five most recent substantive edits to this page. The full version history lives in git; when DOI minting comes online (see schema docs), each entry below will also link to a version-pinned DataCite DOI.