NIAS are compounds liable to migrate into food and have not been introduced voluntarily into the initial composition of the material. Analyzing the risk associated with NIAS requires the joint implementation of identification tests, hazard assessment, and exposure measurement.
Risk assessment of NIAS
In theory, the risk assessment associated with NIAS must be carried out in-depth for any packaging placed on the market; in practice, in 90% of situations, the packaging manufacturers show that the material, its composition, its transformation and post-treatment conditions have characteristics common to the vast majority of materials on the market. In this situation, it is accepted that industrial practices have made it possible to correct bad practices likely to generate NIAS of critical nature and quantities.
Therefore, the complete assessment of the risk associated with NIAS is concentrated in all situations where the composition of the material and the processes applied are outside the current practices of composition and transformation. In practice, any new material, any plasma type process, ionizing irradiation, UV treatment, transformation at a temperature higher than usual practices (...) requires the evaluation of the NIAS.
To evaluate unknown substances, (i) their identity can be determined by GCMS of the material extract; high-resolution GCMS facilitate the identification when the substance is not repertoried in mass spectra databases (ii) the hazard can be evaluated from the molecular structure thanks to QSAR models (iii) the quantification of substances with no commercial access of analytical standards needs to use semi quantification approaches to overestimate the quantity of the substance.
The previous approach being quite cumbersome to implement, alternative analysis strategies are envisaged: carry out bioassays which only if they give positive results (suspicion of undesired activity) trigger the strategy of analytical characterisation.