S pe a i c l i d E t n o i ABPC Newsletter TM Volume 7, Number 4 The Association of British Pewter Craftsmen October 2013 New EU Regulations on leaching and testing The long-awaited European Directorate for the Quality of Medicines & Healthcare (EDQM) – Metals and alloys used in food contact materials and articles - has recently been issued. This note, prepared by Richard Abdy, Chairman of ABPC, is intended to be followed up with a more detailed analysis of the EDQM, so far as it relates to pewter, in the near future. The EDQM specifies the Specific Release Limit (SRL) of metallic elements into food and drink contained within the receptacle,; and the Regulations are organised by metallic element. Those of relevance to pewter are as follows: Tin - Pewter (not mentioned directly again in the EDQM) is directly referred to in the tin section as follows: “Pewter may contain lead as a contaminant, which can also be released. Antique pewter may have been manufactured using lead-containing alloys, but this is not the case with modern pewter. Today, maximum levels of lead are specified for lead-containing pewter.” The conclusion of the section is: “the SRL for tin is set, in approximation with Regulation (EC) No. 1881/2006, at 100mg/kg”. Antimony - Antimony is confirmed as being used in “white metal”; and pewter is not directly mentioned. However a further regulation concerning antimony is mentioned in the EDQM in that: “In France, a maximum permissible antimony content of 2.5% is specified in Information Notice No. 2004-64 on materials in contact with foodstuffs”. ABPC members selling pewter items into France should pay particular attention to this. The conclusion states: “the SRL for antimony is set at 0.04mg/kg”. Copper - There is no specific mention of pewter or similar alloys in the copper section. The conclusion states: “the SRL for copper is set at 4mg/kg”. Lead - Given the statement quoted above associating pewter with lead, I propose that we should investigate the SRL of lead for ABPC products. The lead section of the document quotes a study of “the release of lead from pewter cups”. The results of that study are quoted, with the maximum permitted release being set at 1.1mg/litre. The conclusion states: “the P-SC-EMB decided to set the SRL at 0.01mg/kg”. Testing Copper is a chemical element with the symbol Cu and atomic number 29. It is a ductile metal with very high thermal and electrical conductivity. Pure copper is soft and malleable; a freshly exposed surface has a reddish-orange colour. Symbol: Cu Melting point: 1,085 °C Electron configuration: [Ar] 3d10 4s1 Atomic number: 29 Atomic mass: 63.546 ± 0.003 u Members may recollect that the first issue of these Regulations was withdrawn after first release a couple of years ago, when it was realised that the testing criteria were largely unworkable. This document includes a chapter entitled: Analytical methods for release testing of food contact materials and articles made from metals and alloys. At first sight, the relevant sections for pewter appear to be as follows: Methods of analysis used for release testing of food contact materials and articles must comply with the provisions of Annex III of Regulation (EC) No. 882/2004 For materials or articles not yet in contact with food (i.e. non-packaging applications) but intended to come into repeated contact with foodstuffs, the release test(s) shall be carried out three times in succession … . Compliance is established on the findings from the third test. This takes account of the passivation process that some alloys undergo. Any instructions provided by the manufacturer with regard to pre-treatment of the test specimens, such as cleaning, must be followed before release testing is performed. The material or article to be tested shall be brought into contact with the intended foodstuff, if available. If no particular foodstuff has been indicated, a representative foodstuff should be selected, especially one having an equivalent pH value and organic acid, salt, fat and alcohol content. There should be prior knowledge of the natural concentration of the metals in the foodstuffs to be tested. The article should be filled to approximately 2/3 total capacity and then covered to reduce evaporation Articles should be tested under actual conditions of use, or if not applicable, by applying the following conditions: the article should be tested over a period of 10 days at 40 degrees C. Tin is a chemical element with symbol Sn and atomic number 50. It is a main group metal in group 14 of the periodic table. Symbol: Sn Melting point: 231.9 °C Electron configuration: Kr 4d10 5s2 5p2 Atomic number: 50 Atomic mass: 118.71 u My preliminary conclusions are: 1. ABPC should run a new testing program for ABPC members’ products that are intended to be in contact with food and or drink. 2. The pieces should be tested along the guidelines above (shown in greater detail in the EDQM). 3. We should test for the SRL of the four elements discussed above. 4. As products are typically associated with certain alcoholic beverages (but not sold as such) they should be tested with those liquids, and also a neutral beverage (water?). We should test a children’s christening cup. Accordingly, I propose testing a tankard with beer, a quaich with whisky, and a flask with another spirit. We will be discussing shortly whether we re-test the pieces previously tested by Sheffield Assay Office, using the same facilities, checking that they are able to test as required. Lead is a chemical element in the carbon group with symbol Pb and atomic number 82. Lead is a soft and malleable metal, which is regarded as a heavy metal and poor metal. Symbol: Pb Melting point: 327.5 °C Electron configuration: [Xe] 4f14 5d10 6s2 6p2 Atomic number: 82 Boiling point: 1,750 °C Antimony is a chemical element with symbol Sb and atomic number 51. A lustrous gray metalloid, it is found in nature mainly as the sulfide mineral stibnite. Symbol: Sb Electron configuration: Kr 4d10 5s2 5p3 Atomic number: 51 Melting point: 630.8 °C Atomic mass: 121.76 ± 0.001 u We will also consider whether we test: different alloy compositions to see any differences between them; test pieces made from alloys made by different pewter sheet manufacturers; and test a tankard that has been spun from a circle of pewter and one made from a soldered “neck” in order to see if the issues raised by the previous tests are repeated. Comments from members will not just be very welcome, but essential if we are to get the best results from the testing programme. Comments and questions, please, to: Cathy Steele. Richard Abdy, Chairman, ABPC. 11th October 2013 Thanks to Wikipedia for the descriptions of the elements and the illustrations of them. Ed. Alan Williams. Published by The Association of British Pewter Craftsmen, Unit 10, 1st Floor, Edmund Road Business Centre, Sheffield, Yorkshire, S2 4ED. www.britishpewter.co.uk Pewter Bank ITRI Antique Metalware Society The Pewter Society The Pewterer The Worshipful Company of Pewterers The Association of British Pewter Craftsmen Pewter Live 2013 Editor: Alan Williams. Published by The Association of British Pewter Craftsmen, Unit 10, 1st Floor, Edmund Road Business Centre, Sheffield, Yorkshire, S2 4ED. Copyright: ABPC, October 2013 Opinions expressed in this Journal are those of the several authors and not necessarily those of the editor or publisher.
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