Notice of Modification to the  List of Permitted 
Food Additives with Other Accepted Uses  to 
Extend  the Use of Sodium Phosphate, Tribasic 
to Certain Frozen Products  
 
Notice of Modification  – Lists of Permitted Food 
Additives  
Reference Number: NOM/ADM-0166 
April 27 , 2021 
 Notice of M odification to the List of Permitted Food Additives with Other Accepted Uses  to Extend  the Use of Sodium Phosphate, 
Tribasic to  Certain Frozen Products – Reference Number: NOM/ADM -0166| 2 
 Summary  
Food additives are regulated in Canada under Marketing Authorizations  (MAs) issued by the Minister of 
Health and the Food and Drug Regulations  (Regulations) .  Approved food additives and their permitted 
conditions of use are set out in the Lists of Permitted Food Additives  that are incorporated by reference in 
the MAs and published on the Canada.ca website.  A petitioner can request that Health Canada approve a 
new additive or a new condition of use for an already approved food additive by filing a f ood additive 
submission with the Department's Food Directorate.  Health Canada uses this premarket approval process to 
determine whether the scientific data support the safety of food additives when used under specified 
conditions in foods sold in Canada.  
Health Canada’s Food Directorate received a food additive submission seeking approval for the use of sodium 
phosphate, tribasic  (also known as trisodium phosphate  or TSP) , to reduce processing losses and thaw drip  in 
frozen shrimp and frozen cooked shrimp.   The requested maximum level of use is  0.5% total added 
phosphate, calculated as sodium phosphate, dibasic .  According to the petitioner the primary function of TSP 
is to maintain a stable , higher pH environment, which helps to restore the natural water r etention capacity of 
muscle proteins and increase the functionality of pyro - or poly -phosphates . 
In Canada, several phosphates1 other than TSP are already permitted for the same  purpose of use in frozen 
shrimp  and frozen  cooked shrimp  as well as  in frozen clams, frozen crab, frozen fish fillets, frozen lobster, 
frozen minced fish,  and frozen squid . The results of the Food Directorate’s evaluation of available scie ntific 
data support the safety and efficacy of sodium phosphate, tribasic , when used in co mbina tion with other 
phosphates, as set out in the table  below .  Therefore, Health Canada has modified the  List of Permitted Food 
Additives with Other Accepted Uses  to extend the use of sodium phosphate, tribasic , by adding the entry  
shown below to the list.  
 
Modification to the  List of Permitted Food Additives with Other Accepted Uses  
Item 
No. Column 1  
Additive  Column 2  
Permitted in or Upon  Column 3  
Purpose of use  Column 4  
Maximum Level of Use and 
Other Conditions  
S.7.1 Sodium 
Phosphate, 
tribasic  Frozen clams; Frozen 
cooked shrimp; Frozen 
crab; Frozen fish fillets; 
Frozen lobster; Frozen 
minced fish; Frozen 
shrimp; Frozen squid  To reduce processing 
losses and to reduce 
thaw drip  In combination with other 
phosphates permitted by this 
list for the same purpose of 
use, the total added 
phosphate not to exceed 
0.5%, calculated as sodium 
phosphate, dibasic  
 
  
                                                             
1 Other phosphates permitted for this purpose of use  are potassium pyrophosphate, tetrabasic , potassium 
tripolyphosphate,  sodium acid pyrophosphate, sodium hexametaphosphate, sodium potassium 
hexametaphosphate, sodium potassium tripolyphosphate, sodium pyrophosphate, tetrabasic, sodium 
pyrophosphate, tribasic, sodium tripolyphosphate  (see the List of Permitted Food Additives with Other Accepted 
Uses ). Notice of M odification to the List of Permitted Food Additives with Other Accepted Uses  to Extend  the Use of Sodium Phosphate, 
Tribasic to  Certain Frozen Products – Reference Number: NOM/ADM -0166| 3 
 Consequential and Editorial  Modification s 
To maintain the alphabetical order of  food additives in the English version of  the List of Permitted Food 
Additives with Other Accepted Uses , sodium phosphate, tribasic , needed to be inserted after sodium 
phosphate, dibasic and before sodium potassium hexametaphosphate. To have a simple item number 
sequence  for the  sodium phosphates and sodium potassium phosphates that are listed  after sodium 
phosphate, dibasic (item no. S.7), and before sodium  silicate (item no. S.8), sodium phosphate, tribasic , was 
inserted into the list as item no. S.7.1 and the item numbers for these other phosphates were revised  as 
follows : 
 Sodium potassium hexametaphosphate  is now item no. S.7.2 (formerly item no. S.7.01) ; 
 Sodium potassium tripolyphosphate  is now  item no. S.7.3 (formerly item no. S.7.02) ; 
 Sodium pyrophosphate, tetrabasic , is now  item no. S.7. 4 (formerly item no. S.7. 1); 
 Sodium pyrophosphate, tribasi c, is now item no. S.7. 5 (formerly item no. S.7 .2). 
The same  item number  revisions were also made for these phosphates in the  French v ersion  of the List.  
Minor editorial changes  were also made in the French version  of the  List.  The word “calculé” was replaced 
with “calculée” in column 4  for subitem s no. C.1(2) , no. S.6(2), and no. S.13(1) , revised subitem no. S.7.2 (2) 
(formerly subitem  no. S.7.01(2) ), and item s no. C.2, no. P.5, no. P.5.2,  no. S.1.1, revised  item no. S.7.3  
(formerly no.  S.7.02 ), revised item no. S.7. 4 (formerly item no. S.7. 1), revised item no. S.7. 5 (formerly item 
no. S.7 .2), and item n o. S.11. The  entry in column 2 for item no. S3A was revised  to remove the hyphen in 
« hexaméta -phosphate  » and to add « de », « le » and «  les » where they had been missing . All these minor 
changes do not affect the permitted uses of the food additives . 
Rationale  
Health Canada’s Food Directorate completed a premarket safety of sodium phosphate, tribasic , when used in 
combination with other pyro - or polyphosphates  that are already permitted for use to reduce processing 
losses and to reduce thaw drip . The assessment conclud ed that information related to allergenicity, 
chemistry, microbiology, nutrition  and toxicology supports the safety  of sodium phosphate, tribasic , for its 
requested use  in frozen shrimp and frozen cooked shrimp as well as in  certain other frozen marine and fresh 
water animal products that are already permitted to be treated with  certain other phosphates  to reduce 
processing losses and to reduce thaw drip There fore, the Department has enabled  the uses of  sodium 
phosphate, tribasic , shown in t he above table by adding them to  the List of Permitted Food Additives with 
Other Accepted Uses . 
Other Relev ant Information  
The Food and Drug Regulations  require that food additives such as  sodium phosphate, tribasic , that do not 
have food -grade specifications set out in Part B of the Regulations meet the food -grade specifications set out 
in the  most recent  edition of the  Food Chemicals Codex  or the Combined Compendium of Food Additive 
Specifications .  The Food Chemicals Codex  is a compendium of standards for purity and identity for food 
ingredients, including food additives, published by the United States P harmacopeial Convention. The 
Combined Compendium of Food Additive Specifications , which contains specifications prepared by the Joint 
FAO/WHO Expert Committee on Food Additives (JECFA), is published by the Food and Agriculture 
Organization of the United Na tions.  Notice of M odification to the List of Permitted Food Additives with Other Accepted Uses  to Extend  the Use of Sodium Phosphate, 
Tribasic to  Certain Frozen Products – Reference Number: NOM/ADM -0166| 4 
 Implementation and Enforcement  
The above modification came into force April 27, 2021, the day it was published in  List of Permitted Food 
Additives with Other Accepted Uses .  
The Canadian Food Inspection Agency is responsible for the enforcement of the Food and Drugs Act and its 
associated regulations with respect to foods.   
Contact Information  
Health Canada's Food Directorat e is committed to reviewing new scientific information on the safety in use of 
any permitted food additive, including  sodium phosphate, tribasic .  Anyone wishing to submit new scienti fic 
information on the use of this additive or to  submit inquiries on this modification may do so in writing, by 
regular mail or electronically.  If you wish to contact the Food Directorate electronically, please use the words 
"Sodium phosphate, tribasic (NOM -0166)" in the subject line of your e -mail.  
Bureau of Chemical Safety, Food Directorate  
251 Sir Frederick Banting Driveway  
Tunney’s Pasture, PL: 2202C  
Ottawa, Ontario K1A 0K9  
E-mail: hc.bcs -bipc.sc@canada.ca