Notice of Modification to the  List of Permitted Food Additives with Other Generally Accepted Uses  to Enable   
The Use of S odium Tripolyphosphate or Sodium Hexametaphosphate Singly; a Combination of Sodium 
Hexametaphosphate and Sodium Carbonate; and a Combination of Sodium Tripolyphosphate,  
Sodium Acid Pyrophosphate and Sodium Pyrophosphate, Tetrabasic in Frozen Squid   
Bureau of Chemical Safety, Food Directorate, Health Products and Food Branch     1 
  Notice of Modification to the  List of Permitted Food Additives with 
Other Generally Accepted Uses  to Enable  the Use of S odium 
Tripolyphosphate or Sodium Hexametaphosphate Singly; a 
Combination of Sodium Hexametaphosphate and Sodium 
Carbonate; and a Combination of Sodium Tripolyphosphate, 
Sodium Acid Pyrophosphate and Sodium Pyrophosphate, 
Tetrabasic in Frozen Squid  
Notice o f Modification – Lists of Permitted Food Additives  
Reference Number: [NOM/ADM -0013] 
 
 
 July 11, 2013  Notice of Modification to the  List of Permitted Food Additives with Other Generally Accepted Uses  to Enable   
The Use of S odium Tripolyphosphate or Sodium Hexametaphosphate Singly; a Combination of Sodium 
Hexametaphosphate and Sodium Carbonate; and a Combination of Sodium Tripolyphosphate,  
Sodium Acid Pyrophosphate and Sodium Pyrophosphate, Tetrabasic in Frozen Squid   
Bureau of Chemical Safety, Food Directorate, Health Products and Food Branch     2 Summary  
 
Food additives are regulated in Canada under Marketing Authorizations  (MAs) issued by the 
Minister of Health and the Food and Drug 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.  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 food 
additive submission with the Depart ment'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 received a food additive submission seeking approval for the use of sodium 
tripolyphosphate or sodium hexametaphosphate singly; a combination of sodium 
hexametaphosphate and sodium carbonate; and a combination of sodium tripolyphosphate, 
sodium acid pyrophosphate and sodium pyrophosphate, tetrabasic to reduce  thaw drip in added 
frozen squid. The petitioner proposes to use these phosphate additives at a total level of 
phosphate not to exceed  0.5% calculated as sodium phosphate, dibasic in the f rozen squid. 
Sodium carbonate could be used up to a maximum level of  use of  15% of a mixture of sodium 
carbonate and sodium hexametaphosphate whe n the total added phosphate calculated as sodium 
phosphate, dibasic does not exceed 0.5% in the frozen squid.  
  
These additives are already permitted for this use at the same maximum level  of use in other 
seafoods  sold in Canada , namely : frozen lobster, frozen crab, frozen clams and frozen shrimp. 
Although frozen squid and these other seafoods are subject to the same compositional standard 
set out in section B.21.004 of the Food and Drug Regulations  (Part B), there is no provision in 
the standard or the Lists of Permitted Food Additives  for the use of any of these phosphate 
additives , or the combination of sodium carbonate and sodium hexametaphosphate , in frozen 
squid.  
  
The results of Health Canada’s evaluation of available scientific data support the safety of these 
food additives when used in frozen squid  as set out in the table below .  Health Canada has taken 
into consideration that three of the additives, sodium acid pyrophosphate, sodium 
tripolyphosphate and sodium pyrophosphate, tetrabasic, are also permitted in frozen lobster, 
frozen crab, frozen clams and frozen shrimp for the pu rpose of reducing processing losses, and 
that they should be permitted in frozen squid, a similar food, for the same purpose.   Therefore, 
Health Canada has modified the List of Permitted Food Additives with Other Generally Accepted 
Uses  by adding the following entries to this list.  
 
  Notice of Modification to the  List of Permitted Food Additives with Other Generally Accepted Uses  to Enable   
The Use of S odium Tripolyphosphate or Sodium Hexametaphosphate Singly; a Combination of Sodium 
Hexametaphosphate and Sodium Carbonate; and a Combination of Sodium Tripolyphosphate,  
Sodium Acid Pyrophosphate and Sodium Pyrophosphate, Tetrabasic in Frozen Squid   
Bureau of Chemical Safety, Food Directorate, Health Products and Food Branch     3 Modification to the List of Permitted Food Additives with Other Generally 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.1.1  Sodium Acid 
Pyrophosphate  (2) 
Frozen squid  (2) 
To reduce 
processing losses 
and to reduce thaw 
drip (2) 
Used in combination with 
sodium tripolyphosphate 
and sodium 
pyrophosphate tetrabasic, 
total added phosphate not 
to exceed 0.5% calculated 
as sodium phosphate, 
dibasic  
S.3A  Sodium Carbonate  (2)  
In combination 
with sodium 
hexametaphosphate 
for use on frozen 
squid  (2) 
To reduce thaw 
drip (2) 
15% of the combination of 
sodium carbonate and 
sodium 
hexametaphosphate  
S.6 Sodium 
Hexametaphosphate  (4) 
Frozen squid  (4) 
To reduce thaw 
drip (4) 
0.5% total added 
phosphate calculated as 
sodium phosphate, dibasic  
S.7.1  Sodium 
Pyrophosphate, 
tetrabasic  (2)  
Frozen squid  (2)  
To reduce 
processing losses 
and to reduce thaw 
drip (2) 
Used in combination with 
sodium tripolyphosphate 
and sodium acid 
pyrophosphate, total 
added phosphate not to 
exceed 0.5% calculated as 
sodium phosphate, dibasic  
S.11 Sodium 
Tripolyphosphate  (3) 
Froze n squid  (3) 
To reduce 
processing losses 
and to reduce thaw 
drip (3) 
Used singly or in 
combination with sodium 
acid pyrophosphate and 
sodium pyrophosphate 
tetrabasic, total added 
phosphate not to exceed 
0.5% calculated as sodium 
phosphate, dibasic  
 
In addition, a corrective modification has been made to column 4 of item S.1.1 of the English list 
to replace the wording “…total added pyrophosphate not to exceed” with “…total added 
phosphate not to exceed”.  This will align the wording of the English li st with the wording of the Notice of Modification to the  List of Permitted Food Additives with Other Generally Accepted Uses  to Enable   
The Use of S odium Tripolyphosphate or Sodium Hexametaphosphate Singly; a Combination of Sodium 
Hexametaphosphate and Sodium Carbonate; and a Combination of Sodium Tripolyphosphate,  
Sodium Acid Pyrophosphate and Sodium Pyrophosphate, Tetrabasic in Frozen Squid   
Bureau of Chemical Safety, Food Directorate, Health Products and Food Branch     4 French list as well as to the original intent of the provision. Thus, the text in column 4 of item 
S.1.1 has been replaced as follows:  
 
Item 
No. Column 1  
Additive  Column 2  
Permitted in or 
Upon  Column 3  
Purpose of Use  Column 4  
Max imum Level of 
Use and Other 
Conditions  
S.1.1  Sodium Acid 
Pyrophosphate  (1) 
Frozen fish fillets; 
Frozen minced 
fish; Frozen 
lobster; Frozen 
crab; Frozen 
clams; Frozen 
shrimp  (1) 
To reduce 
processing losses 
and to reduce thaw 
drip (1) 
Used in combination 
with sodium 
tripolyphosphate and 
sodium 
pyrophosphate 
tetrabasic, total added 
phosphate not to 
exceed 0.5% 
calculated as sodium 
phosphate, dibasic  
 
A corrective modification is also being made to column 2 of item S.3A of the French list by 
inserting the w ords “ pour être utilisé sur”. This will align the French version of the list with the 
wording in the English and will add clarity.  Thus, the text in column 2 of item S.3A of the 
French has been replaced  as follows : 
 
Article  Colonne 1  
Additifs  Colonne 2  
Permis dans ou sur  Colonne 3  
But de l’emploi  Colonne 4  
Limites de tolérance 
et autre conditions  
S.3A  Carbonate de 
sodium  (1)  
Mélangé avec 
l'hexamétaphosphate 
de sodium pour être 
utilisé sur les filets 
de poisson congelés, 
le homard congelé, 
le crabe cong elé, les 
clams congelés et 
les crevettes 
congelées  (1)  
Pour empêcher de 
suinter en 
dégelant  (1)  
15 % du mélange de 
carbonate de sodium 
et 
d’hexamétaphosphate 
de sodium  
 
  Notice of Modification to the  List of Permitted Food Additives with Other Generally Accepted Uses  to Enable   
The Use of S odium Tripolyphosphate or Sodium Hexametaphosphate Singly; a Combination of Sodium 
Hexametaphosphate and Sodium Carbonate; and a Combination of Sodium Tripolyphosphate,  
Sodium Acid Pyrophosphate and Sodium Pyrophosphate, Tetrabasic in Frozen Squid   
Bureau of Chemical Safety, Food Directorate, Health Products and Food Branch     5 Rationale  
 
Health Canada’s Food Directorate has completed a pre -market safety assessment of the use of 
sodium tripolyphosphate or sodium hexametaphosphate singly; a combination of sodium 
hexametaphosphate and sodium carbonate; and a combination of sodium tripolyphosp hate, 
sodium acid pyrophosphate and sodium pyrophosphate, tetrabasic in frozen squid. The 
assessment considered the toxicological, chemical and nutritional aspects of these food additives 
when used as requested in the food additive submission.   
 
Sodium tr ipolyphosphate, sodium hexametaphosphate, sodium acid pyrophosphate, sodium 
pyrophosphate, tetrabasic and sodium carbonate used in foods sold in Canada must meet the 
food-grade specifications for these additives set out in the most recent edition of the Food 
Chemicals Codex , a compendium of standards for the purity and identity of food ingredients, 
including food additives, which is published by the United States Pharmacopeial Convention.   
 
Since frozen squid is subject to a standard of composition set out  in section B.21.004 of the Food 
and Drug Regulations  (Part B), Health Canada consulted with the Canadian Food Inspection 
Agency (CFIA) and the appropriate food industry association regarding the use of these additives 
in frozen squid.  Both organizations indicated their support.  
 
Provision exists in the Codex Alimentarius General Standard for Food Additives (GSFA) for the 
use of phosphates, which includes sodium tripolyphosphate, sodium hexametaphosphate, sodium 
acid pyrophosphate and sodium pyrophosphate,  tetrabasic, in frozen fish, fish fillets, and fish 
products, including molluscs, crustaceans and echinoderms at a maximum level of 2,200 mg/kg 
(0.22%) calculated as phosphorus (equivalent to 1.01% as sodium phosphate, dibasic). The 
GSFA also permits the u se of sodium carbonate in semi -preserved , as well as preserved , fish and 
fish products, including molluscs, crustaceans and echinoderms at levels consistent with Good 
Manufacturing Practice (GMP).  
 
Based on the results of the safety assessment, Health Cana da’s Food Directorate consider s that 
the data demonstrate that these phosphate additives and sodium carbonate are safe food additives 
under the requested conditions of use in frozen squid. The Department has therefore extend ed the 
use of these food additiv es as described in the above table.  
  
Implementation and Enforcement  
 
The above modifications came into force on July 11, 2013,  the day on which they were published 
in the List of Permitted Food Additives with Other Generally 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.  
 
  Notice of Modification to the  List of Permitted Food Additives with Other Generally Accepted Uses  to Enable   
The Use of S odium Tripolyphosphate or Sodium Hexametaphosphate Singly; a Combination of Sodium 
Hexametaphosphate and Sodium Carbonate; and a Combination of Sodium Tripolyphosphate,  
Sodium Acid Pyrophosphate and Sodium Pyrophosphate, Tetrabasic in Frozen Squid   
Bureau of Chemical Safety, Food Directorate, Health Products and Food Branch     6 Contact Information  
 
Health Canada's Food Directorate is committed to reviewing any new scientific information on 
the safety in use of any food additive, including the food additives  described in this document . 
Anyone wishing to submit new scientific information on the use of these a dditives or to submit 
any inquiries may do so in writing, by regular mail or electronically. If you wish to contact the 
Food Directorate electronically, please use the words “ phosphates and sodium carbonate  in 
frozen squid ” in the subject line of your e-mail.  
 
   Bureau of Chemical Safety  
   251 Sir Frederick Banting Driveway  
   Tunney’s Pasture, PL: 2202C  
   Ottawa, Ontario K1A 0 K9 
   E-mail:  bcs-bipc@hc -sc.gc.ca