Notice of Modification to the List of Permitted Food Additives with Other Generally Accepted Uses  and the List of Permitted Sequestering 
Agents  to Enable the Use of Trisodium Pyrophosphate in Unstandardized Foods and Certain Standardized Fish Products   
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  and the List 
of Permitted Sequestering Agents  to Enable the Use of 
Trisodium  Pyrophosphate in Unstandardized Foods and 
Certain Standardized Fish Products  
 
Notice of Modification – Lists of Permitted Food Additives  
Reference Number: [NOM/ADM -0034] 
 
 
 August  20, 2014   
Notice of Modification to the List of Permitted Food Additives with Other Generally Accepted Uses  and the List of Permitted Sequestering 
Agents  to Enable the Use of Trisodium Pyrophosphate in Unstandardized Foods and Certain Standardized Fish Products   
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 and published on Health Canada’s website.  A petitioner 
can request that Health Canada approve a n ew additive or a new condition of use for an already 
approved food additive by filing a food additive submission with the Department's Food 
Directorate.  Health Canada uses this premarket approval process to determine whether the 
scientific data support th e 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 trisodium 
pyrophosphate in those standardized meat, poultry and fish products and un standardized foods 
where the use of tetrasodium pyrophosphate and sodium acid pyrophosphate are currently 
permitted.  Trisodium pyrophosphate is a phosphate that has a variety of technical functions (e.g, 
inhibit protein denaturation, sequester metal ions,  reduce cooking loss, maintain colour stability).  
It would be used in place of other already -permitted phosphate salts.  
 
The results of Health Canada’s evaluation of available scientific data support the safety and 
efficacy of trisodium pyrophosphate when  used as requested by the petitioner.  Since this is a 
food additive that was not previously permitted for use in Canada, Health Canada published an 
Information and Consultation Document on Health Canada’s Proposal to Enable the Use of the 
Food Additive ‘Trisodium Pyrophosphate’ in Certain Standardized Meat, Poultry and Marine 
and Freshwater Products, and in Unstandardized Foods  in October 2012, requesting comments.  
No new scientific information was submitted to the Department as a result of this publication. 
Since the conclusions of the evaluation remain as described in the publication, Health Canada 
has modified the Lists of Permitted Food Additives as indicated bel ow. 
 
At this time, Health Canada is enabling the use of trisodium pyrophosphate in standardized fish 
products and unstandardized foods.  The approval for  use of this additive in standardized meat 
and poultry  products is currently  delayed  until Health Canad a can resolve  issues related to 
provisions in the Food and Drug Regulations  that set out minimum protein requirements for 
these products when phosphate additives are used.  While  there will be no change to the 
requirements for minimum protein content when phosphate additives are used in these products , 
Health Canada does anticipate being in a position to make a decision on these additional uses in 
the near future.  
 
 
 
 
 
 
  
Notice of Modification to the List of Permitted Food Additives with Other Generally Accepted Uses  and the List of Permitted Sequestering 
Agents  to Enable the Use of Trisodium Pyrophosphate in Unstandardized Foods and Certain Standardized Fish Products   
Bureau of Chemical Safety, Food Directorate, Health Products and Food Branch     3 Modifications to the Lists of Permitted Food Additives  
 
The following information has been added in 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  
T.5 Trisodium 
pyrophosphate  Frozen clams; 
Frozen crab; Frozen 
fish fillets; Frozen 
lobster; Frozen 
minced fish; Frozen 
shrimp  To reduce processing 
losses and to reduce 
thaw drip Used in combination 
with sodium 
tripolyphosphate, total 
added phosphate not to 
exceed 0.5% calculated 
as sodium phosphate, 
dibasic.  
 
In addition, the following modification to column 4 of item S.11 in the List of Permitted Food 
Additives with Other Generally Accepted Uses is necessary to allow for the use of trisodium 
pyrophosphate in combination with sodium tripolyphosphate.  
 
The terminology “frozen comminuted fish” has been removed from the listing for so dium 
tripolyphosphate.  The wording is redundant as the meaning is captured by the term “frozen 
minced fish”.  
 
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.11 Sodium 
tripolyphosphate  (1) 
Frozen clams; 
Frozen crab; Frozen 
fish fillets; Frozen 
lobster; Frozen 
minced fish; Frozen 
shrimp  (1) 
To reduce processing 
losses and to reduce 
thaw drip  (1) 
Used singly or in 
combination with 
sodium acid 
pyrophosphate and 
sodium pyrop hosphate 
tetrabasic or in 
combination with 
trisodium 
pyrophosphate, total 
added phosphate not to 
exceed 0.5% calculated 
as sodium phosphate, 
dibasic.  
 
 
 
 
  
Notice of Modification to the List of Permitted Food Additives with Other Generally Accepted Uses  and the List of Permitted Sequestering 
Agents  to Enable the Use of Trisodium Pyrophosphate in Unstandardized Foods and Certain Standardized Fish Products   
Bureau of Chemical Safety, Food Directorate, Health Products and Food Branch     4 The following information has been added to the List of Permitted Sequestering Agents : 
 
Item 
No: Column 1  
Additive  Column 2  
Permitted In or Upon  Column 3  
Maximum Level of use and Other 
Conditions  
T.1 Trisodium 
Pyrophosphate  (1)  
Canned seafoods  (1) 
Used singly or in any combination 
with sodium acid pyrophosphate, 
sodium hexametaphosphate or 
sodium tripolyphosphate, total added 
phosphate not to exceed 0.5% 
calculated as sodium phosphate, 
dibasic  
(2)  
Unstandardized foods  (2) 
Good Manufacturing Practice  
 
In addition, the modifications to column 3 of items S.1, S.3, S.7 are required to the List of 
Permitted Sequestering Agents  as a result of this submission:  
 
Item 
No: Column 1  
Additive  Column 2  
Permitted In or Upon  Column 3  
Maximum Level of use and 
Other Conditions  
S.1 Sodium acid 
pyrophosphate  (1) 
Canned seafoods  (1) 
Used singly or in any combination 
with sodium hexametaphosphate, 
sodium tripolyphosphate or 
trisodium pyrophosphate, total 
added phosphate not to exceed 
0.5%, calculated as sodium 
phosphate, dibasic.  
S.3 Sodium 
hexametaphosphate  (1) 
Canned seafoods  
 (1) 
Used singly or in any combination 
with sodium acid pyrophosphate, 
sodium tripolyphosphate or 
trisodium pyrophosphate, total 
added phosphate not to exceed 
0.5%, calculated as sodium 
phosphate, dibasic.  
S.7 Sodium 
tripolyphosphate  (6) 
Canned seafoods  (6) 
Used singly or in any combination 
with sodium acid pyrophosphate, 
sodium hexametaphosphate or 
trisodium  pyrophosphate, total 
added phosphate not to exceed 
0.5%, calculated as sodium 
phosphate, dibasic.  
  
Notice of Modification to the List of Permitted Food Additives with Other Generally Accepted Uses  and the List of Permitted Sequestering 
Agents  to Enable the Use of Trisodium Pyrophosphate in Unstandardized Foods and Certain Standardized Fish Products   
Bureau of Chemical Safety, Food Directorate, Health Products and Food Branch     5 Rationale  
 
Health Canada’s Food Directorate completed a pre -market safety and efficacy assessment of 
trisodium  pyrophosphate.  The assessment considered microbiological, toxicological, nutritional 
and technical aspects of trisodium pyrophosphate when used as requested in the food additive 
submission.     
 
As the permitted foods and levels of use for trisodium pyrophosphate are the same as those for 
the already -permitted phosphate salts and since this additive could be used to replace other 
permitted phosphates, it is not expected that trisodium pyrophosphate will increase dietary intake 
of pho sphate or sodium for consumers. Furthermore, trisodium pyrophosphate is chemically 
equivalent to a 50:50 equimolar blend of sodium acid pyrophosphate and tetrasodium 
pyrophosphate (sodium pyrophosphate, tetrabasic), two already permitted food additives.  
 
Based on the results of the safety assessment, Health Canada’s Food Directorate considers that 
the data support the safety of trisodium pyrophophate when used under the conditions of use set 
out in the tables above.  The Department has therefore enabled the  use of trisodium 
pyrophosphate as described in the above tables.  
 
Other Relevant Information  
 
Trisodium pyrophosphate used in foods sold in Canada must meet the food -grade specifications 
set out in the most recent edition of the Food Chemicals Codex (FCC). The FCC is a 
compendium of standards for purity and identity of food ingredients, including food additives, 
which is published by the United States Pharmacopeial Convention.   
 
Trisodium  pyrophosphate is recognized by the international Codex Alimentarius Commission as 
having a number of functional classes. The Codex General Standard for Food Additives (GSFA) 
provides for the use of this additive in food. Trisodium pyrophosphate is permitt ed to be used in 
the European Union, the United States and Australia/New Zealand in a broad range of foods, 
which include certain meat, poultry and fish products.  
 
Notification – Summary of Comments  
   
In response to the Information and Consultation Document on Health Canada’s Proposal to 
Enable the Use of the Food Additive ‘Trisodium Pyrophosphate’ in Certain Standardized Meat, 
Poultry and Marine and Freshwater Produc ts, and in Unstandardized Foods  published in 
October 2012, no comments were received.  
 
 
 
 
  
Notice of Modification to the List of Permitted Food Additives with Other Generally Accepted Uses  and the List of Permitted Sequestering 
Agents  to Enable the Use of Trisodium Pyrophosphate in Unstandardized Foods and Certain Standardized Fish Products   
Bureau of Chemical Safety, Food Directorate, Health Products and Food Branch     6 Implementation and Enforcement  
 
The above modification came into force August  20, 2014 , the day it was published in the List of 
Permitted Food Additives with Other Generally Accepted Uses  and the List of Permi tted 
Sequestering Agents . 
 
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 Directorate is committed to reviewing any new scientific information on 
the safety in use of any food additive, including trisodium pyrophosphate . Anyone wishing to 
submit new scientific information on the use of this additive or to su bmit 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 " trisodium pyrophosphate " 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 0L2  
E-mail:  bcs-bipc@hc -sc.gc.ca