Health Canada’s Proposal to Enable the Use of Tripotassium Phosphate (Potassium Phosphate, Tribasic), Potassium Tripolyphosph ate, 
Sodium Potassium Tripolyphosphate and Sodium Potassium Hexametaphosphate in Various Standardized and Unstandardized Foods  
  
Bureau of Chemical Safety, Food Directorate, Health Products and Food Branch     1 
  
Health Canada’s Proposal to Enable the Use of 
Tripotassium Phosphate (Potassium Phosphate, 
Tribasic), Potassium Tripolyphosphate, Sodium 
Potassium Tripolyphosphate and Sodium Potassium 
Hexametaphosphate in Various Standardized and 
Unstandardized Foods  
Notice of Proposal – Lists of Permitted Food Additives    
September  11, 2014   
Health Canada’s Proposal to Enable the Use of Tripotassium Phosphate (Potassium Phosphate, Tribasic), Potassium Tripolyphosph ate, 
Sodium Potassium Tripolyphosphate and Sodium Potassium Hexametaphosphate in Various Standardized and Unstandardized Foods  
  
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 new additive or a new condition of use for an already 
approved food additive by filing a food additive submissio n 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 receive d five food additive submissions  that together  seek approval for the use of 
tripotassium phosphate (which would be referred to in the Lists of Permitted Food Additives as 
potassium phosphate, tribasic), potassium tripolyphosphate, sodium potassium tripol yphosphate 
and sodium potassium hexametaphosphate in those foods where trisodium phosphate (referred to 
in the Lists of Permitted Food Additives as sodium phosphate, tribasic), sodium tripolyphosphate 
and sodium hexametaphosphate are already permitted.  Th e requested levels and conditions of 
use of these potassium and sodium potassium phosphates were the same as for the already 
permitted sodium analogue.   
 
Canada’s Lists of Permitted Food Additives are organized by technological function. Phosphates 
exert multiple technological functions (e.g., sequestering agent, protein stabilizer, emulsifier, pH 
modifier, texturizer) in foods and are therefore listed for use in a wide variety of foods in the 
Lists of Permitted Food Additives . 
 
The new phosphate additives could be used as substitutes for their permitted sodium analogues to 
reduce the sodium content of the food without changing the intended technical or functional 
effect of the phosphate in the food. While the potassium or sodium potassium analogues 
indicated above could be used as replacements for their sodium counterparts, food manufacturers 
would be able to continue using the sodium versions of these additives.  Thu s, manufacturers 
would have more choice and greater flexibility in food formulation.  
 
The results of Health Canada’s evaluation of available scientific data support the safety and 
efficacy of these additives when used as requested by the petitioners.  
 
In addition, Health Canada reviewed some of the foods and levels of use for the already 
approved phosphate additives.  There are a variety of approved phosphates and different 
combinations are permitted in different foods.  Health Canada’s review took into co nsideration 
the recognized technical functions, which are determined by the pH and the chain length, of the 
phosphate.  The review was limited to the use of phosphates in meat, fish and poultry.  As a 
result, certain extensions of use of already permitted phosphates are being proposed.  This would 
provide greater consistency among the permitted uses of certain phosphate additives.   
  
Health Canada’s Proposal to Enable the Use of Tripotassium Phosphate (Potassium Phosphate, Tribasic), Potassium Tripolyphosph ate, 
Sodium Potassium Tripolyphosphate and Sodium Potassium Hexametaphosphate in Various Standardized and Unstandardized Foods  
  
Bureau of Chemical Safety, Food Directorate, Health Products and Food Branch     3 Based on the outcome of this assessment, Health Canada intends to modify the List of Permitted 
Emulsifying, Gelling, Stabilizing or Thickening Agents , the List of Permitted Food Additives with 
Other Generally Accepted Uses , the List of Permitted pH Adjusting Agents, Acid Reacting 
Materials and Water Correcting  Agents , the List of Permitted Sequestering Agents  and the List of 
Permitted Starch -Modifying Agents  as described below.  
 
Proposed Modifications to the L ists of Permitted Food Additives  
 
List of Permitted Emulsifying, Gelling, Stabilizing or Thickening Agents : 
 
 Permit the use of potassium phosphate, tribasic in the same foods and with the same 
maximum levels of use and other conditions as sodium phosphate, tribasic.  
 Permit the use of sodium potassium hexametaphosphate in the same foods and with the 
same maximum levels of use and other conditions as sodium hexametaphosphate.  
 Permit the use of potassium tripolyphosphate, sodium potassium tripolyphosphate and 
trisodium pyrophosphate in a blend of prepared fish and prepared meat referred to in 
paragraph B.21.006 (n) of the  Food and Drug Regulations (FDR ). 
 Extend the use of potassium pyrophosphate, tetrabasic and sodium acid pyrophosphate to 
a blend of prepared fish and prepared meat referred to in paragraph B.21.006 (n) of the  
FDR . 
 For the phosphates (i.e. potassium  pyrophosphate tetrabasic, potassium tripolyphosphate, 
sodium acid pyrophosphate, sodium hexametaphosphate, sodium potassium 
hexametaphosphate, sodium potassium tripolyphosphate, sodium pyrophosphate 
tetrabasic, sodium tripolyphosphate, and trisodium pyrop hosphate) permitted for use in a 
blend of prepared fish and prepared meat referred to in paragraph B.21.006 ( n) of the 
FDR, the following maximum level of use is being proposed: “0.15% calculated as 
sodium phosphate, dibasic.  If used in combination with o ther phosphates, total added 
phosphate not to exceed 0.4%, calculated as sodium phosphate, dibasic.”  This is 
consistent with current maximum use levels of already permitted phosphates in this food 
but is expressed on the basis of sodium phosphate, dibasic . 
 For the use of sodium potassium hexametaphosphate in infant formula, a maximum level 
of use of 0.05% in the product, as consumed, is being proposed.  When sodium potassium 
hexametaphosphate is to be used in combination with sodium hexametaphosphate, the 
combined total amount of these two additives would be set at 0.05%.  
 
List of Permitted Food Additives with Other Generally Accepted Uses : 
 
 Permit the use of potassium tripolyphosphate and sodium potassium tripolyphosphate in 
frozen clams, frozen cooked shrimp, frozen crab, frozen fish fillets, frozen lobster, frozen 
minced fish, frozen shrimp and frozen squid with the purpose of use “To reduc e  
Health Canada’s Proposal to Enable the Use of Tripotassium Phosphate (Potassium Phosphate, Tribasic), Potassium Tripolyphosph ate, 
Sodium Potassium Tripolyphosphate and Sodium Potassium Hexametaphosphate in Various Standardized and Unstandardized Foods  
  
Bureau of Chemical Safety, Food Directorate, Health Products and Food Branch     4 processing losses and reduce thaw drip”.  These food additives would be enabled for use 
singly or in combination providing the total added phosphate does not exceed 0.5%, 
calculated as sodium phosphate, dibasic.  
 Permit the use of sodium potassium hexametaphosphate in the same foods and at the 
same maximum levels of use as sodium hexametaphosphate.  Since these two additives 
can be used in combination, it is proposed that the total amount of the two additives when 
used in combination be set at 2% and 0.2%, respectively, for gelatin intended for 
marshmallow composition and beef blood.  
 Extend the use of potassium pyrophosphate, tetrabasic to frozen clams, frozen cooked 
shrimp, frozen crab, frozen fish fillets, frozen  lobster, frozen minced fish, frozen shrimp 
and frozen squid with the purpose of use “To reduce processing losses and reduce thaw 
drip”.  This food additive would be enabled for use singly or in combination with other 
permitted phosphates providing the tot al added phosphate does not exceed 0.5%, 
calculated as sodium phosphate, dibasic.  
 Extend the use of sodium acid pyrophosphate, sodium hexametaphosphate and sodium 
pyrophosphate, tetrabasic to frozen cooked shrimp at a maximum level of use such that 
total a dded phosphate does not exceed 0.5% calculated as sodium phosphate, dibasic.  
 Extend the use of sodium pyrophosphate, tetrabasic to frozen squid at a maximum level 
of use such that total added phosphate does  not exceed 0.5% calculated as sodium 
phosphate, d ibasic.  
 Permit the use of trisodium pyrophosphate in frozen squid and frozen cooked shrimp at a 
maximum level of use such that total added phosphate does not exceed 0.5% calculated 
as sodium phosphate, dibasic.  
 Permit the use of sodium carbonate in combina tion with either sodium 
hexametaphosphate or sodium potassium hexametaphosphate or both and extend the use 
of sodium carbonate, in combination with either sodium hexametaphosphate or sodium 
potassium hexametaphosphate or both, to frozen squid and frozen co oked shrimp.  
 Add the use of sodium hexametaphosphate in frozen minced fish at a maximum level of 
use of “total added phosphate, not to exceed 0.5% calculated as sodium phosphate, 
dibasic” as a corrective modification to reflect the standard set out in B.21 .003 ( b).  
 Replace the term “frozen fish” in column 2 of item S.7 Sodium phosphate, dibasic with 
“glaze for frozen fish”  in order to use a more appropriate term.  
 
List of pH Adjusting Agents, Acid -Reacting Materials and Water Correcting Agents : 
 
 Permit po tassium phosphate, tribasic in ale, beer, malt liquor, porter, stout and 
unstandardized foods at a maximum level of use consistent with good manufacturing 
practice.   
Health Canada’s Proposal to Enable the Use of Tripotassium Phosphate (Potassium Phosphate, Tribasic), Potassium Tripolyphosph ate, 
Sodium Potassium Tripolyphosphate and Sodium Potassium Hexametaphosphate in Various Standardized and Unstandardized Foods  
  
Bureau of Chemical Safety, Food Directorate, Health Products and Food Branch     5  Permit potassium tripolyphosphate, sodium potassium hexametaphosphate and sodium 
potassium tripolyphosphate in unstandardized foods at a maximum level of use consistent 
with good manufacturing practice.  
 In the French version of the list, the name of the food additive identified as item P.10 is 
proposed to change from “phosphate bipotassique” to “phosphate dipotassique” for 
consistency.  
 In the French version of the list, the name of the food additive identified as item S.22 is 
proposed to change from “polyphosphate trisodique” to “tripolyphosphate de sodium” for 
consistency.  
 
List of Permitted Sequestering Agents :  
 
 Permit the use of potassium tripolyphosphate and sodium potassium tripolyphosphate in 
the same foods with the same maximum level of use and other conditions of use as 
sodium tripolyphosphate.  
 Permit the use of sodium potassium hexame taphosphate in the same foods and the same 
maximum level of use and other conditions of use as sodium hexametaphosphate.  
 Extend the use of potassium phosphate, monobasic; potassium phosphate, dibasic; 
sodium acid pyrophosphate; sodium hexametaphosphate; so dium phosphate, dibasic; 
sodium phosphate, monobasic and trisodium pyrophosphate to meat tenderizers at a 
maximum level of use consistent with good manufacturing practice.  
 Extend the use of potassium pyrophosphate, tetrabasic and sodium pyrophosphate, 
tetrabasic to canned seafood at a maximum level of use such that total added phosphates 
do not exceed 0.5% calculated as sodium phosphate, dibasic.  
 Extend the use of potassium pyrophosphate, tetrabasic; potassium phosphate, monobasic 
and potassium phosphate, dibasic to injection or cover solutions for use in the curing of 
poultry or poultry meat, and pumping pickle for the curing of pork, beef and lamb cuts.  
 
List of Permitted Starch -Modifying Agents : 
 
 Permit the use of potassium tripolyphosphate and sodium po tassium tripolyphosphate in 
starch at a maximum level of use such that total residual phosphate does not exceed 0.4% 
calculated as phosphorus.  
  
Rationale  
 
Health Canada’s Food Directorate has completed its pre -market safety and efficacy assessment 
of potassium phosphate, tribasic (also known as tripotassium phosphate), potassium 
tripolyphosphate, sodium potassium tripolyphosphate and sodium potassium hexamet aphosphate  
Health Canada’s Proposal to Enable the Use of Tripotassium Phosphate (Potassium Phosphate, Tribasic), Potassium Tripolyphosph ate, 
Sodium Potassium Tripolyphosphate and Sodium Potassium Hexametaphosphate in Various Standardized and Unstandardized Foods  
  
Bureau of Chemical Safety, Food Directorate, Health Products and Food Branch     6 when used as described above.  The assessment considered toxicological, nutritional and 
technical aspects of the proposal.   
 
Since these additives could be used as replacements for sodium -based phosphates, there would 
be no change on the phosph ate level in the food supply.  However, the use of these additives 
could result in an increase in potassium intake.  Available information suggested a complete 
replacement of the sodium analogues with the potassium or sodium potassium analogues would 
resul t in the mean potassium intake increasing by approximately 200 mg but remaining below 
the adequate intake (AI) of 4700 mg for adults.  It was also noted that this would also result in a 
comparable reduction in the sodium intake.   
 
Based on the results of the safety assessment, Health Canada’s Food Directorate  scientists  
consider that the data support the safety of potassium phosphate, tribasic (tripotassium 
phosphate), potassium tripolyphosphate, sodium potassium tripolyphosphate and sodium 
potassium hexam etaphosphate when used in the same foods and at the same levels of use as their 
sodium analogues.  Health Canada  is therefore proposing to enable the use of potassium 
phosphate, tribasic (tripotassium phosphate), potassium tripolyphosphate, sodium potassiu m 
tripolyphosphate and sodium potassium hexametaphosphate as described above.  
  
International Environment  
 
Tripotassium phosphate and potassium tripolyphosphate are listed in the Codex General 
Standard for Food Additives (GSFA) for use in foods where all other phosphates are allowed.  
While sodium potassium tripolyphosphate and sodium potassium hexametaphosphate are not 
specifically listed in the GSFA, the sodium analogue and potassium analogues of these two 
additives are listed.  
 
All four additives are considered Generally Recognized as Safe (GRAS) and are permitted for 
various food uses in the United States.  
 
The European Union permits the use of tripotassium  phosphate and potassium tripolyphosphate 
in many processed foods, inclu ding certain meat, poultry, fish and seafood applications.  
Although sodium potassium tripolyphosphate and sodium potassium hexametaphosphate are not 
specifically listed for use in foods, both their sodium and potassium analogues are permitted for 
use. 
 
The Australia New Zealand Food Standards Code provides for the use of sodium, potassium, 
calcium, ammonium and magnesium phosphates; the pyrophosphates; the triphosphates; and the 
polyphosphates.  These provisions would include tripotassium phosphate, potass ium 
tripolyphosphate, and may include sodium potassium tripolyphosphate and sodium potassium 
hexametaphosphate (where specifications exist in primary or secondary sources recognized by 
Food Standards Australia New Zealand), in a variety of foods, including  certain meat, poultry, 
fish and seafood applications.  
  
Health Canada’s Proposal to Enable the Use of Tripotassium Phosphate (Potassium Phosphate, Tribasic), Potassium Tripolyphosph ate, 
Sodium Potassium Tripolyphosphate and Sodium Potassium Hexametaphosphate in Various Standardized and Unstandardized Foods  
  
Bureau of Chemical Safety, Food Directorate, Health Products and Food Branch     7 Potassium phosphate, tribasic (tripotassium phosphate), potassium tripolyphosphate, sodium 
potassium tripolyphosphate, and sodium potassium hexametaphosphate that would be used in 
foods sold in Canada  would need to 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 Un ited 
States Pharmacopeial Convention.  
 
Implementation and Enforcement  
 
The proposed changes will be effective the day on which they are published in the Lists of 
Permitted Food Additives .  This will be announced via a Notice of Modification which will be 
published on the Food and Nutrition - Public Involvement and Partnerships  section of Health 
Canada’s Website . 
  
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  
For additional information or to submit comments related to this proposal, please co ntact:   
 
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  
 
If communicating  by e-mail, please use the word  “phosphates ” in the subject line of your e -
mail.   Health Canada is able to consider information received by November  24, 2014 , 75 days 
from the date of this posting.