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Chromium in food and drinking water Committee for Food was unable to define a specific physiological requirement for Cr(III) (SCF, 2003). In a recent review Vincent pointed out that the mechanism of action of Cr(III) as an essential element has not been identified yet and the reports of clinically relevant chromium deficiency in humans are rare and controversial (Vincent, 2010). The role of Cr(III) as an essential element is currently under evaluation by the EFSA Panel on Dietetic Products, Nutrition and Allergies (EFSA NDA Panel, in preparation). 2. Legislation EU Council Directive 98/83/EC 8 ‘on the quality of water intended for human consumption’ sets a parametric value for total chromium at 50 µg/L (Annex I, Part B ‘Chemical parameters’); at the same time, it also indicates the minimum performance characteristics to be warranted by the method used for the analysis. As the aforesaid maximum level is for unspeciated chromium, the water could virtually contain toxic Cr(VI) up to the maximum concentration allowed and still be compliant with chromium regulatory requirement for potability. As known, within the Directive scope, water intended for human consumption refers to: ‘all water … intended for drinking, cooking, food preparation or other domestic purposes, … from a distribution network, from a tanker, or in bottles or containers’; ‘all water used in any food-production undertaking for the manufacture, processing, preservation or marketing of products or substances intended for human consumption …’. In the EU, the concentration limit for chromium in natural mineral waters is regulated by the Commission Directive 2003/40/EC 9 . In this Directive, chromium is listed in Annex I amongst the constituents naturally present in natural mineral waters, with a Maximum Limit of 50 µg/L (as total chromium). In the USA, total chromium in drinking water is regulated in the Title XIV of the Public Health Service Act (Safe Drinking Water Act) with a federal drinking water standard of 0.1 mg/l (U.S. EPA, online). There are currently no maximum levels in the EU legislation for chromium - either Cr(III), Cr(VI), or total - in foodstuffs. In general, chromium in food contact materials (FCM) is not regulated at the EU level, and in particular in metal and alloys used for FCM. However, the Council of Europe recently published a practical guide on metals and alloys used for food contact materials and articles, and which sets out a specific release limit of 0.25 mg/kg (EDQM, 2013). Several Cr(VI) compounds and salts are included in the list of substances subject to authorisation for their placing on the market under Annex IV of the REACH Regulation (EC) No 1907/2006 10 . Chromium is listed in the EC Regulation 1925/2006 11 amongst the minerals which may be added to food in the form of the following Cr(III) salts: chromium chloride and its hexahydrate, chromium sulphate and its hexahydrate. Following a decision of the European Commission 12 , chromium 8 Council Directive 98/83/EC of 3 November 1998 on the quality of water intended for human consumption. OJ L 330, 5.12.1998, p. 1-28. 9 Commission Directive 2003/40/EC of 16 May 2003 establishing the list, concentration limits and labelling requirements for the constituents of natural mineral waters and the conditions for using ozone-enriched air for the treatment of natural mineral waters and spring waters. OJ L126, 22.5.2003, p. 34-39. 10 Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), establishing a European Chemicals Agency, amending Directive 1999/45/EC and repealing Council Regulation (EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as well as Council Directive 76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC. OJ L 136, 29.5.2007, p. 3-280. 11 Regulation (EC) No 1925/2006 of the European Parliament and of the Council of 20 December 2006 on the addition of vitamins and minerals and of certain other substances to foods. OJ L 404, 30.12.2006, p. 26-38. 12 Commission Decision of 27 May 2011 authorising the placing on the market of Chromium Picolinate as a novel food ingredient under Regulation (EC) No 258/97 of the European Parliament and of the Council. 2011/320/EU, OJ L 143, 31.5.2011, p. 36-37. EFSA Journal 2014;12(3):3595 24
Chromium in food and drinking water picolinate was authorised as a novel food ingredient under Regulation (EC) No 258/97 of the European Parliament and of the Council. 3. Sampling and methods of analysis 3.1. Sample collection and storage There are no specific guidelines for the sampling of foods to be analysed for their total chromium and chromium species content. Therefore, basic rules for sampling of trace elements should be followed. For example, requirements are laid down in Commission Regulation (EC) No 333/2007 13 amended by Commission Regulation (EU) No 836/2011 14 for methods of sampling and analysis for the official control of some trace elements in certain foodstuffs. This Regulation contains inter alia a number of provisions concerning methods of sampling depending on the size of the lot, packaging, transport, storage, sealing and labelling. The primary objective is to obtain a representative and homogeneous laboratory sample with no secondary contamination. The EN 13804:2013 standard does not deal with sampling issues but it details processes involved from receipt of the laboratory sample to the end result. Both laboratory samples and test samples shall be stored in such a way that the composition and sample mass does not change as a result of, for instance, drying out, evaporative loss, spoilage or decay. In speciation analysis of food samples, only borosilicate or quartz glass should be used for handling and storage. Some glassware may cause contamination with chromium (EN 13804:2013). Dilution shall be done only immediately before the analysis. Parameters with a strong influence in speciation analysis are: a) Temperature: Storage temperature shall be low enough to prevent microbial activity resulting in reactions e.g. methylation and biodegradation. For Cr species, keep samples at 4 °C or lower. b) pH: The pH of the media may strongly affect the stability of the inorganic species. Samples intended for species analysis shall not be changed in their acidity for preservation purposes. The pH has different effects on the stability of Cr(III) and Cr(VI). c) Light: Light may cause instability of organometallic compounds by photodegrading. When analysing organometallic compounds storage shall be done in the dark or in opaque containers. d) Storage time: Generally, storage should be kept as short as possible. Minimum frequency of sampling and analysis for water intended for human consumption is laid down in Council Directive 98/83/EC. For water, sampling, preservation and handling are described in different parts of EN ISO 5667 standard (EN ISO 5667-1:2007; EN ISO 5667-3:2012; EN ISO 5667- 5:2006). For total chromium analysis, water samples are collected in acid cleaned polyethylene (PE), polypropylene (PP), perfluoroethylene/propylene (FEP), polytetrafluoroethylene (PTFE), polyethylene high density (PE-HD) perfluoroalkoxy polymer (PFA) containers and acidified to pH 1 to pH 2 with HNO 3 before storage. Samples remain stable for a maximum of 6 months (EN ISO 5667-3:2012). Water samples for Cr(VI) analysis are collected in acid cleaned plastics or borosilicate glass containers and analysed preferably within 24 hours to a maximum of 4 days (EN ISO 5667-3:2012). 13 Commission Regulation (EC) No 333/2007 of 28 March 2007 laying down the methods of sampling and analysis for the official control of the levels of lead, cadmium, mercury, inorganic tin, 3-MCPD and benzo(a)pyrene in foodstuffs OJ L 88, 29.3.2007, p. 29-38. 14 Commission Regulation (EU) No 836/2011 of 19 August 2011 amending Regulation (EC) No 333/2007 laying down the methods of sampling and analysis for the official control of the levels of lead, cadmium, mercury, inorganic tin, 3-MCPD and benzo(a)pyrene in foodstuffs. OJ L 215, 20.8.2011, p. 9-16. EFSA Journal 2014;12(3):3595 25
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