INK SAFETY PORTAL

Bioassays for the DNA Reactivity Assessment
of NIAS in Food Contact Materials

Ames Microplate Format (MPF) assay, a high-throughput version of the traditional Ames test was introduced for the mutagenicity assessment of the FCM extracts with low concentrations of NIAS. This is a miniaturized version of the plate agar Ames tests that takes advantage of a liquid microplate approach in 384-well plates with a color change-based readout. Ames MPF assay uses the same principle and tester strains (e.g., Salmonella typhimurium and Escherichia coli) as the standard Ames test but in a microplate format.

Introduction & Toxicological Assessment of NIAS

Food Contact Materials (FCMs) including printing inks are formulated with numerous chemicals that have the potential to migrate into food products which can result in human exposure. Read our ePaper and learn more about the details.

Introduction & Toxicological Assessment
of FCMs & NIAS

Introduction

Food Contact Materials (FCMs) including printing inks are formulated with numerous chemicals that have the potential to migrate into food products which can result in human exposure. According to the Article 3 of the EU Framework Regulation (EC) No 1935/2004, materials and articles in contact with food should not transfer components into the food in quantities that could endanger the human health. Migrating substances from FCMs may include intentionally added substances (IAS) and non-intentionally added substances (NIAS). The IAS refers to known substances used in the manufacturing of printing inks to achieve specific properties, while NIAS are chemical compounds that are not intentionally included in the ink formulation but are unavoidable substances as a result of raw material impurities, oligomers, reaction intermediates, contaminants, by products or degradation products.

Toxicological Assessment of NIAS

According to the FCM regulatory guidelines, the data requirements for the toxicological assessments of IAS and NIAS are based on the migration of the substance into the food (EFSA 2020; FCA, 2023). Specific toxicity data for IAS will be generated as per "EFSA Note for Guidance" (EFSA, 2020), while for NIAS, exclusion of DNA reactivity is the preliminary requirement for the application of Threshold of Toxicological Concern (TTC) Cramer Class III limit, corresponding to self-derived SML of 90 ppb (EuPIA, 2021). Some NIAS can be structurally identified and toxicologically evaluated, however, in many instances it might be challenging to ascertain the safety of the NIAS, simply due to the lack of valid analytical methods for their identification and quantification. Further, the availability of sufficient quantity of the test material for toxicological assessments could be problematic. Standard genotoxicity assays require significant quantity of the test material, consequently, these assays are not suitable for the genotoxicity assessment of NIAS with insufficient  quantity.

The identification and quantification of all NIAS together with their toxicological investigation is desirable but not always possible. A pragmatic approach aimed to address the safety of NIAS was recommended by FCM regulatory authorities (EFSA 2018). However, there exists diverging scientific opinions on the battery of assays to be considered for the adequate evaluation of the genotoxic potential of NIAS in FCMs. While some regulatory bodies mandates the evaluation of different end-points, i.e. induction of gene mutations (mutagenicity), structural (clastogens) and numerical (aneugens) chromosomal alterations, many experts believe that a well-conducted bacterial gene mutation (Ames) test would be sufficient to study the genotoxicity in terms of DNA reactivity which can lead to mutations, potentially being the first step in carcinogenesis.

 

Ames test, Microplate Format (MPF) Assay & Use in recycling projects

The Ames test is recognized as the most relevant and frequently used in vitro assay for the detection of DNA reactivity, i.e., mutagenicity potential of chemical substances.

Ames test (OECD 471), Ames MPF Assay
& Use in recycling projects

Ames test (OECD 471)

The Ames test is recognized as the most relevant and frequently used in vitro assay for the detection of DNA reactivity, i.e., mutagenicity potential of chemical substances. It has a well-established method recommended in the OECD 471 guideline and is used for the safety assessment of chemicals in food contact materials (FCM) (EFSA 2016) and industrial chemicals (OECD 2016). The Ames test is known for its high sensitivity in detecting mutagens, with reported sensitivity values ranging from 93% to 97% when compared to rodent carcinogenicity assays. However, its specificity is generally lower, typically ranging from 55% to 86%, meaning it can produce some false positive results (Trejo-Martin et al., 2022). FCM extracts have been assessed using the Ames test but in general, the data obtained indicated evidence of the absence of mutagenicity/genotoxicity potential (Séverin et al. 2016). Very little literature is available on the capability of this test to detect low levels of mutagenic impurities in complex mixtures such as FCM migrates and the Limit of Detection (LOD) of this test is inadequate. It was observed that only very potent mutagens could potentially be detected by the standard AMES test at levels relevant for safety and regulatory purposes, i.e., TTC value of 0.15 ppb (Rainer et al., 2018). This highlighted the intrinsic limitations of the standard Ames test regarding the detection of mutagens at low concentrations in complex mixtures.

 

Ames Microplate Format (MPF) Assay

Ames Microplate Format (MPF) assay, a high-throughput version of the traditional Ames test was introduced for the mutagenicity assessment of the FCM extracts with low concentrations of NIAS. This is a miniaturized version of the plate agar Ames tests that takes advantage of a liquid microplate approach in 384-well plates with a color change-based readout. Ames MPF assay uses the same principle and tester strains (e.g., Salmonella typhimurium and Escherichia coli) as the standard Ames test but in a microplate format. Ames MPF assay enables simultaneous processing of multiple replicates and performs equally well as the standard Ames test. It requires smaller sample volumes, is fast, relatively simple and cost-effective and therefore can be a useful tool for screening of FCM migrates (Rainer B et al., 2019).

While some miniaturized testing versions are referred in the OECD 471 guideline, this guideline does not formally consider the miniaturized format sufficient and the regulatory acceptance of such approaches is still limited (OECD 2022; Spiliotopoulos and Koelbert, 2020). Consequently,  Ames MPF assay is not considered suitable for testing the pure substances, nevertheless can be used for the primary screening in early stages of product development, or to assess the impurities with limited quantity. The ICH guideline for evaluating the mutagenic potential of impurities in pharmaceuticals (ICH, 2023) identifies Ames MPF as a suitable alternative during the limited available quantity of the impurity. In the Detailed Review Paper (DRP) published by the OECD in 2022, a good agreement between the Ames MPF assay and standard assay was reported and when only a limited amount of testing material is available including NIAS migrating from FCMs, Ames MPF assay is then certainly acceptable and permitted (OECD 2022).

A particular challenge while conducting the Ames MPF assay is the extraction and concentration of the DNA-reactive genotoxic substances that are potentially present in the FCM extracts. It is important to ensure that the limit of detection of the Ames MPF assay is not compromised, leading to false negative results. In order to obtain higher substance concentrations for easier detection by the Ames MPF assay, suitable evaporation and concentration methods needs to be standardized depending on the physicochemical properties of the envisaged NIAS of the FCM extracts under investigation (Mayrhofer E et al., 2023). Hence, it is quite essential to standardize a suitable extraction method in advance prior to the initiation of the Ames MPF assay in order to obtain required limit of detection of the assay and reproducible study findings.

The positive and negative results obtained with the Ames MPF method should be interpreted in compliance with EFSA statement on genotoxicity assessment of chemical mixtures (EFSA, 2018). If the testing of the FCM extract provides a clear negative result, the mixture does not raise concern for DNA reactivity. If Ames MPF method provides positive result, it can be concluded that the FCM extract does raise a concern about DNA reactivity. Nevertheless, further analytical characterization of the FCM extract could elucidate the specific NIAS with DNA reactivity, which will enable the ink manufacturers to implement the specific technical measures to mitigate its formation/migration.

It should be noted that Ames MPF assay is considered as powerful tool to study genotoxic hazard assessment of FCM extracts and not the final indicator of potential risk to the consumer. Even in case of positive findings in the Ames MPF assay, the potential health concern due to genotoxic substances could still be mitigated as long as its migration is maintained with the applicable limit of 0.15 ppb for genotoxic compounds.

Use of the Ames MPF assay in recycling projects

Scientific projects like “PolyCycle” and “SafeCycle” were conducted by Fraunhofer Institute, Germany and Industry Association for Food Technology and Packaging, Germany for the comprehensive analysis of recyclates and their applicability for different packaging scenarios. The objectives of these projects are to develop and validate the testing strategy for carcinogens in recycled plastics and to clarify the origin of any systemic contamination. In these projects, it was found that the performance of the Ames MPF assay is in agreement with the standard agar based Ames assay while identifying the genotoxic components in post-consumer recycled (PCR) plastics/simulated PCRs.

Similar high-throughput, cost effective assays are under development to detect structural (clastogens) and numerical (aneugens) chromosomal damage of the FCM extracts with low concentrations of NIAS.

 

Siegwerk Position

In Siegwerk, Ames MPF assay is used as an effective screening tool to assess the genotoxic potential of NIAS with unknown structure in the FCM extracts and limited sample volume.

Siegwerk Position
Ames MPF assay as an effective screening tool

In Siegwerk, Ames MPF assay is used as an effective screening tool to assess the genotoxic potential of NIAS with unknown structure in the FCM extracts and limited sample volume.

If the Ames MPF assay provides clearly negative result, respective FCM extract is considered as of no concern with respect to genotoxicity. All the individual NIAS will be considered as Cramer Class III substances with the corresponding self-derived Specific Migration Limit (SML) up to  90 ppb as per TTC approach.

If the Ames MPF assay provides clear positive result, it can be concluded that the FCM extract does raise a concern about genotoxicity, and the proposed TTC of 0.15 ppb for genotoxic compounds theoretically could be allocated as the self-derived SML for individual NIAS. However, in many instances it is challenging to develop suitable analytical methods with the LOD up to 0.15 ppb for the genotoxic substances, hence ALARA (As Low As Reasonably Achievable) principle is applied in the analysis of FCM extracts to minimize potential health risks from substances transferring from packaging into food. The “10 ppb threshold” will be utilized as LOD for the validated analytical determination of migrants in food or food simulant.  However, when the analytical methods enable a determination below 10 ppb, this will be considered to be the applicable detection limit.

In summary, Ames MPF assay is fast, relatively simple and cost-effective and therefore can be a useful screening tool to assess the genotoxicity potential of NIAS with unknown structure in the FCM extracts. Though Ames MPF assay is not explicitly included in the current OECD test guideline 471, it is a suitable approach for screening samples for low concentrations of potential genotoxic substances. This assay is of importance, especially when assessing complex mixtures, such as FCM extracts with low-level contaminations.

 

References & Literature

 

1. EFSA
1.1 European Food Safety Authority. 2016. Recent developments in the risk assessment of chemicals in food and their potential impact on the safety assessment of substances used in food contact materials. EFSA J. 2016;14(1):4357
1.2 European Food Safety Authority. 2018. Genotoxicity assessment of chemical mixtures. DOI: 10.2903/j.efsa.2019.5519
1.3 European Food Safety Authority. 2019. Guidance on the use of the Threshold of Toxicological Concern approach in food safety assessment. DOI: doi.org/10.2903/j.efsa.2019.5708
1.4 European Food Safety Authority. 2020. Note for guidance for the preparation of an application for the safety assessment of a substance to be used in plastic food contact materials. DOI: 10.2903/j.efsa.2008.21r
1.5 European Food Safety Authority. 2024. Scientific Guidance on the criteria for the evaluation and on the preparation of applications for the safety assessment of post-consumer mechanical PET recycling processes intended to be used for manufacture of materials and articles in contact with food. DOI: doi.org/10.2903/j.efsa.2024.8879

2. EuPIA
The European Printing Ink Association. 2021. EuPIA Guidance for Risk Assessment of Non-Intentionally Added Substances (NIAS) and Non-Evaluated or Non-Listed Substances (NLS) in printing inks for food contact materials. Accessed from: www.eupia.org/wp-content/uploads/2022/09/2021-05-11-EuPIA_NIAS_Guidance.pdf

3. CEFIC FCA
Food Contact Additives. 2025. Risk Assessment of non-listed substances (NLS) and non-intentionally added substances (NIAS) under the requirements of Article 3 of the Framework Regulation (EC) 1935/2004. Accessed from: https://fca.cefic.org/wp-content/uploads/2021/02/FCA-RA-Guidelines-v.5-3.pdf

4. OECD
4.1 Organisation for Economic Co-operation and Development. 2016 Jul 29. Guideline for the testing of chemicals: in vitro mammalian chromosomal aberration test. Vol. 473. OECD.
4.2 Organisation for Economic Co-operation and Development. 2022. Series on Testing and Assessment No.358. Detailed Review Paper on the miniaturised versions of the bacterial reverse gene mutation test. Accessed from: web-archive.oecd.org/2024-05-17/60619-series-testing-assessment-publications-number.htm

5. Others
5.1 Rainer B et al (2018). Suitability of the Ames test to characterise genotoxicity of food contact material migrate. Food Addit Contam Part A. doi:10.1080/19440049.2018.1519259
5.2 Rainer B et al (2019): Mutagenicity assessment of food contact material migrates with the Ames MPF assay. Food Additives & Contaminants: Part A, DOI: 10.1080/19440049.2019.1634841
5.3 ICH 2023. M7(R2) Guideline on assessment and control of DNA reactive (mutagenic) impurities in pharmaceuticals to limit potential carcinogenic risk. Accessed from: www.ema.europa.eu/en/documents/scientific-guideline/ich-m7r2-guideline-assessment-and-control-dna-reactive-mutagenic-impurities-pharmaceuticals-limit-potential-carcinogenic-risk-step-5_en.pdf
5.4 Mayrhofer E et al (2023). Safety assessment of recycled plastics from post-consumer waste with a combination of a miniaturized Ames test and chromatographic analysis. Recycling, 8:87. doi.org/10.3390/recycling8060087
5.5 Séverin I et al (2016). In vitro toxicity assessment of extracts derived from sol-gel coatings on polycarbonate intended to be used in food contact applications. Food Chem Toxicol. 93:51–57. doi:10.1016/j.fct.2016.04.025
5.6 Spiliotopoulos D and Koelbert C (2020). Assessment of the miniaturized liquid Ames microplate format (MPF™) for a selection of the test items from the recommended list of genotoxic and nongenotoxic chemicals. Mutat Res Gen Tox En 856-857. https://doi.org/10.1016/j.mrgentox.2020.503218
5.7 Trejo-Martin et al (2022). Use of the bacterial reverse mutation assay to predict carcinogenicity of N-nitrosamines. Regulatory Toxicology and Pharmacology. 135:105247. doi.org/10.1016/j.yrtph.2022.105247