Q. We are interested in applying UV curable coatings for concrete floors and other concrete surfaces, in some cases where there will be food

preparation involved. Are you aware of any designation or clearances that the coating must have before it can be used for these purposes? Do they require an FDA or USDA label or something similar?

A: The floor and walls of a food preparation or storage area normally are not expected to come into contact with food, so they are not required by regulation to be compliant with specific FDA citations in 21 CFR. This is not the case for food storage, handling and processing equipment. For example, a coating on the inside of a concrete food storage bin (grain bin or water tank, for example), on the other hand, must be FDA compliant, because contact is expected.

Food handling and processing equipment, such as food mixers and counter tops, may fall under the FDA “housewares” exemption, but any coating should be demonstrably safe for the intended application.

Under USDA guidelines, a guaranty is not required for coatings which do not meet the definition of packaging materials, even though there may be food contact. Though not covered under the packaging regulations, such materials may be regulated under other sections of the regulations. For example, performance and sanitation requirements for floors, walls, equipment and utensils are covered under Sections 308.5, 381.48 and 381.53 of the Meat and Poultry Inspection regulations.

Irrespective of regulatory compliance, if the customers demand FDA compliance even for floor coatings, that's their prerogative.

The good news is that it now is possible with FCN 772 to formulate an epoxy floor or concrete coating that specifically complies with FDA regulations, and it is foreseen that a limited amount of new test data on a urethane oligomer, for example, could allow an Alliance member to gain clearance for that type of oligomer and coating.