By David Acheson
Many in the food safety world are heavily focused on microbial contamination. Such focus is not only necessary, but is critical to both public health and brand protection. Microbial contamination can be of rapid onset and deadly, and thus readily connectable to a specific food. In contrast, chemical contamination is much more the stealth hazard. Long-term exposure concerns are the norm with chemicals, as they rarely have an acute clinical picture (with some exceptions like nitrite poisoning or high-level arsenic exposures). But recent history has demonstrated not only increased regulatory focus on chemicals and heavy metals, but increasing concern and thus reaction from the consumer.
Recently the issue of chemical testing has taken on increased regulation, as detailed in a FSIS July 6 Federal Register announcement on New Analytic Methods and Sampling Procedures for the United States National Residue Program (NRP).
The NRP gives the regulators more “bang for the buck” with greater capacity to test more with the same resources, and it includes testing for chemical compounds, including approved (legal) and unapproved (illegal) veterinary drugs, pesticides, hormones, and environmental contaminants in meat, poultry, and egg products. According to the announcement, the “new, modern, high-efficiency methods … will conserve resources and provide useful and reliable results while enabling the Agency to analyze each sample for more chemical compounds than previously possible.” When FSIS finds a positive sample the data are sent to FDA for that Agency to take action – and in 2011, 7.2% of FDA Warning Letters were issued for Illegal Drug Residue, and indications would suggest this oversight and action will only increase.
FSIS is not the only Agency—of the U.S. or worldwide—taking a closer look at chemical residues. The United Nations’ food standards body, Codex Alimentarius Commission, also passed a new ruling just last week declaring the maximum amount of melamine allowed in powdered infant formula to be 1 mg/kg and the amount of the chemical allowed in other foods and animal feed to be 2.5 mg/kg.
Additionally, the implementation of
FSMA section 103, Hazard analysis and risk-based preventive controls, will make prevention and control of chemicals a mandatory requirement. As stated in the regulation, “The owner, operator, or agent in charge of a facility shall (1) identify and evaluate known or reasonably foreseeable hazards that may be associated with the facility, including (A) biological, chemical, physical, and radiological hazards, natural toxins, pesticides, drug residues, decomposition, parasites, allergens, and unapproved food and color additives; and (B) hazards that occur naturally, or may be unintentionally introduced …”
And for those importing or exporting globally (and these days, very few aren’t), there is the additional challenge of global harmonization of food standards. Take, for example, the use of ractopamine, a “fattening agent” for pigs and cattle. Although Codex was voting to establish a tolerance, which could reduce some of the barriers U.S.and Canadian pork exporters face, the European Union is opposing the decision, arguing that it should not be used at all because of potential health risks to humans.
As stated by a colleague in Canada, and a comment to which I wholeheartedly agree, “This harmonization issue will be a tough wicket to crack on many fronts and the EU’s position on ractopamine reminds me of a very common saying up here in Quebec….plus ca change, plus c’est la meme chose….which roughly translates as the more things change the more they stay the same….”
But it’s not just regulation—domestic or global—that is forcing the issue, rather consumer opinion and media attention is just as focused. And with events such as the Dr. Oz apple-arsenic scare of 2011, fruits are faring no better. Despite FDA’s assurance that monitoring has found that total arsenic levels in apple juice are typically low, and that it considers the consumption of apple juice to be safe, consumer advocates have continued to raise concerns. As a result, FDA began a peer review of scientific information and assessments focused on an assessment of cancer risk associated with exposure to inorganic arsenic from apple juice consumption.
What does all this mean to you?
Primarily that it is imperative that all food manufacturers take the regulatory and consumer focus on chemical residues to heart and ensure that your prevention and detection procedures are as thorough and in-depth for chemicals as they are for microorganisms. Often this means paying close attention to your supply chain for any drugs, pesticides and heavy metal risks that may be lurking with the ingredients you are using.
Test and hold
In this, as in many testing areas, the industry sits on a double-edge sword. Ever-advancing technology is finding better and better ways to drive limits of detection to lower and lower levels, but this ability is not always accompanied by an understanding of whether or not those increasingly minute levels actually have any impact on the safety of the food or health of those who consume it. But consumers don’t differentiate – if you can detect “it” and “it” is associated with harmful effects even at much higher doses, then it must be bad. The FSIS announcement is indicative of these and other such technological advances, enabling regulators (and Dr. Oz’s) to not only detect to a minute level, but to detect a multitude of contaminants in a single sample.
Thus, the more that we, as an industry, can do to apply and communicate science-based practices and information, the more we can parry the thrusts of consumer emotion. At the same time, it is critical that you, yourself, understand and ensure that there is a scientific basis to your practices, and require that of your suppliers as well.
It is an education that may be end up being of benefit only to yourself and your understanding of your product. But if, on the other hand, an environmental group begins checking on your product—whether it be for arsenic in chicken, aflatoxins in figs, or acrylamide in corn chips—you will be glad you are not having to suddenly scramble for facts.
The more things change …