Recently, federal authorities banned the sale of meat from hogs and then chickens fed melamine-contaminated gluten in food and feed. The contaminated gluten, shipped from China, is the suspected culprit in the deaths of thousands of cats and dog, but no one really is certain.
Chickens, as you may know, produce another popular food product: eggs. Studies have shown that many chemicals are passed from chicken to egg. Knowing this, officials from FSIS and FDA (which jointly regulate eggs) had a responsibility to tell the public something regarding the risk from eggs produced by contamiinated chickens. Here are the things they could have said.
1. "We've tested the eggs and have found contamination." No, didn't say that.
2. "We've tested the eggs and find no evidence of contamination." Didn't say that, either.
3. "We don't know yet if the eggs are contaminated, but we've begun implementing procedures to find out." Again, no.
4. "(silence)." Bingo.
The official response was to publicly ignore the issue. But, did US officials have a different story for EU officials?
Authorities admit contamination of chickens
On May 4, the USDA reported that millions of chickens are being withheld from slaughter voluntarily while it investigates whether the birds are "safe" to eat.
May 4 (Bloomberg) -- The U.S. Department of Agriculture said it is keeping as many as 20 million chickens from slaughter this weekend as officials investigate whether the birds were given tainted feed.
The chickens are in several states on farms contracted to ``large commercial operators,'' USDA spokesman Keith Williams said today in a phone interview. The chickens are being voluntarily held until at least May 7 while the USDA, the Food and Drug Administration and the Environmental Protection Agency decide whether they are safe for eating.
The chickens received feed believed to be tainted with melamine, an industrial chemical that has been found in wheat gluten imported from China, Williams said. The contaminated feed has been connected to the deaths of at least 14 pets and caused the quarantine of hog farms in six U.S. states this year.
Official advice: don't worry
In advance of the tests, FDA has been assuring consumers that the reported contamination poses little threat to humans.
"The combination of melamine and cyanuric acid is of concern to human and animal health," said Captain David Elder, director of the FDA's Office of Enforcement Office of Regulatory Affairs. "Melamine, at detected levels, is not a human health concern.”
Canada's CBC quotes university professors who support the U.S. government's assertions that little of the melamine/cyanuric acid would be passed on through meat to consumers.
"Remember, dogs and cats are primarily eating just one product, so they were eating ["]1/8 melamine 3/8["] at high concentrations every day," noted Dr. Stephen Hooser, assistant director at Purdue University's Animal Disease Diagnostic Laboratory. Hooser also suspects that Chinese workers who added the melamine to wheat gluten and rice proteins may have added much more to some lots than to others. "So, there might have been some spots where there was a lot of it, and that got passed on to certain pets," Hooser said. Humans, on the other hand, didn't eat the pet food directly. Instead, it was fed to hogs or chickens who naturally excrete much of the melamine away. In fact, very little of the compound could be expected to settle in the animals' muscle tissue - the prime source of meat eaten in the United States. And, unlike pets eating a single food, consumers "are not exclusively eating chicken or pork," Hooser said. - Different physiologies. "There are lots of differences between species on how they respond to chemicals," Hooser noted.
Why we might want to worry, anyway
But, that assumes that melamine only contaminated meat animals like hogs and chickens and that the current theory is correct, that the deaths resulted from the presence of melamine or melamiine in combination with cyanuric acid. But, suppose, the theory is wrong. Or, suppose the contamination is more widely spread. That would greatly change the risk to humans. It's even possible for both of these conditions to exist.
Why would the USDA fail to even address the issue of egg contamination, when it knows that other contaminants have shown up in eggs? For example, in 1999, the FDA put a hold on egg imports after reports of chickens fed contaminated feed.
The Food and Drug Administration announced today that all imports of eggs, products containing eggs, and game meats (FDA regulated) from Belgium, France and the Netherlands, and all animal products including animal derived medicated and non- medicated feeds, feed ingredients, and pet foods from all European countries will be detained at U.S. ports of entry.
These products are being detained because of the possibility that they may be contaminated with polychlorinated byphenyls (PCBs) and dioxins. Dioxins and PCBs are groups of compounds that may be potential carcinogens at low levels of exposure over extended periods of time and may have other types of toxicological effects. FDA is detaining these products as a precautionary step.
FDA is taking this action in response to recent reports that a fat product from a rendering company in Europe was contaminated with PCBs and dioxins in January 1999. This fat was subsequently sold to European animal feed manufacturers. Most of these feed manufacturers are in Belgium although some of the contaminated feed has reportedly been shipped to feed manufacturers in France and the Netherlands. Food producing animals may have consumed the feed resulting in potentially contaminated food products, for example, eggs. Since some animals that ate the contaminated feed may have been rendered and the renderings added to feed shipped to other European countries, FDA is also detaining all animal-derived feed and feed ingredients as well as pet food from all European countries. [emphasis added]
If, instead, a product suspected of contamination turns out, through testing, to have no contamination or little risk, government officials normally are quick to confirm that to consumers. In this case, they have not, and the silence is unsettling.
Implications of egg contamination
Consider that China has been shipping gluten to the U.S. since at least August 2006. Consider also that the U.S. produces more than 70 billion table eggs a year (2005 figure). Consider that annual per capita (table) egg consumption, at it's lowest, was 233.9 eggs (1999). Consider that U.S. sold $76.4 million of eggs to foreign countries in 2006. Consider that eggs are incorporated into a wide variety of food products, among them mayonnaise, cakes and ice cream.
Who inspects egg products for contamination? Here is the answer from FSIS:
In 1995, the Food Safety and Inspection Service (FSIS) became responsible for the inspection of egg products. FSIS inspects all egg products, with the exception of those products exempted under the Act, that are used by food manufacturers, foodservice, institutions, and retail markets. Officially inspected egg products will bear the USDA inspection mark. In 2004, FSIS inspected 3.2 billion pounds of egg products.
That includes some significant exceptions, including "institutions," which are regulated locally.
U.S. food safety officials have been exposing contamination of the food supply in agonizingly slow steps, as though hoping to desensitise us through repeated recalls to the full import of gluten contamination. That could explain the failure to mention eggs even as authorities investigate chickens. And, what of other food products? It's important to note that U.S. authorities do not know the identities of the original suppliers of the contaminated gluten.
The melamine-tainted vegetable proteins came from two Chinese firms -- Xuzhou Anying Biologic Technology Development Co. Ltd. and Binzhou Futian Biology Technology Co. Ltd. “There is strong evidence, however, that these firms are not the actual manufacturers (of these ingredients),” the FDA says in its report. “Moreover, despite many weeks of investigation, it is still unknown who the actual manufacturer or manufacturers of the contaminated products imported from China are.”
In theory, the original suppliers could have shipped contaminated gluten to other countries for use in products that they then exported to the U.S. Thus, looking closely at Chinese products offers no assurance of protection from bad gluten. Supposedly, the Chinese government has held up investigation, but, given US reluctance to be upfront about risks, one has reason to wonder if that's the only obstacle to finding the truth.
If, indeed, gluten has entered U.s. food supply directly, we have an even bigger problem. Gluten, it seems, is everywhere. People I know with gluten intolerance have great difficulty finding gluten-free foods at restaurants and stores (although this appears to be changing fast.)
Calculating the risks
Let's now do something that FDA and FSIS are unwilling to do. Let's look at the worst case scenario, including all potential sources of contamination, not just the pieces they have revealed one by one, like some television game show.
The contaminated gluten is widespread in pet food, which also was fed to hogs. The gluten also was fed to chickens (and turkeys per the most recent update) and probably other food animals as well. Very likely, the contamination is in eggs, although authorites are still mum about that, and therefore could be in a broad spectrum of food products. At the far end of the certainty scale is the possibility - a fairly good one - that contaminated gluten has entered our food supply in some of the many food products that incorporate gluten. The total exposure to contaminated gluten could be considerable and well may exceed safe levels for humans, which - notably - our government has not even determined yet.
When U.S. officials finally do identify all of the sources of contamination, how would they assess the risk to human health? Normally, they do that by using the "market basket" approach, used to calcuate exposures to pesticides. I began criticizing the market basket method back in the middle 1990's, but it's still being used - and criticized
The market basket approach has been criticized for omitting the concerns of consumers who eat a lot of a particular food that does not make up a sizable proportion of the market basket. People who consume certain foods in significantly greater amounts than the general public may be assuming a greater risk.
That's not the only problem with the approach. Ethnic groups and those on special diets for medical reasons or weight loss clearly would be affected. But, those who consume the majority of their food from local sources also are affected (ironically) because the market basket
generalizes contamination across several markets and only a dozen at that.
FDA collects samples of domestic and imported foods and analyzes them for pesticide residues. This survey, performed about four times each year, is known as the Total Diet Study or the Market Basket Study. FDA personnel go to 12 cities across the United States, including Puerto Rico, and fill shopping carts with more than 200 different foods, as if they were shopping for a family. The items include a variety of meats, vegetables, soft drinks, snacks, baby food, and infant formula. Each market basket can cost up to $1,200. The items can come from roadside stands and small retailers as well as supermarkets.
After each shopping spree, perishable items are packed in ice. All the food is then rushed to an FDA laboratory where it is cooked and prepared as it would be at home. Then, samples of the food are analyzed for pesticide residues using extremely sensitive instruments capable of detecting residues at a level of one part per billion. Although each market basket may contain trace amounts of 70 or 80 pesticides, the levels of these substances are usually so low that they pose no significant health risks.
EU sets new rules for US egg products
In researching links for this story, I was interested to read that US producers of egg products intended for sale to EU countries are now required to have HACCP procedures in place. For those unfamiliar with HACCP, here is FSIS' description.
HACCP principles require processors to identify potential food safety risks and put in place procedures to adequately deal with problems when they occur. HACCP shifts the focus to preventative rather than reactive proceedures.
Prevention sounds good, particularly considering that our food safety agencies have no authority to order recalls and have been reluctant to request recalls of melamine-contaminated pork and chicken. US meat processors have long been required to have HACCP procedures in place.
4/26/2007 - From today, US egg products destined for the EU must come from premises operating with procedures based on international safety standards known as hazard analysis and critical control plan (HACCP) principles.
But, egg products destined for our own people have different requirements, says FSIS.
US processing establishments are not currently required to operate in accordance with HACCP principles but similar domestic regulations achieve the same end, according to the Food Safety Inspection Service (FSIS).
Here is FSIS' own
description of its regulation of shell eggs.
FSIS is responsible for the import of eggs destined for further processing and for assuring that imported shell eggs destined for the retail market are transported under refrigerated conditions.
FSIS verifies shell eggs packed for the consumer are labeled "Keep Refrigerated" and transported under refrigeration and ambient temperature of no greater than 45 °F.
USDA also educates consumers about the safe handling of eggs. FSIS has developed numerous publications on egg safety and uses a variety of networks (such as the USDA Meat and Poultry Hotline, "Ask Karen," and USDA cooperative extension agents) to get this information to consumers.
If any of you find a mention of inspecting for contamination buried in there somewhere, please wire immediately.
What did they know and when did they know it?
Perhaps the most interesting thing about the EU's new requirement for US egg producers is the date of implementation: April 26, 2007. Those with sharp memories will recall that that was the day FDA officials first hinted publicly that chickens may have been fed contaminated feed.
Officials from the Food and Drug Administration and the U.S. Department of Agriculture said about 6,000 pigs may have eaten food contaminated with harmful industrial chemicals.
The food went to eight producers in California, Utah, Kansas, New York, Oklahoma, South Carolina and North Carolina, officials said in a teleconference from Washington, D.C. Tainted pet food also made its way to a chicken farm in Missouri.
Is there something our food safety officials have shared with EU countries that they have not yet shared with us? Surely, not. They'd never do that - would they?