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Lois Haighton Intertek
Hello everyone,
My name is Lois Haighton and I am a senior director with the Intertek Assuris Food & Nutrition Group.
As June 7, 2023 is World Food Safety Day, Intertek Assuris has prepared 2 podcasts to discuss food quality and safety. The first podcast is on the topic of the importance of food standards in ensuring food safety. This podcast is presented by Dr. Kathy Musa-Veloso who discusses the historical adulteration of foods, leading to the need for food standards and the current efforts to modernize them.
In this podcast, we will discuss what counts as "food grade" with respect to safety and quality, and the role of toxicology and risk assessment in making those determinations. The law requires food manufacturers to produce food and food ingredients in accordance with good manufacturing practices, using quality raw ingredients, and under sanitary conditions to limit microbial growth and ensure safety and quality of the product. However, in spite of these best practices, food may still be impacted by a variety of contaminants. These include environmental contaminants such as lead, mercury, or PCBs, residual solvent impurities, Maillard reaction contaminants from food processing or cooking, and mycotoxins and pesticide residues from raw commodities. While it is impossible to completely remove these types of impurities from the diet, food safety efforts seek to minimize their impacts.
I am joined today by Spencer West, risk assessment manager with our consumer assurance team. He is going to provide some background information on the history of government efforts to regulate food quality and safety.
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Spencer West Intertek
Welcome everyone, my name is Spencer West and I am a manager within the Intertek Food & Nutrition Group. Thank you for joining us today.
In discussing safe food, it is interesting that food regulations don't explicitly define what "safe" means. Instead, they establish specific prohibitions on foods that are deemed unfit for sale, along with exemptions from those prohibitions. This may seem a bit perplexing. To shed light on this, let's take a brief journey through the history of food regulation.
Let’s first zoom in on food regulation in the United States. The story of modern-day federal food regulation begins at the turn of the 20th century when, in 1906, shocking revelations of unsafe and unsanitary practices in the meat industry sparked widespread public outcry and spurred Congress into action. The Pure Food and Drug Act was enacted in response. Although this act didn't explicitly define “food” itself, it aimed to prevent the inclusion of adulterated or hazardous ingredients in food products, and it remained in force for several decades, garnering support from various activist groups.
By the 1930s however, despite strong advocacy to further strengthen the existing food safety laws, it took a tragedy for any new regulation to be implemented. In 1937, an estimated over 100 individuals were poisoned by a supposed elixir containing sulfanilamide meant to treat infections. This event triggered congress to pass the Federal Food, Drug, and Cosmetic Act in 1938. This Act, although with many subsequent additions and amendments, has been the central food regulation in the U.S. ever since.
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Lois Haighton Intertek
Today, in recognition of the unavoidable contaminants in foods, the U.S. enacted regulations to address such residues. The regulations can be found in Title 21 of the Code of Federal Regulations (CFR), which includes part 109 “unavoidable contaminants in food for human consumption and food-packaging material”. A naturally occurring poisonous or deleterious substance is defined as a poisonous or deleterious substance that is an inherent natural constituent of a food rather than the result of environmental, agricultural, industrial, or other contamination.
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Spencer West Intertek
A good example of a naturally occurring contaminant in food is arsenic. As most people are aware, arsenic is highly toxic to humans, with well-documented acute and chronic effects. While human activities and industries have increased the presence of arsenic in our environment, it is, nevertheless, a component naturally found in the Earth's crust. Unfortunately, many of the soils we rely on for food production do contain low levels of arsenic, which can be absorbed by various plants. Rice, for instance, absorbs more arsenic from the environment than most other crops.
To address this issue, regulatory bodies like the U.S. Food and Drug Administration and other organizations have established guidelines and regulations to limit arsenic exposure. These measures include stringent manufacturing guidelines and exposure limits. The FDA regularly conducts surveys to monitor levels of arsenic and other metals in food, particularly for vulnerable populations, and conducts exposure assessments to evaluate potential toxicological risks.
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Lois Haighton Intertek
Fortunately, while there are unavoidable environmental contaminants, regulators have control over intentionally added ingredients. In the U.S., the Federal Food, Drug, and Cosmetic Act was amended in 1958 to stipulate that if a substance was determined to be carcinogenic in any species of animal or humans, then it cannot be used as a food additive. This amendment is known as “the Delaney Clause.” However, this zero-risk policy has proved problematic as analytical capabilities have improved over time and a greater number of substances have been identified as potentially carcinogenic, including natural constituents of plant extracts. As such, regulators require data from rigorous testing programs to ensure ingredients proposed as food additives or color additives aren’t carcinogenic.
Another means of addressing risk that was proposed was to adopt a de minimis risk level, typically 1 in 100,000 or 1-in-1 million as a threshold below which an ingredient could be present. In addition, pesticides are regulated differently from food additives. The U.S Environmental Protection Agency established pesticide tolerances in foods are discussed in Title 40 of the Code of Federal Regulations. In setting these maximum residue limits, which is the greatest concentration of a pesticide that can remain in food or feed, all agricultural commodities for which the pesticide is used must be considered in estimating exposures, and the residues must be at very low concentrations.
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Spencer West Intertek
Interestingly, cooking food itself can also be a source of contamination. Cooking has been a fundamental practice since the discovery of fire, unlocking flavors and nutrients while rendering food safe to eat. However, it’s lesser known that cooking can introduce contaminants. High-temperature cooking, especially of starchy foods, can catalyze chemical reactions that generate contaminants such as acrylamide. Acrylamide is a potential neurotoxin and carcinogen.
Despite the potential concerns, it is important to note that the health risk associated with consuming uncooked or undercooked food is significantly higher than that of consuming acrylamide in cooked food. Furthermore, detected levels in food are much lower than levels used in experimental studies. Nevertheless, the presence of acrylamide remains a concern. In the European Union, regulations have been implemented to mandate manufacturers to minimize acrylamide levels in food products. We’ve seen advancements in acrylamide reduction in the production of foods like French fries: lowering the oil temperature during cooking has been shown to decrease acrylamide by significant amounts.
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Lois Haighton Intertek
In Europe, experts have established a comparison method called the margin of exposure, or the MOE approach, whereby the exposure to a contaminant from food consumption should be at least 10,000-fold lower than the dose that would cause a 10% increased risk of a tumor response. This dose level is established using benchmark dose modeling. Publications that demonstrate the MOE approach are available for many common food contaminants, including acrylamide and aflatoxin.
Suffice to say, the safety and quality of food is a paramount concern to the public and thus to regulatory bodies, and in that regard, improvements in manufacturing processes are always possible. Certain substances that had been harmful to health were previously allowed for use in food manufacturing, if subsequently removed from the final product. However, there is now a greater focus on residuals in foods. This includes the use of certain solvents.
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Spencer West Intertek
Decaffeinated coffee is an interesting example of that. In the past, benzene—a highly toxic compound— was used to decaffeinate coffee. Recognizing the harm of even trace amounts of benzene in food, it was banned and replaced with methylene chloride. Although methylene chloride also has adverse properties, trace amounts pose a much smaller risk than benzene. Today, methylene chloride is still permitted but strictly regulated. In the U.S., methylene chloride can be used for coffee decaffeination, but no more than 10 parts per million is allowed in final products.
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Lois Haighton Intertek
While the specifics vary, the key to ensuring safe consumption of any food involves conducting detailed dietary assessments and establishing acceptable daily intakes from toxicology studies. Studies allow us to establish maximum residue limits for pesticides residues and specifications for solvents in ingredients, and to ultimately ensure contaminants are present at concentrations well below those that pose harm. It is important to recognize, too, that efforts to improve food safety are always evolving: limits are not static and may change in response to new information. To give just one example: many years ago, the heavy metals specification including lead was 10 ppm, and today lead must now be controlled at much lower concentrations. Moreover, there will always be emergent knowledge of “new” contaminants to address. The best contemporary example of this is perfluoroalkyl and polyfluoroalkyl substances, aka PFAS. A few years ago, these substances were discovered to be prevalent in ground water. Fortunately, a risk assessment and regulatory framework now exists to address this new class of contaminants. It is important to remember: the dose makes the poison.
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Spencer West Intertek
And with that, we’ll end this podcast. We hope you have found it interesting. Thank you to all listeners for tuning in!
