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7 Policy Options to Reduce Exposure to Dioxins and Dioxin-like Compounds INTRODUCTION AND BACKGROUND The central task assigned to the committee was to identify risk-management options to reduce exposure to dioxins and dioxin-like compounds (referred to collectively as DLCs) through the food supply and to recommend ways to mini- mize current exposure levels. The committee was not asked to do risk assess- ment, thus the focus was on evaluating risk relationships and risk-management options. In the course of its deliberations, the committee considered many potential intervention scenarios within the framework outlined in Chapter 6. These inter- ventions can be initiated at a number of points along the animal production, human food, and food-consumption pathways (Figures 7-1 through 7-3~. The generated range of risk-management options took into account current statutory food safety standards and other regulatory policies, procedures, and practices that frame and constrain the adoption of regulatory interventions. The committee also considered risk-management options that involve encouraging voluntary actions that could be taken by food system participants to reduce DLC exposure. As explained in Chapter 6, the committee considered these options within an overall framework of a risk relationship analysis. The committee' s approach was to deliberate and present a broadly represen- tative list of risk-management options and some guides toward the evaluation of the desirability of these options. All of the options presented have the intention of reducing DLC exposure through food, working from the starting point that reduc- tions in exposure are desirable. However, a central conclusion of the committee is that the desirability of particular risk-management options in many instances 174

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POLICY OPTIONS TO REDUCE EXPOSURE TO DIOXINS 1 Harvested Cereals, Forage, Grasses, Others ENVIRONMENT Generation Chemical Processing Combustion I Worldwide Reservoir Sediments Waterways A ~ / \ Vegetables, _ / Cereals ~ ~ lie ~ Terrestrial Animals \ - Animal Feed + : - Fishmeal, Fishoils, Animal Fats nor] Prordil~t. 1 HUMAN FOODS Meat, Fish, Dairy, Eggs, Fruits, Vegetables, Cereals ~ Humans ~ 175 ~ 1 Aquatic Animals / i,:/ x FIGURE 7-1 Pathways leading to exposure to dioxin and dioxin-like compounds through the food supply. Boxes depict point sources in the pathways. Dark arrows refer to path- ways with a greater relative DLC contribution than the pathways with light arrows. cannot be adequately analyzed due to insufficient information. Regulatory agen- cies have invested relatively little toward generating the data required to support risk-management decisions related to options to reduce DLC exposure. For ex- ample, little data are available that would permit more refined estimates of cur- rent DLC levels in feeds, forage, and human foods; the current distribution and

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176 DIOXINS AND DIOXIN-LIKE COMPOUNDS IN THE FOOD SUPPLY ENVIRONMENT Generation Chemical Processing Combustion ~ Worldwide Reservoir / Sediments / Waterways l Soils Harvested Cereals, / \ Forage, Grasses, Others ~~ \ _ ~ ~ Animal 1 Fishoils, 4~ Animals Fishmeal, Fishoils, Animal Fats and Products PATHWAY I Aquatic Animals FIGURE 7-2 Pathway I, animal production systems. Boxes depict point sources in the pathways. Dark arrows refer to pathways with a greater relative DLC contribution than the pathway with a light arrow. levels of human exposure; and the amount of exposure reduction that could be achieved through various interventions. The risk-management options discussed by the committee encompassed a wide range of regulatory and nonregulatory options, which are presented in this chapter. The options are presented in outline form in matrices that correspond to each of the three pathways (see Chapter 6) and are discussed in detail. Not all of the options considered were selected as recommendations for immediate action; specific recommendations and research needs are presented in Chapter 8. The committee analyzed only the likely outcomes or the ultimate desirability of the most significant risk-management options considered. Thus, the matrices contain an array of options greater than those that the committee considered in detail. The listings of current barriers to implementation, expected DLC exposure

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POLICY OPTIONS TO REDUCE EXPOSURE TO DIOXINS I l _ Terrestrial Animal \ HUMAN FOODS Meat, Fish, Dairy, Eggs, Fruits, Vegetables, Cereals Humans Vegetables, Fruits, Cereals Aquatic Animals ,,N~:2 N~ .~ ~ NNN~ 177 - FIGURE 7-3 Pathway II, human foods, and Pathway III, food-consumption patterns. Boxes depict point sources in the pathways. Dark arrows refer to pathways with a greater relative DLC contribution than the pathways with light arrows. reduction, and risk relationships (ancillary benefits and countervailing risks) should be viewed as suggestive not definitive. Additionally, due to gaps in data and high analytical costs, many options are not feasible for immediate implemen- tation, although they may be used in the future. The size and direction of these impacts must be the subject of further analy- sis. For example, a potential countervailing risk of several options could occur through the following chain of events: higher costs of production cause higher prices for some food products (e.g., meat and dairy products), and consumers shift away from the higher-priced foods to the lower-priced foods, which results in less access to important nutrients and a negative impact on nutritional status. The committee's evaluation of the available economic research suggests that this chain of events is unlikely unless price changes were large (i.e., greater than 10 percent) and widespread. Moreover, some of the effects of shifts in diet are likely to provide ancillary health benefits, either through reduction in intake of dietary constituents that are currently consumed in excess, or through increased intake of

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178 DIOXINS AND DIOXIN-LIKE COMPOUNDS IN THE FOOD SUPPLY constituents that are consumed at suboptimal levels. However, inclusion of this possible risk relationship in matrices suggests the need for further evaluation. While the committee did not fully analyze the available risk-management options, it did identify two areas that appear to be the most promising leverage points for affecting DLC exposure from food. One of these is at the animal production stage, where DLCs enter the food supply through forage and feeds and are subsequently recycled back through the system by practices such as the reuse of animal fats (where DLCs accumulate) as ingredients in animal feeds. The second leverage point is in food-consumption patterns, where consumption of foods with higher levels of animal fat, particularly by children, contributes to DLC exposure and life-long DLC body burdens. These two areas are where further analysis of risk-management options should begin. ENVIRONMENTAL CONSIDERATIONS The committee was clearly instructed by the sponsors to address ways to reduce DLCs in the food supply, but not the environment. However, the commit- tee felt it was necessary to take into account the sources of the DLCs that enter feeds and foods. Therefore, the committee addressed reservoir and high-exposure sources of DLCs as contributors to the overall exposure through foods. Dramatic reductions have occurred in the production of DLCs from combus- tion sources in the United States as a result of enforcement of the provisions of the Clean Air Act. For example, DLC emissions from municipal waste incinera- tors fell from 8,877 g TEQDF whop in 1987, to 1,250 g TEQDF whole in 1995, and are projected to fall to 12 g TEQDF whorl in 2002 to 2004 (Winters, 2001~. There have been similar dramatic declines in emissions from medical waste incinerators, smelters, and cement kilns. The largest current source of DLC pro- duction in the United States is now backyard barrel burning (estimated at 628 g TEQDF wHOg~/Y) and other poorly characterized sources such as sewage sludge application, residential wood burning, and coal-fired utilities. Actions should be taken at all possible levels to monitor and reduce emis- sions from these poorly characterized sources. The net effect of restricting the emission of DLCs into the atmosphere is a long-term continual decline in DLC levels in pastureland, soil, and sediment and, thus, reduced entry of these con- taminants into the pathways that lead to human exposure through the food supply. PATHWAY I: ANIMAL PRODUCTION SYSTEMS Effective, long-term reduction of DLC exposure through the human food supply requires interrupting the introduction of DLCs into pathways leading to human foods. Thus, a range of possible measures to reduce DLC levels in forage and feeds were identified and are presented in Matrix 1. Due to global environ-

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POLICY OPTIONS TO REDUCE EXPOSURE TO DIOXINS 179 mental contamination, it is expected that all forages and many grain sources will have detectable, although widely variable, DLC levels. The gaps in current information on the quantitation of risks due to DLCs in forage and feeds make it more difficult to develop uniform policy. However, research studies currently underway will improve future decision-making options for the management of these issues. Option: Require Testing for DLC Levels in Forage, Feeds, and Feed Ingredients This option would require feed manufacturers and animal producers to test samples of forage, feeds, and feed ingredients used in animal production systems to determine DLC levels in these products. Data would be collected for samples of ingredients, with the sampling and tracking of samples being performed under close supervision. The data obtained from testing and surveys would be com- bined with data from other sources to form a nationwide database on the levels and distribution of DLCs in forage, feeds, and human food. The database would be developed and maintained as a private/public cooperative project, with partici- pation from meat and produce commodity groups, feed manufacturers, meat and vegetable/fruit processors and retail markets, state departments of agriculture and public health, and the U.S. Department of Agriculture (which would act as the lead). An interagency coordination group should develop sampling priorities to identify and remediate deficits in DLC contamination data for all feeds, feed ingredients, forage, and animal production environments associated with produc- tion agriculture and for the human food supply. In addition, the interagency coordination group should develop uniform sampling techniques, analytic pro- cesses and data reporting, and storage algorithms to enable direct cross-industry and regional comparisons. To supplement the mandated testing, government agencies, commodity groups, and other food industry suppliers, including importers, would be encour- aged to supply analytic and descriptive product data to further expand the avail- able information. All data collected should be maintained with source anonymity and be collected for informational purposes only. As data accumulate and are evaluated, modifications in collection procedures may be required to maximize the resources available to the industry and the government. The justification for mandated testing, as discussed in Chapter 4, would be the need to build the base of data required to support a coherent risk-management strategy to identify and remove DLCs sources that enter animal production sys- tems and, thus, interrupt the cycle that allows DLCs to accumulate in the human food supply. At present, DLC data are collected piecemeal and are insufficient for use in tracking regional or national trends. Under a mandated data collection and distribution system, disparate public and private information resources would

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180 DIOXINS AND DIOXIN-LIKE COMPOUNDS IN THE FOOD SUPPLY Matrix 1. Intervention Options Considered to Reduce DLC Exposure Through Pathway l: Animal Production Systems A. Require testing for DLC levels in forage, feeds, and feed ingredients Alternate/lnterim Establish a national voluntary monitoring and information Actions system for DLCs in forage, feeds, and feed ingredients: 1. Develop new, less costly methods for DLC analysis 2. Encourage cooperative reporting of DLC results among feed manufacturers and other industry suppliers 3. Continue or expand government DLC monitoring programs 4. Make monitoring data available to industry and to the public Current Barriers to Current food safety laws are not applicable to DLCs Implementation The current cost of analysis creates a barrier to required testing DLC Exposure Results of testing provide supportive data to establish Reduction acceptable levels of DLCs in forage, feeds, and feed ingredients and augment monitoring for unintentional contaminants Risk-Relationship Ancillary Benefits: An expanded database to track Analysis unintentional contaminants in forage, feeds, and feed ingredients that could be used in conjunction with forthcoming analyses of the human food supply Countervailing Risks: Possible increased cost of some foods, which may decrease the availability of these foods and impact the nutritional status of at-risk populations B. Establish tolerance levels for DLCs in forage, feeds, and feed ingredients Alternate/lnterim 1. Implement avoluntary program to reduce DLC- Actions contaminated fat in animal feeds 2. Establish nonbinding targets for DLCs in forage, feeds, and feed ingredients Current Barriers to Data are insufficient to establish specific evidence-based DLC Implementation levels, and there is a low-priority resource status for implementing industry- or government-sponsored testing programs DLC Exposure Reduced levels of DLCs in animals and farmed fish that enter Reduction the food supply Risk-Relationship Ancillary Benefits: Long-term reduced levels of other Analysis undesirable lipophilic contaminants that have been found with DLCs in fats from animal-based foods Countervailing Risks: Possible increased cost of some foods, which may decrease the availability of these foods and impact the nutritional status of at-risk populations C. Restrict the use of animal products and forage, feeds, and feed ingredients that originate from specific areas that are considered to be contaminated

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POLICY OPTIONS TO REDUCE EXPOSURE TO DIOXINS 18 Alternate/lnterim 1. Identify and target for further analyses those geographic Actions areas with high potential for contamination and determine appropriate reduction strategies 2. Implement educational strategies to teach consumers who reside in contaminated areas how to modify cooking and food preparation to minimize exposure Current Barriers to The uncertainty of risk and insufficient forage, feed, or feed- lmplementation ingredient data available to assess local, regional, or national contamination levels and identify high-risk contaminant classifications DLC Exposure Reduced levels of DLCs in animal feeds that contain fats from Reduction animal sources Risk-Relationship Ancillary Benefits: Decreased opportunity for other Analysis undesirable contaminants that have been found with DLCs in lipid-based ingredients to enter into food animals and farmed fish via feeds Countervailing Risks: Possible increased costs of some foods, which may decrease the availability of these foods and impact the nutritional status of at-risk populations D. Restrict the reuse of the animal by-products in agriculture, animal husbandry, and manufacturing processes Alternate/lnterim 1. Work with industry to develop voluntary good agricultural, Actions animal husbandry, manufacturing, and transportation practices to achieve reduction in DLCs: a) Monitor building materials and bedding for DLC contamination b) Eliminate growing foods and forages in high-exposure areas or do not use first-cut forages from high exposure areas c) Increase intensive growing practices for livestock d) Reduce or eliminate the use of animal fats and oils, which may be high in DLCs, as ingredients in animal feeds 2. Provide subsidies to encourage the adoption of practices that reduce DLCs in forage, feeds, and feed ingredients Current Barriers to The use of vegetable fats may lead to increased spoilage and Implementation off-flavors in some products; disposal of unused animal fats will create additional environmental problems DLC Exposure Reduced reintroduction of DLCs into animal production Reduction systems, which will reduce DLC levels in human foods in the long-term Risk-Relationship Ancillary Benefits: The entry of other undesirable lipophilic Analysis contaminants into lipid-based agricultural products also is reduced as a result of revised production practices Countervailing Risks: Possible increased cost of some foods, due to costs of expanded testing and reporting, which may decrease the availability of these foods and impact the nutritional status of at-risk populations

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182 DIOXINS AND DIOXIN-LIKE COMPOUNDS IN THE FOOD SUPPLY combine, over time, into a body of information that would be useful for an ongoing analysis of risk and the development of risk-management strategies that reflect the evolution of environmental DLC levels. Alternate/Interim Actions An alternative to mandated DLC testing is a voluntary national monitoring and information system, developed to contain reported DLC levels in forage, animal feeds, feed ingredients, and animal production environments as described above. This option was developed in consideration of available regulatory tools and the constraints inherent in using them. Current Barriers to Implementation Current food safety laws do not provide regulatory agencies with the legal authority to mandate testing except possibly as part of a regulatory intervention that the agencies could justify as necessary to prevent illegal "adulteration" of a product. As discussed in Chapter 6, the evidence required for this appears not to be currently available. Thus, new legislation would likely be required to adopt the mandatory data collection option. The committee assumes that, under current law, the agencies could collaborate with the private sector in a voluntary data collection effort. Beyond legal authority, the committee strongly believes that a major factor in the paucity of DLC contamination data for all feeds and food classes is the high cost and complexity of available, validated analytic proce- dures. New and less costly methods for DLC analysis in forage, feeds, feed ingredients, and animal production environments, as well as in a wide range of food commodities and processed foods, should be encouraged. Screening tests that detect baseline contamination levels at costs that are significantly below current levels, as well as simplified instrumentation and detection processes, are needed to move forward. Funding for developmental research in DLC detection methods should be encouraged as part of the national research agenda. DLC Exposure Reduction Identifying "hot spots" where DLC contamination is particularly high would help narrow the focus for short-term or immediate interventions to reduce DLC exposures to food animals through forage and feeds. Such actions would also help minimize problems that could arise from the intermingling of food animals raised in areas where a contamination event has occurred with those raised in uncontaminated areas. Long-term testing would further allow for trend monitor- ing to map the rate of decrease of DLCs in exposure pathways and would be a useful adjunct to monitoring for human exposures and health outcomes that chro- nologically coincide with trends in DLC levels.

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POLICY OPTIONS TO REDUCE EXPOSURE TO DIOXINS Risk-Relationship Analysis 183 Ancillary Benefits. The committee did not identify a specific ancillary ben- efit to mandated or voluntary DLC testing and establishment of a nationwide database other than the possibility that the proposed system may, in the future, be useful in identifying other unintended or unwanted contaminants (similar to DLCs) in animal production systems. Countervailing Risks. A potential countervailing risk could occur if imple- mentation of this option increased the cost and prices of some foods. However, the size of the production-cost increases resulting from expanded testing and reporting, and the resultant consumer-level food price increases, would have to be significant for this to be a strong likelihood. The committee did not view this as probable. Option: Establish Tolerance Levels for DLCs in Forage, Feeds, and Feed Ingredients The option to regulate DLC levels in forage, feeds, and feed ingredients would likely take the form of tolerances or action levels (see Chapter 6~. These levels would be set, based on current DLC levels in forage, feeds, and feed ingredients and projected target levels, to achieve exposure reduction. Setting tolerances or action levels requires that the levels be set at a maximum limit necessary to protect public health (see Chapter 6~. Tolerances, but not action levels, are legally binding and enforceable through court action. The purpose of setting tolerances or action levels for DLCs is to achieve a specific reduction goal that is consistent with a maximum level of exposure considered to be safe. The justification for setting tolerances or action levels is based on the premise that DLC exposure reduction is necessary for public health and safety. Alternate/Interim Actions As an alternative to the binding limitations established by tolerances, it may be feasible to set nonbinding goals aimed at reaching lower DLC levels in forage and feeds that would minimize the amounts of these compounds available to food animals through these pathways. Furthermore, by maintaining flexible and ad- justable goals, these nonbinding target levels could conform to changing trends in environmental DLC loads as new data are gathered. Current Barriers to Implementation The limited amount of data available on DLC levels in forage and feeds creates a barrier to establishing enforceable tolerance levels. However, even if

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184 DIOXINS AND DIOXIN-LIKE COMPOUNDS IN THE FOOD SUPPLY tolerance levels were in place, foods such as wild-catch fish and imported foods would be missed by established feed regulations. An additional barrier to imple- menting enforceable tolerance levels is that testing is expensive. Establishing nonbinding goals to reduce DLC levels in animal forage and feeds is limited by the expense and difficulty of the analytical procedures cur- rently in place. There is also the question of whether nonbinding goals would be followed and whether they would achieve a reduction in DLC levels in these products. DLC Exposure Reduction Implementing measures to ensure that DLCs are reduced in animal forage, feeds, and feed ingredients is an important point of intervention in reducing DLCs in human food because the contamination of animal feeds is directly linked to the presence of contaminants in human food. By establishing maximum limits for DLCs in animal feeds, products contaminated at levels above the defined limits would be legally excluded from the food supply. Risk-Relationship Analysis Ancillary Benefits. If taking action to reduce the source of DLCs in the food chain results in a decrease in other hazardous contaminants, this could produce an ancillary risk-reduction benefit. Countervailing Risks. A potential countervailing risk could occur if imple- mentation of this option increased the cost and prices of some foods. However, the size of the production-cost increases resulting from expanded testing and reporting, and the resultant consumer-level food price increases, would have to be significant for this to be a strong likelihood. The committee did not view this as probable. Option: Restrict the Use of Animal Products and Animal Forage, Feeds, and Feed Ingredients That Originate from Specific Areas That Are Considered to Be Contaminated This option mandates that forage, feeds, and feed ingredients obtained from geographic regions known to be contaminated with greater than background levels of DLCs be removed from animal production systems, and that the use of animal food products obtained from contaminated areas be restricted. This option may also be a means to protect potentially highly exposed popu- lations from DLC sources in their immediate areas. Within specific geographic regions, certain populations may have higher daily intake levels of DLCs than the general population, due to food-consumption patterns, use of locally obtained

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POLICY OPTIONS TO REDUCE EXPOSURE TO DIOXINS 191 Current Barriers to The lack of current data is a barrier to setting enforceable Implementation standards DLC Exposure Reduced levels of DLCs in human foods, although food Reduction processing and packaging appear to play minor roles in human exposure to DLCs Risk-Relationship Ancillary Benefits: The cost of a DLC monitoring program for Analysis food packaging materials could be spread over several suppliers within the industry, thus diminishing the cost to individual companies Countervailing Risks: Possible increased costs of some foods, which may decrease the availability of these foods and impact the nutritional status of at-risk populations C. Require cleaning or washing practices for all vegetable, fruit, and grain crops that potentially had contact with soil Alternate/lnterim Recommend washing practices to consumers Actions Current Barriers to Cost impact is assumed to be small Implementation DLC Exposure Reduced levels of DLCs in processed foods of nonanimal Reduction origin Risk-Relationship Ancillary Benefits: May reduce exposure to bacterial and other Analysis food contaminants, especially on fresh fruits, vegetables, and grains Countervailing Risks: Possible increased costs of some foods, which may decrease the availability of these foods and impact the nutritional status of at-risk populations Option: Establish Enforceable Standards for DLC Levels in Processed Foods and in Food-Product Packaging That Directly Contacts Foods This option mandates that, within the current regulatory framework, enforce- able standards be set that limit the maximum allowable DLC levels in materials used for food packaging. In the past, DLCs have been found to enter the food supply through the processing and packaging of foods (see Chapter 4~. Fortunately, these instances were infrequent and corrective measures were taken. In addition, there are no materials currently in use in processing and packaging that are known sources of DLCs. Based on past experience, predicting inadvertent contamination events that may occur through processing, although not easily done, would be prudent as a means of preventing contamination incidents in the future.

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192 Alternate/Interim Actions DIOXINS AND DIOXIN-LIKE COMPOUNDS IN THE FOOD SUPPLY An alternative option is for regulatory agencies to develop a proactive moni- toring program that will identify DLC-contaminated food packaging materials for removal prior to their use. As an example of ways to reduce DLC levels by exploiting food safety intervention programs already in place, manufacturers could take a proactive role in monitoring product processing and packaging using the current HACCP program as a model. Current Barriers to Implementation As previously discussed in Matrix 1, the greatest barrier to implementing either enforceable standards or allowable levels for a detection program for DLCs in food-product packaging is a lack of legal authority, given the limitations in available data, which is due in large part to the high cost of testing and analysis. Lower-cost alternatives (see Chapter 2) may be implemented until DLC testing and analysis becomes more affordable. However, widespread testing and accu- rate information on current exposure levels are needed to establish enforceable guidelines. DLC Exposure Reduction Although food processing and packaging play a minor role in contributing to DLC exposure through foods, identifying the critical points at which the entry of DLCs into the food and food packaging process can be controlled. Setting action levels at these points, could further reduce the DLC level in many processed foods, which may be important if DLC exposure is found to be hazardous at background levels. Risk-Relationship Analysis Ancillary Benefits. A potential ancillary benefit to food producers and pro- cessors that may result from implementation of a DLC monitoring program in food packaging materials is that the cost of DLC analyses would not be borne by a single supplier, but rather would be spread over several suppliers within the industry, thus diminishing the cost to individual companies. Countervailing Risks. A potential countervailing risk could occur if imple- mentation of this option increased the cost and prices of some foods. However, the size of the production-cost increases resulting from expanded testing and reporting, and the resultant consumer-level food price increases, would have to be significant for this to be a strong likelihood. The committee did not view this as probable.

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POLICY OPTIONS TO REDUCE EXPOSURE TO DIOXINS 193 Option: Require Cleaning or Washing Practices for All Vegetable, Fruit, and Grain Crops That Potentially Had Contact with Soil This option mandates that food processors and producers implement a uni- form standard for washing practices for fresh vegetables, fruits, and grains used in food products. Soil containing DLCs may adhere to vegetables, fruits, and grains intended for human consumption. Although vegetables have not been shown to contribute large amounts of DLCs to overall intake levels, they can increase DLC exposure when contaminated soil is present on their surface. Thus, washing vegetable and fruit surfaces, leaves, and stems to remove soil and peel- ing root and waxy-coated vegetables are effective ways to reduce DLC exposure through these foods. Washing can be incorporated into industry production prac- tices, and can be encouraged among consumers and food preparers. Alternate/Interim Actions An alternative and interim action to mandated washing practices within the food processing industry is to develop a public education and information pro- gram to disseminate the information to consumers that they can reduce their exposure to DLCs by washing fresh vegetables and fruits. This option should include information on cleaning foods obtained from home gardens. Current Barriers to Implementation Uniform standards for washing fresh vegetables, fruits, and food grains are not currently in place in the food-processing industry. The cost to industry of implementing washing procedures is unknown, and a cost-impact analysis would be needed to determine the cost feasibility of such procedures. However, washing has been shown to be effective in reducing DLC levels in vegetables, fruits, and grain crops (see Chapter 5), and the cost of washing may be smaller than the cost of discarding foods that would be considered unusable due to DLC contamina- tion. DLC Exposure Reduction The committee regards washing procedures as an important intermediary step to reduce DLC exposure through vegetables, fruits, and grains. Even though such foods have not previously been considered major contributors to DLC expo- sure in humans, they may deserve more consideration than they have been af- forded if DLC testing and analysis are implemented and levels are found to be high in some of these foods.

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194 Risk-Relationship Analysis DIOXINS AND DIOXIN-LIKE COMPOUNDS IN THE FOOD SUPPLY Ancillary Benefits. DLCs adhere to the outside surfaces of plants, including the skins and peels of vegetables and fruits. These compounds are carried in soil, along with many other potential contaminants (e.g., bacteria, other organisms, and lead) that may pose some health risk, particularly to children. Implementing stringent cleaning and washing practices will reduce not only DLC levels on the surfaces of vegetables, fruits, and grains, but also any bacterial or other contami- nants on these surfaces and thus reduce exposure, particularly of young children, to these potential hazards. Countervailing Risks. A potential countervailing risk could occur if imple- mentation of this option increased the cost and prices of some foods. However, the size of the production cost increases resulting from expanded cleaning and washing practices, and the resultant consumer-level food price increases, would have to be significant for this to be a strong likelihood. The committee did not view this as probable. PATHWAY III: FOOD-CONSUMPTION PATTERNS Given that the majority of human exposure to DLCs is from food sources, information on the human consumption patterns of foods that may contain DLCs is an important component of any assessment of body burden for these contami- nants. Furthermore, an accurate analysis of food consumption by individuals in the general population and in sensitive or highly exposed subpopulations can serve as the basis for identifying certain foods, such as animal fats, that are major sources of DLC exposure. Food-consumption patterns are dynamic, and consumers tend to make spe- cific choices within the various food groups to meet their nutritional needs. Within a food group (e.g., the "meat and meat alternates" food group, which contains meat, poultry, fish, dry beans, eggs, and nuts), specific foods vary greatly in terms of their animal fat content and potential source of DLC exposure. It is generally recognized that food-consumption patterns that include a vari- ety of food choices are important for maintaining nutritional health. When the selection of a food is limited, whether by choice, accessibility, or custom, the potential to limit nutrient availability is increased, as is the probability for DLC exposure if the food chosen is a source of DLCs. The committee identified various dietary choices that may reduce exposure to DLCs (see Matrix 3), yet have a minimal impact on nutrient availability or intake (see Chapter 5~.

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POLICY OPTIONS TO REDUCE EXPOSURE TO DIOXINS Option: Increase the Availability of Low-Fat and Skim Milk in Federal Feeding Programs Targeted to Children by Amending the Current Act Favoring the Provision of Whole Milk in the National School Lunch Program 195 This option would increase the availability of low-fat and skim milk to participants in federal nutrition programs that are targeted to children, such as the National School Lunch and School Breakfast Programs, and the Child and Adult Care Food Program. The statute governing the National School Lunch Program (Richard B. Russell National School Lunch Act, amended Dec. 8, 2000, 9~2~) states that "schools participating in the school lunch program under this Act shall offer students a variety of fluid milk consistent with prior year preferences unless the prior year preference for any such variety of fluid milk is less than 1 percent of the total milk consumed at the school," which currently favors the purchase of whole milk. Thus, this option requires the amendment of regulations that favor the provision of whole milk to participants in the School Lunch Program. Whole milk and full-fat dairy foods have been identified as important con- tributors to the DLC intake of children, whereas low-fat and skim milk contain at least as much calcium and other essential nutrients as whole milk, but have lower levels of DLCs (see Chapter 5~. Thus, choices of low-fat milk and dairy products can satisfy nutrient requirements and reduce exposure to DLCs. Alternate/Interim Actions An alternative to requiring that low-fat and skim milk be provided in federal nutrition programs is to encourage the inclusion and increase the marketing of low-fat and skim milk in these programs, and encourage the selection of low-fat milk and dairy products for children over 2 years of age in the Special Supple- mental Nutritiom Program for Women, Infants and Children. In addition, public education and information efforts can be used to encourage parents to choose, when appropriate, low-fat and skim milk in place of whole milk in diets of their children above the age of 2 years. Current Barriers to Implementation The committee did not identify any significant direct cost barriers to pro- gram sponsors that would result from implementation of the option to reduce DLC exposure through foods provided in federal nutrition programs. However, the committee recognizes that the dairy and related industries face a significant economic issue with regard to the disposal of excess butterfat if it is removed from milk; interfacing with relevant federal agencies for assistance may help resolve this problem.

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196 DIOXINS AND DIOXIN-LIKE COMPOUNDS IN THE FOOD SUPPLY Matrix 3. Intervention Options Considered to Reduce DLC Exposure Through Pathway 111: Food-Consumption Patterns A. Increase the availability of low-fat and skim milk in federal feeding programs targeted to children by amending the current act favoring the provision of whole milk in the National School Lunch Program Alternate/lnterim the inclusion and marketing of low-fat and skim Actions milk in federal feeding programs targeted to children Current Barriers to Highly feasible; possible cost barriers to the dairy industry Implementation DLC Exposure Reduced consumption of whole milk and increased Reduction consumption of low-fat and skim milk, which have lower levels of DLCs Risk-Relationship Ancillary Benefits: Improved long-term health benefits due to Analysis reduced consumption of saturated fats Countervailing Risks: The nutritional status of children who will not consume low-fat or skim milk may be at risk B. Establish a maximum saturated fat content for meals served in schools that participate in federal child nutrition programs Alternate/lnterim Encourage following recommended dietary guidelines for the Actions maximum saturated fat content for individual meals served in schools that participate in federal feeding programs, while determining the feasibility of setting maximum limits on saturated fats in individual meals DLC Exposure Reduction Based on current evidence for DLC exposure through whole milk and full-fat dairy products (see Chapter 5), the committee expects that reduced consumption of these products will decrease the DLC intake levels in children who consume them. The commissioned analysis of DLC exposure through foods further indi- cates that, especially in young children over 2 years of age and girls under 19 years of age, consuming low-fat or skim rather than whole milk and choosing low-fat versions of other dairy foods will reduce their DLC intake (see Chap- ter 5~. Risk-Relationship Analysis Ancillary Benefits. There are no clear nutritional benefits from eating foods high in saturated fats that would not be obtained by eating lower-fat versions of

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POLICY OPTIONS TO REDUCE EXPOSURE TO DIOXINS 197 Current Barriers to High feasibility if recommendations are accepted and Implementation implemented, but cost may be high, especially to food industries DLC Exposure Reduced exposure to DLCs present in animal fats Reduction Risk-Relationship Ancillary Benefits: Changed food-consumption patterns away Analysis from the consumption of saturated fats from animal-based foods will decrease the risk for some chronic diseases Countervailing Risks: The nutritional status of some children who will not consume foods low in saturated fats may be at risk C. Promote changes in dietary-consumption patterns of the general population that more closely conform to recommendations from the Dietary Guidelines for Americans to reduce the consumption of foods high in saturated fats Alternate/lnterim Implement revisions to the federally sponsored dietary Actions guidelines Current Barriers to High feasibility if recommendations are accepted and Implementation implemented by the public DLC Exposure Reduced exposure to DLCs through foods containing animal Reduction fats Risk Relationship Ancillary Benefits: Changed food-consumption patterns away Analysis from the consumption of saturated fats from animal-based foods will decrease the risk for some chronic diseases Countervailing Risks: Dietary recommendations to increase fish consumption are not conducive to reducing DLC intake the same foods. If young children, both male and female, decrease their intake of whole milk and full-fat dairy products, they will consume lower levels of satu- rated fats, while consuming the same levels of calcium, vitamin D, and other important nutrients. This modification will likely have the net benefit of decreas- ing the risk for certain chronic diseases that are associated with consuming high levels of saturated fats (see Chapter 5~. Countervailing Risks. A possible countervailing risk that could arise from offering low-fat and skim milk in place of whole milk to children is that they could choose to not drink any milk, which could place them at nutritional risk. However, a risk analysis would have to be performed for this scenario in order to verify this outcome.

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198 DIOXINS AND DIOXIN-LIKE COMPOUNDS IN THE FOOD SUPPLY Option: Establish a Maximum Saturated Fat Content for Meals Served in Schools That Participate in Federal Child Nutrition Programs This option would, within the current regulatory framework, establish a maximum allowable content for saturated fats in individual meals served through federal child nutrition programs, including the School Lunch and School Break- fast Programs and the Child and Adult Care Food Program. There is currently no standard for saturated fat levels for individual meals in these programs. There is, however, a requirement that meals averaged over a week contain less than 10 percent of total calories from saturated fats (School Meals Initiative for Healthy Children, 7 C.F.R. 20~. Since these standards were adopted, reductions in the saturated fat content of school meals have occurred, although the goal for saturated fat to be less than 10 percent of total calories has not been met. Alternate/Interim Actions An alternate or interim action is to encourage compliance with recommended dietary guidelines through public education and information programs that will inform parents of the benefits of providing foods low in saturated fats to their children, while determining the feasibility of setting maximum limits on satu- rated fat in school breakfast and lunch meals. Current Barriers to Implementation Children who are not accustomed to consuming foods low in saturated fats may not initially accept such foods offered through federal nutrition programs. If the meals served in a program are the primary source of nutrients for children, their nutritional intakes are affected by the food choices they make. There are, however, a wide variety of foods low in saturated fat that can be made available to children. Thus, although this option will change the variety of foods offered, it will not necessarily limit it. One barrier to implementation of this option is likely to be poor acceptance of foods lower in saturated fats, particularly if they are not presented in an attractive and appealing way. Current studies suggest that implementing reductions in the saturated fat content of school meals can be accomplished at minimal cost to consumers. However, because the economic feasibility of reducing the saturated fat content of school meals, and the impact of other factors, such as reduced acceptance by children and increased costs to the food industry have not been established, this is another barrier to implementation.

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POLICY OPTIONS TO REDUCE EXPOSURE TO DIOXINS DLC Exposure Reduction 199 DLCs are found primarily in animal fats. Additionally, these fats are also the primary source of saturated fats in the American diet. By reducing the availability of foods high in saturated fats, exposure to DLCs that may be present will also be reduced. Since this option is targeted to young children, their exposure to DLCs through these foods is expected to decrease. As previously stated, the committee believes that DLC exposure reduction is important in young children, particularly girls, so that they may enter their reproductive years with lower DLC body burdens. Risk-Relationship Analysis Ancillary Benefits. Research has shown that reducing the consumption of foods high in saturated fats is associated with the reduced risk for many chronic diseases, including heart disease and cancer. Therefore, long-term health benefits would be expected to result from reducing saturated fat intake beginning in childhood. Countervailing Risks. Children who do not accept foods lower in saturated fats may not have adequate nutrient intakes and may be at increased nutritional risk. Option: Promote Changes in Dietary-Consumption Patterns of the General Population That More Closely Conform to Recommendations from the Dietary Guidelines for Americans to Reduce the Consumption of Foods High in Saturated Fats This option recommends that the federal sponsors of the U.S. Dietary Guide- lines institute public education and information dissemination campaigns and actively promote compliance with the recommendations of the Guidelines, par- ticularly those that advise the decreased intake of foods high in saturated fats. Although the U.S. Dietary Guidelines are available through publications and informational websites, current promotional efforts by federal sponsors are insuf- ficient. The dietary recommendations and associated educational tools for the gen- eral population that are consistent with reducing DLC exposure by reducing animal-fat intake include the Dietary Guidelines for Americans, last revised in 2000; the Food Guide Pyramid, based on the Dietary Guidelines; the dietary findings of the Institute of Medicine in the recently released report on Dietary Reference for Intakes Energy, Carbohydrate, Fiber, Fat, Fatty Acids, Choles- terol, Protein, and Amino Acids; and the recommendations of the American Heart Association (AHA). Although these documents do not provide specific guidance

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200 DIOXINS AND DIOXIN-LIKE COMPOUNDS IN THE FOOD SUPPLY regarding foods high in DLCs, their recommendations to reduce intake of animal fat, the primary source of saturated fats, will result in a reduction in exposure to DLCs. As discussed in Chapter 5, dietary surveys, such as the Continuing Survey of Food Intakes by Individuals and the National Health and Nutrition Examina- tion Survey have shown a trend of decreasing saturated fat intake in the general population, and the committee believes this trend should be encouraged to con- tinue. In addition, the recommendation to reduce intake of saturated fats is in keeping with current national policies for good nutrition and health. Compliance with this recommendation does not require a reduction in protein intake; rather, it is a recommendation to trim visible fats from animal foods. Thus, the committee believes that compliance with this recommendation will not place consumers at increased nutritional risk and would likely reduce the risk for chronic disease. Alternate/Interim Actions An alternate action that may be taken is to revise the content of the U.S. Dietary Guidelines to include a food safety component that would recommend low-fat, but nutritionally equivalent, alternate choices to foods that are high in saturated fats as a way to reduce DLC exposure. Current Barriers to Implementation Since compliance with dietary recommendations is not mandatory, the suc- cess of such programs as a means to reduce DLC exposure depends entirely on their acceptance by the population. Educational campaigns and other promotional efforts can be undertaken to enhance public awareness and improve compliance with dietary recommendations. However, the committee recognizes there is un- certainty about the impact of educational programs on behavioral changes. DLC Exposure Reduction Adherence to dietary recommendations to reduce intake of saturated fats and animal fats is expected to, over a period of years, reduce DLC body burdens. Risk-Relationship Analysis Ancillary Benefits. In addition to reducing DLC exposures, there are con- comitant ancillary benefits to overall health from compliance with recommenda- tions to reduce total and saturated fat intake, such as the reduced risk for chronic disease, especially heart disease. Countervailing Risks. The dietary recommendation in the U.S. Dietary Guidelines and the AHA recommendations that is not conducive to both reducing

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POLICY OPTIONS TO REDUCE EXPOSURE TO DIOXINS 201 DLC intake and improving health outcome is that of fish consumption. As dis- cussed in Chapter 5, certain fish, including salmon and catfish, have been found in some cases to contain relatively high levels of DLCs, although these vary by source, location, and feeding exposure. As with other foods, the DLC content of fish closely parallels the fat content. Unfortunately, the fatty component of fish that is the source of beneficial omega-3 fatty acids is also the component of fish where DLCs accumulate. To some extent, DLC concentrations in fish differ depending not only on the species, but also on the geographic region in which they are found, because some areas have greater environmental contamination than others. Nevertheless, over- all wide variability is seen in analytical data reported for DLC levels in many foods, including fish, which increases the level of uncertainty and decreases the reliability of measures used for trend analysis. This level of uncertainty increases the difficulty of making reliable recommendations to reduce exposure to DLCs, particularly when it may be to the detriment of health benefits derived from certain foods. Chapter 8 presents the committee's recommendations to reduce DLC expo- sure through foods from the array of options presented in this chapter.