Dioxins and Dioxin-like Compounds in the Food Supply Strategies to Decrease Exposure (2003) / Chapter Skim
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6. Framework for the Development of Policy Options to Reduce Exposure to Dioxins and Dioxin-like Compounds
6. Framework for the Development of Policy Options to Reduce Exposure to Dioxins and Dioxin-like Compounds
Pages 150-173
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From page 150... ...
. In considering DLC exposure reduction options, the committee was charged with taking into account both possible reductions in human health risk associated with reducing DLC intake and the possible nutritional consequences of dietary changes that might result from the selected measures.
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options to reduce DLCs in animal forage and feeds, (2) options to reduce DLCs in the human food supply, and (3)
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It is also the most promising pathway that provides an opportunity to interdict and reduce DLC contamination of the human food supply. One major source of DLC contamination is air deposition of DLCs onto plants that are used for forage and feeds.
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However, any reductions in DLC contamination that are achieved at the forage and feed stage have the important benefit of directly reducing the reservoir of DLCs in food to which humans are potentially exposed. Human Food The second major category of opportunities to reduce DLC exposure identified by the committee involves reducing DLC levels in the foods people consume.
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public policy and regulatory interventions beyond traditional food safety interventions, including subsidies, economic incentives, and other measures to reduce DLCs and expand dietary options, and (4) information and education interventions.
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Subsidies, Economic Incentives, and Other Measures to Reduce DLCs and Expand Dietary Options Beyond the traditional regulatory or cooperative approaches to reducing DLCs, there are a number of other tools of public policy that, though rarely used to address food safety hazards, are at least theoretically available to the government to foster reductions of DLCs. These could include, for example, subsidies or other economic incentives, such as taxes, to induce reductions in the use of animal fat in animal feeds; development of alternative uses for animal fats other than feeds (e.g., biofuels)
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Food Safety Regulatory Tools Among the regulatory agencies in the federal government, FDA has the primary food safety regulatory jurisdiction over DLCs in animal feeds and human food categories other than meat and poultry. For meat and poultry, USDA's Food Safety and Inspection Service (FSIS)
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To enforce the first two adulteration provisions noted above, FDA could choose to proceed on the basis of case-by-case enforcement action, through informal or formal standard-setting, or a combination of these two. FDA has the option, if it can prove that a particular lot of food contains an environmental contaminant at a level that violates one of the adulteration provisions, to seek court action to remove that lot from commerce and prevent its future distribution.
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The only tolerances FDA has established to date are for PCBs in certain human foods (milk, dairy products, poultry, eggs, fish, infant and junior foods) and in animal feeds and feed components for food-producing animals.
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Practical Constraints on Regulatory Options While FDA has successfully used these regulatory tools to address a wide range of food safety issues, including hazards posed by environmental contaminants such as lead, mercury, and aflatoxin, the agency would face significant practical constraints in applying them to DLCs in feeds and food. As discussed in Chapter 2, there continues to be scientific debate and uncertainty about the level of human intake of DLCs required to cause adverse health effects in the population at large and in specific subpopulations, especially in light of the fact that the risks of DLCs are generally thought to be associated with their accumulation in human tissue over time.
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The committee has identified a number of voluntary efforts as options to reduce DLC levels in feeds and food. They include setting nonbinding targets for reducing DLC levels in feeds and food, working with the industry to establish and encourage the adoption of voluntary GAPs and GMPs, and providing data on the current levels and sources of DLCs in feeds and food to support voluntary reduction efforts.
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As noted previously, the sponsors of this study did not charge the committee with conducting a risk assessment for DLCs in the food supply, but rather asked it to rely on already existing information. The committee was charged to develop and assess risk-management options for reducing DLC exposure from foods.
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Specifically, the study sponsors asked the committee to consider the possible nutritional consequences of dietary changes that might result from measures taken to reduce DLC exposure. The hypothesis underlying this charge was that such dietary changes, which might stem, for example, from increases in food prices due to costs imposed by new regulatory requirements or by the shifting of food-consumption patterns away from animal fat, might create countervailing health risks by depriving some individuals of needed nutrients.
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The committee concludes that, in considering riskmanagement options to reduce DLC exposure, it is appropriate to conduct a riskrelationship analysis that considers whether a proposed intervention would affect dietary patterns, for better or worse, in relation to current dietary guidelines. Ideally, a risk-relationship analysis would provide a quantitative basis for considering and comparing the risk reduction likely to be achieved by the proposed intervention, any countervailing health risks the intervention might cause, and any expected ancillary health benefits (see Box 6-1~.
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the models and data required to predict changes in dietary patterns are extremely limited, (2) a given intervention might push diets in more than one direction; for example, reductions in the consumption of full-fat dairy products could not only reduce overall intake of undesirable animal fat, but it could also reduce the overall intake of desirable calcium if the low-fat product is not consumed, and (3)
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In Chapter 7, these options are presented in three matrices corresponding to the three major categories of intervention options: Matrix 1: Intervention Options Considered to Reduce DLC Exposure Through Pathway I: Animal Production Systems Matrix 2: Intervention Options Considered to Reduce DLC Exposure Through Pathway II: Human Foods Matrix 3: Intervention Options Considered to Reduce DLC Exposure Through Pathway III: Food-Consumption Patterns Within these matrices, each considered option is presented in the format shown in Figure 6-1. This format captures the series of questions the committee believes government agencies should consider in identifying and analyzing risk-manageOption Alternate/l nterim Actions Current Barriers to Implementation DLC Exposure Reduction Exposure Reduction: RiskRelationship Analysis Ancillary Benefits: Countervailing Risks: FIGURE 6-1 Format for analyzing intervention options considered to reduce DLC exposure.
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The charge to the committee and the proposed framework address the health consequences of efforts to reduce DLC exposure, not the economic consequences. The committee considers the practical feasibility of a proposed intervention to be a valid threshold question because no health benefit will accrue from an intervention that cannot feasibly be implemented.
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Thus, it is appropriate with respect to a number of the proposed interventions discussed in Chapter 7 to consider alternate or interim steps, such as developing improved test methods, expanding data collection programs, and fostering voluntary efforts to reduce DLCs. Current Barriers to Implementation The committee considered at length how DLCs enter the food supply, their pervasiveness, and some of the obstacles to reducing DLC exposure from food.
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DLC Exposure Reduction In the committee's proposed framework, DLC exposure reduction is the declared goal, but it should be understood to be a surrogate for risk reduction. The reason to reduce DLCs in the food supply and in diets is to reduce the potential for adverse health effects resulting from exposure and accumulation of DLCs in human tissue.
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The committee concluded that it is appropriate to consider both the potential ancillary health benefits and countervailing health risks associated with different risk-management options, recognizing that the potential health impact of any dietary change would vary among population subgroups and individuals depending on their nutritional needs and nutritional status at the time of the dietary change. As discussed in Chapter 5, the committee utilized two data resources to help predict the outcomes of certain scenarios of dietary modification that could result from efforts to reduce DLC exposure through foods.
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However, it could be a way to reduce exposure to sensitive population groups in such a manner that negative nutritional consequences could be avoided. The committee also considered the possibility that regulatory interventions to reduce DLC exposure in the diet could impose costs on the food production system that would be reflected in higher consumer prices for food, which could in turn affect dietary choices and nutrient intake levels to an extent that could have negative health consequences.
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A risk-management option to reduce DLC exposure might affect the prices of more than one category of food products at the same time, potentially increasing the impact of the option on nutrient intakes. Nevertheless, it is the committee's judgment that the potential countervailing risk stemming from a causal link between increased production costs, increased food prices, changed dietary intakes, and poorer health is not likely to be an important consideration in evaluating riskmanagement options for reducing DLC exposure.
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1980. FDA regulation of environmental contaminants of food.
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1996. The Food Guide Pyramid.
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