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7. Policy Options to Reduce Exposure to Dioxins and Dioxin-like Compounds
Pages 174-201

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From page 174...
... These interventions 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.
From page 175...
... Regulatory agencies have invested relatively little toward generating the data required to support risk-management decisions related to options to reduce DLC exposure. For example, little data are available that would permit more refined estimates of current DLC levels in feeds, forage, and human foods; the current distribution and
From page 176...
... The listings of current barriers to implementation, expected DLC exposure
From page 177...
... The size and direction of these impacts must be the subject of further analysis. 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)
From page 178...
... 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 contaminants 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.
From page 179...
... . 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 production agriculture and for the human food supply.
From page 180...
... 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
From page 181...
... 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
From page 182...
... 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 monitoring 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 chronologically coincide with trends in DLC levels.
From page 183...
... 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~.
From page 184...
... 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.
From page 185...
... Another possible interim action to protect specific populations that reside in contaminated geographic areas and consume locally obtained foods is to implement educational strategies to teach consumers how to modify cooking and food preparation to minimize exposure (see Chapter 5~. Current Barriers to Implementation Under the statutory standards governing food safety interventions, the uncertainty of risk reduction at low doses and the lack of sufficient data on DLC levels in animal production systems would be a constraint to setting mandatory tolerance levels, enforcing action levels, or mandating restrictions on the use of animal products, forage, and animal feeds that originate from specific regions.
From page 186...
... Option: Restrict the Reuse of Animal By-Products in Agriculture, Animal Husbandry, and Manufacturing Processes This option requires that the by-products of animal production systems, particularly animal fats, be restricted from re-entering the pathways that lead to the human food supply via animal feed ingredients. Removing animal fats from animal diets will, over time, reduce DLC levels in animal food products and interrupt the cycle of introducing DLCs into the food supply.
From page 187...
... DLC Exposure Reduction rl~he long-term effect of implementing restrictions on the reuse of animal fats in the animal feed supply is that the reintroduction of DLCs into the human food supply through the animal feed pathway will be reduced, ultimately resulting in lower DLC exposure to the humans who consume animal food products. Risk-Relationship Analysis Ancillary Benefits.
From page 188...
... Thus, reducing DLC exposure by not consuming foods that may be sources of important nutrients is appropriate only if nutritionally equivalent foods are substituted. Option: Require Testing and Publishing of Data on DLC Levels in the Human Food Supply, Including Food Products, Dietary Supplements, and Breast Milk, to Use in Establishing Tolerance Levels in Foods This option would require food manufacturers and processors of food products and dietary supplements to determine current levels of DLCs in their products.
From page 189...
... Current Barriers to Implementation The government lacks authority under current food safety laws to require private sector DLC testing for the purposes proposed here. The high cost of DLC analysis is also an obstacle to widespread testing for DLC levels in all foods.
From page 190...
... Require testing and publishing of data on DLC levels in the human food supply, including food products, dietary supplements, and breast milk, to use in establishing tolerance levels in foods Alternate/lnterim Encourage voluntary analysis of the DLC content in human Actions foods, dietary supplements, and human breast milk Current Barriers to No government authority to require private-sector testing; low Implementation feasibility at the current cost of testing and analysis DLC Exposure Establishment of a database that will allow the accurate Reduction assessment of DLC exposure through foods and provide a basis for setting tolerance or action levels in foods Risk-Relationship Ancillary Benefits: Changes in food-consumption patterns Analysis away from consumption of saturated fats from animal-based foods will decrease the risk for some chronic diseases 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 B Establish enforceable standards or allowable levels for DLC in processed foods and in food-product packaging that directly contacts foods Alternate/lnterim Modify Hazard Analysis and Critical Control Point (HACCP)
From page 191...
... 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.
From page 192...
... 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.
From page 193...
... 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)
From page 194...
... 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 contaminants on these surfaces and thus reduce exposure, particularly of young children, to these potential hazards. Countervailing Risks.
From page 195...
... 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 program sponsors that would result from implementation of the option to reduce DLC exposure through foods provided in federal nutrition programs.
From page 196...
... 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)
From page 197...
... If young children, both male and female, decrease their intake of whole milk and full-fat dairy products, they will consume lower levels of saturated fats, while consuming the same levels of calcium, vitamin D, and other important nutrients. This modification will likely have the net benefit of decreasing the risk for certain chronic diseases that are associated with consuming high levels of saturated fats (see Chapter 5~.
From page 198...
... 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 saturated 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.
From page 199...
... 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 Guidelines institute public education and information dissemination campaigns and actively promote compliance with the recommendations of the Guidelines, particularly those that advise the decreased intake of foods high in saturated fats.
From page 200...
... 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.
From page 201...
... 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 exposure through foods from the array of options presented in this chapter.


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