What is there to prevent some of the arsenic present in the soil and/or groundwater from migrating to the crops produced in these areas? These crops may be shipped all over the country. Food manufacturers make use of some these crops as ingredients in their own products. Since there are no regulatory limits for the arsenic allowed in such crops (or in food), why should it surprise anyone when arsenic picked up by, say, tomatoes in the field shows up in a jar of salsa? If there are no regulatory limits for arsenic in food, then there can be no labeling requirements either. By the time that jar of salsa has been placed in the supermarket cart, the consumer may know very little about it beyond what has been disclosed on the label, which will say nothing at all about arsenic. Why should FDA regulation (or the lack of it) be as mysterious as alchemy? Through FSA, consumers will have the lead and arsenic levels of their food samples determined by the best analytic technology currently available, Inductively Coupled Plasma – Mass Spectroscopy (ICP/MS).
The issue of mercury content in seafood is another example. FDA has already published that the average mercury content of one of the most popular canned seafood products sold in this country (albacore tuna) averaged 0.83 ppm. However, the limit for mercury in food has been set to 1 ppm. Significantly, FDA warns consumers not to eat too much albacore tuna. Consumers might be forgiven for asking why, if the average content of mercury is less than the purported “safe” level for albacore tuna, should they be warned not to eat too many albacore tuna fish meals in a week? To put the question another way, does not the recommendation to limit the number of albacore tuna fish meals in a given week suggest that 1 ppm may not, in fact, be a “safe” limit? Since expert opinion differs in this matter, should not the consumer be provided with the information to make up his/her own mind? Through FSA, consumers will have their mercury samples analyzed by one of the most sensitive analytic technologies available for mercury, Cold Vapor Atomic Absorption Spectroscopy (CVAAS).
Of equal importance in identifying problems is the matter of recognizing and rewarding safety. FSA believes that the overwhelming majority of food manufacturers want to provide consumers with the safest food possible. Doing so is good business and a key to sustained profitability. Consumers will naturally want to reward (with their business) food manufacturers who consistently provide products low in these (and other) toxic heavy metals. Until now, there has been no way for consumers to learn these facts. Regulatory agencies are only empowered to act when they perceive that a regulatory limit has been breached. FSA is not a regulatory agency of any kind. Results will simply be provided to all consumers who “shared” in ordering the testing. Consumers will then be able to make up their own minds how the results they paid for should be used.
The FDA Food Safety Modernization Act (FSMA) is currently in the process of being implemented and FDA is in the midst of rulemaking to support it. This law asks companies to conduct an periodic assessment of the hazards (Hazard Analysis = HA) present in their production plants and then to mitigate the identified hazards through the use of certain Critical Control Points (CCP) incorporated into the manufacturing process. The intent here is to reduce the role of end product safety testing through prevention. While this is good strategy, it also means that manufacturers will perform significantly less testing of their finished goods once the preventative measures have been put in place. Consumers testing the “finished goods” they buy in the stores can make a real difference here.
Despite the fact that FDA has been handed broad new powers and also been saddled with a great deal of new rulemaking, our ongoing economic crisis has prompted some (mostly Republican) legislators to recommend a funding cut for FDA under the assumption that our food is already safe. The fact that food recalls occur with dismal regularity and that during some of these outbreaks Americans have sickened and died does not appear to sway some PollyAnna guardians of the public purse. FDA is now able to inspect only some two percent of food imported into this country. As FDA’s hands are increasingly tied, the kind of consumer-based testing undertaken by consumers themselves may become increasingly more important.
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