“acceptable” Contaminants for Food?: Melamine as Protein Supplement
ROTTERDAM – THE CODEX COMMITTEE
ON CONTAINMANTS IN FOODS MEETING –
MUM’S THE WORD
By Scott C. Tips, NHF President
March 30, 2009
The 3rd Session of the Codex Committee on Contaminants in Foods (CCCF) began its week-long meeting at the Beurs – World Trade Center in Rotterdam, the Netherlands on Monday morning, March 23, 2009. Although the weather was despicable, with rain and heavy winds, the National Health Federation (NHF) delegate, Scott Tips, was able to easily attend this meeting chaired by first-time Chairman Mr. Martijn Weijtens (of the Dutch Ministry of Agriculture, Nature and Food Quality). This particular meeting was important because “acceptable” levels of contaminants of acrylamide, polycyclic aromatic hydrocarbons (PAH), aflatoxins, and melamine, among others, were being discussed and developed.
World Trade Center – Rotterdam
The NHF is the only Codex-accredited health-freedom organization with the right to attend Codex committee meetings such as this one. In fact, although the NHF has for years been attending many other Codex committee and commission meetings – in Germany, Canada, France, Italy, Switzerland, Norway, China, Thailand, and most recently South Africa – this CCCF meeting was the first for us.
As with the other Codex committees, the CCCF attendees consisted of various member-country delegations and a dozen INGOs (International Non-Governmental Organizations). The NHF was the only consumer organization in attendance, with all of the other INGOs representing special trade interests. The rest of the room was filled with government officials and bureaucratic functionaries. This Committee, a relatively recent split off from the former combined Committee on Contaminants and Food Additives, was the smallest of the committees attended by the NHF.
Acrylamide, PAH, and Aflatoxins
In contrast with certain other committees that breed harsh dispute, this Committee was as tame and well-mannered as a pack of Cub Scouts drugged to the teeth on IV-dripped Prozac. Both of the two separate standards being set for acrylamide and PAH in foods sailed smoothly through the Committee, which agreed to forward them to the Codex Alimentarius Commission for adoption at the final Step 8.
The CCCF’s review and discussion of the standard for aflatoxins was a little more lively and included some actual back-and-forth discussion of the topic. In the end, the Committee accepted Brazil’s proposal to return the Proposed Draft Maximum Levels to Step 2/3 for redrafting. But even this standard is not a controversial one.
The drama did not really begin until the Canadian delegate read his country’s report on establishing maximum levels for melamine in food and feed. The Committee document drafted by Canada proposed maximum levels of melamine in food and feed of 2.5 parts per million (ppm) and in infant formula of 1 ppm.
Melamine is a chemical compound that is used industrially in the production of, among other things, laminates, glues, dinnerware, adhesives, molding compounds, coatings, and flame retardants. There are no approved direct food uses for melamine, but melamine is illegally added to artificially increase the protein content of food products. Because it is high in nitrogen and cheap, melamine is a low-cost way to artificially bump up the “protein” content for standard commercial tests. Other contamination comes from indirect sources, such a food contact with melamine-containing packaging.
In 2007, melamine was found in pet feed exported from China to the United States, which feed unfortunately caused the death of a large number of dogs and cats due to kidney failure. Following this incident in 2007, several food agencies and authorities began performing preliminary risk assessments of melamine.
Then, with nearly 40,000 cases of kidney stones in infants (with three deaths and nearly 13,000 hospitalized) from consumption of melamine-contaminated powdered infant formula in China alone as late as September 2008, and with other melamine contamination having been found in liquid milk, frozen yogurt desserts, and coffee drinks, the alarm was raised – melamine is dangerous and to be avoided.
As a result, the US Food and Drug Administration (FDA) published an interim safety/risk assessment on melamine and structural analogues, setting a tolerable daily intake (TDI) of 0.63 mg per kg of body weight per day for melamine. At almost the same time, the European Food Safety Authority (EFSA) published a provisional statement and recommended to apply a TDI of 0.5 mg per kg of body weight per day as tolerable intake value for melamine. Under Commission Decision 2008/757/EC, member States of the European Union are required to ensure that all composite products containing at least 15 % of milk product, originating from China, are systematically tested before import into the Community and that all such products which are shown to contain melamine in excess of 2.5 mg/kg are immediately destroyed. (See http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:273:0018:0020:EN:PDF.)
The Canadian food-and-drug agency, Health Canada, declared an even stricter limit of 0.35 mg. Not to be outdone, the World Health Organization’s Food Safety Director estimated that the amount of melamine a person could stand per day without incurring a bigger health risk, the “tolerable daily intake” (TDI), was 0.2 mg per kg of body mass. (See Lara Endreszl, 10 December 2008, “Safe Melamine Levels Named by World Health Organization”, Health News; see also B Puschner, and PA Pesavento, “Assessment of melamine and cyanuric acid toxicity in Cats,” J. Vet. Diagnostic Investigation, Vol. 19, No. 6, 616-624 (2007) athttp://jvdi.org/cgi/content/abstract/19/6/616.)
Back to CCCF
So it was that with these issues in mind, the NHF raised its nameplate at the CCCF meeting to speak out and oppose the 2.5 ppm upper limit on melamine contamination proposed by the Codex draft paper. At the very least the limit should be no more than 1 ppm, we argued before the Committee. And, preferably, there should be no detectable amounts at all.
Yet when the CCCF Report was prepared and then reviewed for approval by the Committee on Friday, the last day of this session’s meeting, no sign could be seen of the NHF’s comment in the Report. Of course, NHF asked that its comments be reflected in the Report as a simple, one-sentence statement; only to then set off – surprisingly – the most contentious exchange of the entire meeting!
The European Commission strongly opposed showing NHF’s comments in the Report, stating there was no need for the sentence. Canada and Japan both joined in the censorship move – much to their countries’ discredit and dishonor – and argued that NHF could submit written comments later. The NHF shot back, asking the Committee and its delegations what it was afraid of and pointing out that the Report should reflect what happened at the meeting. This caused another stir, with much consultation amongst persons at the head table and negative head-shaking by Codex Secretariat Verna Carolissen-Mackay. In the end, the Chairman politely but firmly refused to allow NHF’s remarks to be noted in the record, but promised that the next session would allow those comments to be recorded (if once again made).
Typical Non-Transparency and Double-Standards
Perhaps unused to controversy or contradiction, the CCCF reacted in knee-jerk fashion to NHF’s comments and, alarmingly,even to the mere mention of them. It is apparent that this Committee – like so many of the other Codex committees – plans to implement as Codex standards those standards already adopted by the European Union. Lap dogs were never this obedient.
The National Health Federation plans to oppose these ironically high limits on melamine contaminants. It is ironic because while touting consumer “safety” as its reason for imposing strict maximum upper levels on natural and healthy dietary food supplements in one Codex committee, the European Commission conveniently looks the other way when consumer safety is at risk by a man-made contaminant such as melamine. Unfortunately, though, it is an irony that kills. And until the European Union/European Commission begins to truly represent the interests of its member countries and citizens, many more will suffer and die.
For further information on Codex, please visit the NHF website (Codex):