Environmental of Chapter II

Environmental Contamination of Food

Maintaining an adequate, safe food supply has been a major goal of the Fed- eral Government since 1906, when the first Federal food and drug law was signed into law. Historically, chemicals such as , , and wood smoke have been used to preserve . Modern relies extensively on the use of chemicals not only for preservation but also to produce appealing colors, , aromas, and textures. Most developed countries now have food laws designed to permit the use of such chemicals in food under conditions judged to be safe. These chemicals are not considered or contaminants and are classed as intentional addi- tives. Other chemicals may enter food as a result of their use in food production, handling, or processing. Such substances maybe legally permitted if they are un- avoidable under good manufacturing practices and if the amounts involved are considered safe. These chemicals are classed as incidental additives. The pres- ence of both these classes of chemicals in food is controlled by regulation.

Environmental contaminants include sub- chemicals (l). During the production, use, and stances from natural sources or from indus- disposal of these substances, there are oppor- try and agriculture. Many of the naturally oc- tunities for losses into the environment. For curring contaminants in food are of microbio- example, the Environmental Protection Agen- logical origin and consist of harmful bacteria, cy (EPA) estimates that there are more than bacterial , and fungal toxins. (Aflatox- 30,000 chemical and radioactive waste dis- in, a contaminant of peanuts and grains, is an posal sites. Of these, 1,200 to 2,000 are con- example of a fungal or . ) The sidered threats to human health (2). second category of environmental contami- Environmental contamination of food takes nants includes organic chemicals, metals and two forms: long-term, low-level contamination their complexes, and radionuclides. Only resulting from gradual diffusion of persistent those environmental contaminants intro- chemicals through the environment, and rela- duced into food as a result of human activities tively shorter term, higher level contamina- such as agriculture, mining, and industry are tion stemming from industrial accidents and considered in this assessment. waste disposal. The environmental contamination of food is An example of low-level contamination is a result of our modern, high-technology soci- polychlorinated biphenyls (PCBs). This group ety. We produce and consume large volumes of substances was widely used in transform- of a wide variety of substances, some of ers and capacitors, as heat-transfer fluids, which are toxic. It is estimated that 70,000 and as an additive in dyes, carbon paper, pes- chemicals may currently be in commercial ticides, and plastics (3). Although production production in the United States and that 50 of was halted in 1977, PCBs remain an ubiqui- these chemicals are manufactured in quanti- tous, low-level contaminant of many foods, es- ties greater than 1.3 billion lbs per year. pecially freshwater fish. Seven percent of this country’s gross national product (GNP), $113 billion per year, is gener- An example of the second type of contami- ated by the manufacture and distribution of nation is polybrominated biphenyls (PBBs) in

15 16 . Environmental Contaminants in Food dairy products and meat. PBBs, a fire retard- level contaminant in Michigan because they ant, were accidentally mixed into animal are very stable and resistant to decay. Ani- feed. Dairy cattle that were fed the contami- mals raised on farms affected by the original nated feed produced contaminated milk. The feed contamination are now contaminated by distinctions between the two types of food the PBB residues remaining in the pastures contamination are not exclusive. For exam- and farm buildings. pie, PBBs have now become a long-term, low-

HOW FOOD BECOMES CONTAMINATED

Chemicals contaminate foods through dif- gated railroad cars, trucks, ships, or storage ferent routes depending on the chemical and buildings used for transport or storage of its physical properties, its use, and the source human food and animal feed are also sources or mechanism of contamination. of environmental contamination. The interi- ors are sprayed or fumigated with , Organic substances that have contami- iand if not sufficiently aired, contamination of nated food have been either industrial or 1 the food or feed occurs. agricultural chemicals. Pesticides are the only agricultural chemicals known to be en- The manufacture of organic chemicals pro- vironmental contaminants in food (see tables duces sludges, gases, and liquid effluents of 1-3). A becomes an environmental varying chemical complexities. The usual contaminant when it is present in foods for ,waste disposal methods (sewage systems, in- which the application or use of the substance cineration, landfill) are unable to prevent or- has not been approved. Livestock, poultry, ganic residues from entering the environment and fish can be contaminated when applica- in spite of Federal laws and corresponding tion or manufacturing of pesticides occurs in regulations governing disposal. The routes in- the vicinity or when residues are transported clude the atmosphere, soil, and surface or through the environment. Improperly fumi- ground water.

Table 1.— Reported Incidents of Food Contamination, 1968-78, by State and Class of Contaminant

State Pesticide PCB PBB Other Total New York ...... • ., . 1 1 1 — — 3 Idaho...... 1 2 — 3 South Carolina...... — 1-biphenyl 1 Minnesota ...... — 1 — 1 Louisiana ...... 8 5 4 — 17 Colorado...... 1 1 — 2 Georgia...... 15 — — — 15 Maryland...... — 1 — 2-petroleum 3 Texas ...... — 1 — 1 New Jersey...... 2 1 — 1-ß-methoxy napthalene 4 and tetraline Kansas . . . — (I)* — — (l)* Missouri ...... 4 — — — — 4 New Mexico. . . — 1 — — — Alaska...... (l)* — — — — (:)* California . 1 3 — — — 4 Indiana ., 3 well-documented — 1 — — 9 5 other incidents Michigan. 13 1 2 1 — 17 Virginia, ., ... 1 — — — — 1 Totals ...... 56 19 8 1 4 88 “Several conservatively estimated as one SOURCE Of fLce of Technology Assessment Ch. //— Environmental Contamination of Food ● 17

Table 2.— Reported Incidents of Food Contamination, 1968-78, by State and Food

Fruit/ Game/meat/ State Dairy Eggs Vegetable Fish/shellfish Grain poultry 3 — — 1 — 1 — 1 1 — 9 1 — — — — 3 — 1 — — 2 — — — 1 — — — — 1 2 — 1 — — 1 4 — 4 — — 1 — 27 3 8

Table 3.— Number of Incidents of Environmental Contaminants of Food Reported by Federal Agencies, 1968-78

Agency Pesticides Mercury PCB’s Other Food affected USDA/FSQS 39 — — — Chickens, turkeys. ducks. cattle, swine, lambs — 1 — — Swine — — 6 — Poultry — — — 1 (Phenol) Cattle FDA ... 21 — — — Fish. cheese, pasta — 84 — — Fish — — 3 — Fish, eggs, bakery products Total. . . . 60 85 9 1

SOURCE Off Ice of Technology Assessment

Metals can be released into the environ- operation of nuclear reactors and processing ment in several ways. The mining and refin- plants, and fallout from nuclear weapons ing processes produce dust and gases which tests. The primary route by which food be- enter the atmosphere. Metallic formed comes contaminated is the deposition of air- during recovery and refining processes can borne material on vegetation or soil. The sub- escape as waste products into surface and sequent fate of the radionuclide is deter- ground water. Sewage sludge used as fertiliz- mined by its chemical and physical nature er on agricultural land also poses a potential and whether it is absorbed and metabolized food contamination problem. Trace metals by plants or animals. Natural radioactivity present in the sludge can be taken up by may become a concern when ores containing crops grown on treated soil. is the radioactive substances are mined and proc- trace metal in sludge that currently gener- essed. The products or wastes may concen- ates the greatest concern. trate the radionuclides. Examples of this are uranium tailings, phosphate rock waste, or Radioactivity in food stems from three slags from phosphorus production. Radium sources: natural radioactivity. releases from may enter the food chain when it dissolves in 18 . Environmental Contaminants in Food ground water and is taken up through plant summarizes the radionuclide contaminants of roots. significance for foods. Nuclear reactors normally release radio- Nuclear waste-processing plants could active noble gases that do not contaminate also have either gaseous or aqueous releases. foods. Reactors do contain large inventories In this case, the fission products are aged of fission products, transuranics, and other before processing, and iodine and the gas- activation products. Accidental releases can eous precursor radionuclides are not re- contaminate vegetation by deposition of parti- leased. Tritium and carbon-14 are the major cles on leaves and soil, or through water. Gas- airborne products, while the waterborne ra- eous releases would most likely involve the dionuclides are the same as for reactors. volatile elements such as iodine and tritium, or those with volatile precursors, such as Atmospheric nuclear weapons tests dis- strontium-90 and cesium-137. Aqueous re- tribute their fission products globally. Local leases would follow failure of the onsite ion deposition depends on the size of the weapon exchange cleanup system. Any of the water- and the conditions of firing (high altitude, sur- soluble elements could be involved. Table 4 face, or underground).

Table 4.— Radionuclide Contaminants of Significance for Foods

Normally present in small amounts, Significant only when enhanced Normally present in small amounts Member of uranium series. Normally present, metabolized somewhat Iike calcium As radium-226, only a member of thorium series Members of uranium series Normally present

Product of nuclear reactions

Product of 24’ Pu decay

Low energy, usually in form of water or organic compounds Low energy, usually in form of organic compounds

Short half-life, so important only for fresh foods, e.g., milk and leafy vegetables Follows calcium somewhat in Follows potassium somewhat in metabolism

Most important are isotopes of zirconium, cerium, barium, rubidium, rhodium. Mostly surface contaminants

Follow stable elements in metabolism Ch. //— Environmental Contain/nation of Food ● 19

MAGNITUDE OF THE PROBLEM

There is little information available on the edge and the extent of uncertainties on the number of food contamination incidents, the health effects of these environmental con- amount and costs of food lost through regula- taminants. tory actions, or the effects of consumption of contaminated food on health. To obtain infor- Polychlorinated Biphenyls mation on the extent of the problem, OTA re- viewed the literature and sought information PCBs occur in food as the result of environ- from the States and Federal agencies. mental contamination leading to accumula- tion in the food chain, direct contact with Evidence of Human Illness food or animal feeds, or contact with food- packaging materials made from recycled pa- Resulting From Consumption of per containing PCBs (5). Several comprehen- Contaminated Food sive literature reviews have been published In evaluating the significance of environ- in the last 5 years detailing the acute and mental contaminants in food the key question chronic toxic effects of PCBs in animals and is whether consumption of contaminated humans (5-1 1). foods poses a health risk. Measurable health Human illness has been caused by expo- effects depend on the toxicity of the sub- sures to PCBs at much higher levels than stance, the level at which it is present in food, those that occur in the United States. In the the quantity of food consumed, and the vul- early part of 1968 the accidental contamina- nerability of the individual or population. In tion of edible rice-bran oil led to a poisoning Japan, foods contaminated with substances epidemic among the Japanese families who such as PCBs, mercury, and cadmium have consumed the oil. The disease became known produced human illness and death. No such as Yusho or rice-oil disease. Its chief symp- mass poisonings have occurred in the United toms were chloracne (a severe form of acne) States. However, in cases such as PBBs and eye discharge; other symptoms included where a large populace has been exposed, skin discoloration, headaches, fatigue, ab- some physiological changes have been noted. dominal pain, menstrual changes, and liver But no conclusions can as yet be drawn on the disturbances. Babies born to mothers who ultimate health effects. consumed the rice oil were abnormally small It is known from limited surveys that the and had temporary skin discoloration. The U.S. population is exposed to a wide variety first symptoms of Yusho disease were regis- of chemical contaminants through food, air, tered on June 7, 1968, and 1,291 cases had and water. The long-term health effects and been reported as of May 1975 (9). the implications of possible interactions Since the rice oil was also contaminated among these residues are unknown. A recent with polychlorinated dibenzofuran (PCDF), it literature review of over 600 published is difficult to determine from the Yusho data studies (4) found that nonoccupationally ex- exactly what effect(s) exposure to PCBs alone posed U.S. residents carry measurable resi- could have on humans. It has been calculated dues of 94 chemical contaminants. Twenty- that the PCDF made the rice oil 2 to 3.5 times six of these are organic substances, including more toxic than would have been expected twenty pesticides and pesticide metabolizes. from its PCB content alone (1 1). Careful rec- The remainder are inorganic substances. ords of the 1,291 Yusho patients have been Americans also have been exposed to low kept to determine possible long-term effects. levels of PCBs, PBBs, mercury, and ionizing At least 9 of 29 deaths that occurred as of radiation through their food. The following May 1975 were attributed to (malig- sections briefly summarize current knowl- nant neoplasm), but a causal relationship be- 20 ● Environmental Contaminants in Food tween PCBs and cancer cannot necessarily peninsula excreted PBB in their breast milk be inferred because of the high concentration (20). of PCDF in the oil. The Yusho study, neverthe- less, had two important results: first, the in- Low concentrations of PBBs also have been formation established that PCBs can be trans- detected in animal feed in Indiana and Illi- ferred from mother to fetus and from mother nois. Unconfirmed surveys of food throughout to child through breast feeding, and second the country found extremely low levels below highly chlorinated PCB compounds are ex- the Food and Drug Administration (FDA) ac- creted more slowly from the body than less tion level in the following States (21): chlorinated ones (9). State Food Alabama. ., ...... Chicken More recent experiments in animals have Indiana...... Turkey demonstrated a variety of toxic effects. Iowa , ... , ...... Beef have been produced in mice and rats Mississippi...... Chicken fed PCBs (6, 12). Monkeys fed levels of PCBs New York ...... , . . . . Chicken equivalent to the amounts consumed by Yu- Texas ...... Chicken sho patients developed similar reproductive Wisconsin ...... Duck disorders (13-16). Young monkeys nursing on Wolff, et al. (22) reported that serum PBB mothers consuming feed containing PCB de- was higher for males than females. It was veloped toxic effects and behavioral abnor- suggested that the greater proportional body malities (15-1 7)0 in women may account for this difference, but exposure may also be important. Males Polybrominated Biphenyls may consume more contaminated food or have more direct contact with PBB than Practically every Michigan resident has females. been exposed to PBB-contaminated food prod- ucts. It is estimated that some 2,000 farm The same study found no consistent trends families who consumed products from their with respect to age. It was observed, how- own PBB-contaminated farms have received ever, that young males had greater concen- the heaviest exposure (18). trations of serum PBB than young females. Young females had greater concentrations Fries (19) studied the kinetics of PBB ab- than older males, and older males had sorption in dairy cattle and its elimination in greater concentrations than older females. It milk, If intake of contaminated milk alone is was also found that very young children and considered, those Michigan residents most individuals who had lived on farms less than severely exposed consumed from 5 to 15 1 year had lower serum PBB levels than other grams of PBB over the initial 230 days of the groups (22) exposure. Those residents that coincidentally 0 consumed contaminated meat and/or eggs Serum PBB concentration is related to the may have received higher total doses of PBB, intensity of exposure. Most studies indicate but the number of such cases is probably that consumers and residents of nonquaran- small, tined farms had significantly lower PBB lev- els than residents of quarantined farms; how- Geographically the residents of the lower ever, families on quarantined farms stopped peninsula, where the original accident oc- consuming meat and milk from their own ani- curred, were found to have the greatest levels mals (20) of exposure. In 1976, the Michigan Depart- 0 ment of conducted a study on In late 1974, the Michigan Department of PBB concentrations in breast milk. It was Public Health conducted a survey to deter- found that 96 percent of the 53 women mine if any adverse effects could be corre- selected from the lower peninsula and 43 per- lated with PBB levels in the body, A sample of cent of the 42 women selected from the upper 165 exposed persons (quarantined farms) Ch. Il—Environmental Contamination of Food ● 21

and 133 nonexposed (nonquarantined farms) Mercury and Methylmercury was studied. Medical history interviews and Foods are the major source of human expo- physical examinations were performed on sure to mercury. The mercury concentration each subject and blood specimens were in food is dependent on the type of food, the taken, Blood PBB levels as high as 2.26 parts environmental level of mercury in the area per million (ppm) were found in the exposed where the food is produced, and the use of individuals; about half exhibited levels mercury-containing compounds in the agri- greater than 0.02 ppm. Of the nonexposed in- cultural and industrial production of the food. dividuals, only two showed blood PBB levels All living organisms have the ability to con- greater than 0.02 ppm; 70 percent of the centrate mercury, Therefore, all animal and adults and 97 percent of the children exhib- vegetable tissues contain at least trace ited levels of 0.0002 to 0.019 ppm. Compar- amounts (26). Several recent reviews have ex- ison of a list of selected conditions and com- amined the health effects associated with plaints revealed no significant differences in consumption of mercury (26-28). The results the frequency of illness between the two of these reviews indicate that the effects of groups. Physical examinations and clinical methylmercury poisoning become detectable laboratory tests disclosed no effects attrib- in the most sensitive adults at blood levels of (24). utable to “chronic” PBB exposure mercury of 20 to 50 µg/100 ml, hair levels The effect of PBB exposure on white blood from 50 to 120 mg/kg, and body burdens be- cell (lymphocyte) function of Michigan dairy tween 0.5 and 0.8 mg/kg body weight (26). farmers who consumed contaminated farm products was examined by Bekesi, et al. (25). Since the Minamata Bay tragedy in Japan, Forty-five members of Michigan farm fami- the effects of chronic exposure to methylmer- lies who had eaten PBB-contaminated food cury have been well-documented. Mercury for periods of 3 months up to 4 years after the readily accumulates within the central nerv- original accident were compared for immuno- ous system (29-3 1), and clearance of mercury logical function to 46 Wisconsin farmers and back into the bloodstream is slow (32). Conse- 79 New York residents. All of the exposed in- quently, the central nervous system is consi- dividuals showed reduced lymphocyte func- dered to be the critical target in chronic mer- tion, and 40 percent showed abnormal pro- cury exposure. The clinical symptoms of cen- duction of lymphocytes. There were also sig- tral nervous system involvement include nificant increases in lymphocytes with no de- headache, vertigo, vasomotor disturbance, tectable surface markers (“null” cells). How- ataxia, and pain and numbness in the ex- ever, the short- and long-term health implica- tremities (30). The most prominent structural tions of these differences are not now known. changes of the central nervous system result- ing from chronic mercury exposure are dif- Lillis (20) examined Michigan farmers and fuse cellular degeneration (30). consumers of dairy products and found that the effect of PBB on humans was mainly neu- In evaluating the teratogenic hazards of rological in nature. He found marked fatigue, mercury exposure to man, the placental hypersomnia, and decreased capacity for transfer of mercury is particularly signifi- physical or mental work. Other symptoms in- cant. Levels that are not toxic to pregnant cluded headache: dizziness: irritability; and women are sufficient to produce birth defects in their offspring (33-35). Transfer of methyl- swelling of the joints with deformity, pain, mercury across the human placenta results and limitation of movement. Less severe gas- in slightly higher blood levels in the infant at trointestinal and dermatological complaints birth than in the mother (36). Table 5 com- were also encountered. pares fetal and maternal blood concentra- 22 ● Environmental Contaminants in Food

Table 5. — Methylmercury Concentrations in tion exposure on health are extremely diffi- Normally Exposed Populations — cult to evaluate. High dose rates (100 million Concentration (µg Hg/g) to 1 billion times background) are estimated Location Maternal blood Placenta Fetal blood to produce 2,600 ionization events per second Japan ...- – ‘ - 0.017 0.072 0.020 in cells. Background radiation levels are esti- Sweden ...... 0.006 — 0.008 mated to produce less than one ionization in Tennessee. . . 0.009 0.021 0.011 lowa. . . . . 0.001 0.002 0.001 the cell nucleus per day (37). Because cells SOURCE Adapted from B J Koos and L D Longo ” Mercury To; IcIty In the have the capacity to repair damage to their Pregnant W’oman, Fetus, and Newborn Infant “ A rner(can ,/ourrra/ of Obstetrms and Gynecology 126(3) 390, 1976 genetic material, repair of ionization damage may occur at low radiation exposure. Higher tions in normally exposed populations in exposures may overwhelm the cells’ repair Japan, Sweden, and the United States, capacity. Whether any effects are observed In humans, the most widely reported fetal in such cases depends on several factors. These include the dose delivered to the tis- risk associated with maternal exposure to sues, the nature of the emissions, and the me- mercury is brain damage. The placental tabolism of the cell. The following examples transfer of mercury and its effects on the illustrate these points: human fetus were first recognized in the 1950’s with the well-known outbreak of con- Strontium-90 in food arouses most con- genital in the towns of cern not only because of its long half-life Minamata and Niigata, Japan. By 1959, 23 in- but also because it behaves in the body fants suffering from mental retardation and in a manner somewhat similar to calci- motor disturbances had been born to mothers um. The replacement of bone calcium exposed to methylmercury during their preg- with strontium-go exposes tissues and nancies. The clinical symptoms of the infants cells covering the bone to radiation, In resembled those of severe cerebral palsy or addition, bone marrow is subject to the cerebral dysfunction syndrome. They in- ionizing radiation from the strontium-go. cluded disturbance of coordination, speech, Thus, cancer of the bone-forming and and hearing; constriction of visual field; im- bone-covering tissue as well as leuke- pairment of chewing and swallowing; en- mias of the bone marrow blood-forming hanced tendon reflex; pathological reflexes; cells can possibly result. involuntary movement; primitive reflexes; su- Iodine is concentrated by the thyroid perficial sensation; salivation; and forced gland. Radioiodines produced in atmos- laughing (30). Only 1 of the 23 mothers exhib- pheric nuclear detonations or released ited any symptoms of mercury poisoning (32). from nuclear power stations are also taken up and concentrated by the thy- Radioactivity roid, increasing the risk of thyroid cancer. Ionizing radiation (X-rays, gamma rays, or Tritium, or radioactive hydrogen, com- beta particles with sufficient energy to strip bines chemically with oxygen to form electrons from molecules and produce ions) water. Tritium derived from food would can produce birth defects, mutations, and be widely distributed throughout the cancers (37). These adverse health effects body exposing all tissues to radiation. are usually associated with high dose levels delivered at high dose rates. The uncertainties surrounding the repair Such a combination is not ordinarily en- capacities of cells and the irreversible nature of the possible health effects have led to the countered in food. Previous radioactive con- tamination of foods has involved relatively adoption in the United States of a prudent policy toward low-level ionizing radiation. small quantities of radioactive elements which have delivered low dose rates (38). Since any amount of radiation is potentially harmful, unnecessary exposure should be In these situations, the effects of the radia- avoided. Ch. //—Environmental Contamination 01 Food ● 23

Number of Food Contamination tal contaminant incident since 1968 for a Incidents total of 88 incidents. All food categories were involved and a variety of substances were im- Questionnaires were mailed to the commis- plicated (see tables 1-3). sioners of health in each of the 50 States and the District of Columbia as well as to Federal The data provided by States are comple- agencies. For the 10-year period 1968-78, mented by the Federal responses. The two each was asked to report on the number of in- Federal agencies responsible for regulating cidents of environmental contamination of the Nation’s food supply reported the number food that resulted in regulatory action. This of environmental contamination incidents survey has limitations. Some States did not that they had identified since 1968. FDA had answer all questions. The questions were 108 reported incidents, and the subject to interpretation and misunderstand- and Quality Service of the U.S. Department of ing. The accuracy and completeness of the Agriculture (USDA) had 47 reported inci- answers were dependent on the respondent. dents (see table 3). The combined Federal and The results presented are therefore prelimi- State total number of incidents comes to 243. nary and do not necessarily represent com- Neither State nor Federal responses indi- plete and comprehensive information on all cated any significant radionuclide contam- States responding. Nonetheless, these data ination episodes during the 1968-78 period. are the first to be developed on the extent of Extensive Government programs for monitor- environmental contamination of food. ing radionuclides in food exist. Thus far, ra- Responses were received from 32 States. dionuclide contamination of food has not been Seven of the top ten agricultural States and found to exceed the exposure limits recom- six of the top ten manufacturing States re- mended in the Federal Radiation Council Pro- sponded to the questionnaire, The agricultur- tective Action Guides. In most cases, the al States in the top 10 were California, Texas, amount of food contamination in the conti- Minnesota, Nebraska, Kansas, Indiana, and nental United States has never even ap- Missouri. The manufacturing States in the proached these limits (39), While atmospheric top 10 were California, New York, Michigan, nuclear testing is less a threat today than New Jersey, Texas, and Indiana. Three of before the signing of the 1963 Test Ban Trea- these States—California, Texas, and Indi- ty, radionuclide contamination of food is still ana—are in the top ten for both agricultural a concern of both Federal and State govern- and manufacturing production. A fairly rep- ments. resentative distribution of States responded from each region of the United States (figure The number of food contamination inci- 2). dents reported to OTA does not represent the total number that has occurred in the United In the following discussions, an incident is States, only those in which the Federal Gov- defined as a case in which a Federal or State ernment and 18 State governments have ta- agency has taken regulatory action against ken regulatory action. Many incidents never contaminated food, The Michigan PBB epi- come to the attention of State or Federal sode is reported as one incident because the authorities. This is because local government contamination stemmed from one source and officials can and do handle environmental was limited to one State. Mercury contami- contaminant incidents by warning offenders nation is reported as separate incidents be- or by condemning contaminated products cause the sources differed (environmental without informing the appropriate State offi- mercury v. industrial waste), the States in- cials. Also, the farmer whose livestock or volved are widely separated, and regulatory poultry has been environmentally contami- actions were taken at different times, Eight- nated may negotiate directly with the firm re- een States reported at least one environmen- sponsible for the contamination for financial 24 . Environmental Contaminants in Food

u) Ch. //— Environmental Contamination of Food ● 25

reimbursement without reporting the con- ence in the environment can mean food con- tamination to Federal or State officials (40). tamination above the action level or tolerance for many years after the source of the pollu- Economic Impact tion has been stopped. The James River in Vir- ginia, for example, is still closed to commer- The economic impact of an incident involv- cial fishing several years after kepone dis- ing the environmental contamination of food charges into the river have been eliminated. includes the cost of condemned food, health The relative influence for each of these fac- costs, and the corresponding distributional tors on the final cost will vary in each con- effects and costs. The magnitude of the eco- tamination incident. nomic impact is determined by: Estimates of the cost of food condemned the amount of food contaminated, through regulatory action are most often ex- the concentration of the contaminant in pressed in dollars. Consequently, this cost is food, usually (and incorrectly) cited as representa- the chemical and toxicological charac- tive of the total economic impact. Such costs teristics of the contaminant, and were collected in OTA’s State and Federal the corresponding regulatory action surveys. The data, however, only partially re- taken on the contaminated food. flect the total economic impact for environ- The initial regulatory action taken by Fed- mental contamination of food in the United eral and State authorities may be the issu- States. This is because the cost of condemned food is only one component of the total eco- ance of a warning or the establishment of nomic impact of an incident. In addition, few either an action level or a tolerance. A more of the incidents reported to OTA included detailed discussion of this regulatory action is presented in chapter III. Action levels and tol- data on the cost of food condemned. OTA esti- mates from the available data that the total erances establish a permissible level for the cost of condemned food as a result of environ- contaminant in food. Any food found to con- mental contamination in the United States tain concentrations of the substances above 1968 is over $282 million (table 6). this level is condemned and either destroyed since The or restricted from being marketed. only cost estimates used were those clearly stated for an incident by the reporting States or Federal agencies. Costs of Food Condemned State Estimates. —Of the 18 States report- In addition to the four factors listed above, ing contamination incidents, only 6 provided the cost of condemned food is also affected by data on the economic impact in dollar terms. its position in the food production and mar- Of those six, Michigan represents 99 percent keting process at the time of condemnation, of the total cost ($255 million) while reporting An action level or tolerance for a contam- only 19 percent of the number of incidents in inant is the most important of the five factors. the 18 States. Indeed, Michigan accounts for If no action level or tolerance is set, no food 90 percent of the total costs reported in the would be condemned and thus there would be United States while reporting only 7 percent no costs incurred. The impact of such a reg- of the incidents that occurred during the ulation will depend on the exact level of a 1968-78 period. It must be recognized, how- substance that is allowed to be present in ever, that 84 percent of Michigan’s costs are food, attributed to the PBB incident. Many inci- The chemical properties of a contaminant dents reported by State and Federal agencies are also important because of the potential are considerably smaller than the PBB epi- for long-term effects on the amount of food af- sode. Thus, the PBB episode is an indication fected. Since many contaminants biologically of how severe a contamination incident can and chemically degrade slowly, their pres- be. 26 . Environmental Contaminants in Food

Table 6.—Economic Impact of Food Contamination Food Safety and Quality Service (FSQS) re- —————— ————— — ported food condemnation cost estimates. Reported incidents Total estimated cost ($) These estimates, however, only cover live- State Idaho. . . $ 100,000 stock and poultry—the food products over PCP 3,000 which FSQS has regulatory authority. FDA, Colorado. . . . Dieldrin 100 which has regulatory authority over the re- Mercury 3,700 Maryland, Mercury 23,000 maining food commodities, did not estimate Texas. . . Mercury 85,000 costs for reported environmental contamina- Indiana . Dieldrin 25,027 tion incidents (70 percent of the Federal Dieldrin 250,000 Michigan. Mercury 10,000,000 total). Thus, a significant proportion of the PCB 30,000,000 total costs for environmental contamination PCNB 100,000 incidents requiring Federal action is un- PBB 215,000,000 Picloram 12,000 known. Comparison of the two agency re- Chlordane 2,500 sponses with the State responses reveals lit- DDT 2,000 tle duplication in the reporting of incidents. Toxaphene 2,000 Parathion 328 Diazinon 13,700 FSQS cost estimates were determined by Pentachlorophenol 28,468 the number of animals or pounds destroyed PCB 150,000 Dieldrin 12,500 multiplied by the market value at the time of confiscation. Since most of these animals $255,813,323-- Federal were taken at the farm or wholesale level, the USDA/FSQS Pesticides 18,900,000 market value was the farm or wholesale Mercury 63,000 PCB 7,450,000 price. Most of the losses resulting from FDA Phenol —350 —— actions would be based on a wholesale or re- 26,413,350 tail price because the seized products had ad- Total United States ...... $282,226,673 vanced further in the marketing system. Therefore, their estimated costs would be SOURCE Off Ice of Tec;n810gy Assessment greater than if they were seized at the pro- duction level (generally the case with FSQS Some States reported the amount of food seizures). destroyed without estimating the cost. Ken- tucky, for example, reported the destruction Summing up, the available data on the cost of 400,000 lbs of milk since 1968 because of of condemned food is limited; consequently pesticide contamination. While such informa- OTA’s $282 million condemned-food estimate tion can be converted into dollars, data on is likely to be a gross underestimation of the market position and price of product at time actual costs. The true cost would be impossi- of confiscation are not readily available. ble to estimate from this limited sample. Many States were unable to provide any esti- mates on either the cost or the amount of food condemned as a result of reported contami- Health Costs nation incidents. New York (with PCBs) and Health costs are also an important compo- Virginia (with kepone) are two States that nent of economic impact. These costs are in- could not provide cost estimates for food con- curred by the consumer whose health has or demned as a result of environmental contami- potentially can be affected adversely by a nation. Virginia, however, has initiated a contaminant present in food. These adverse study to determine the economic impact of the effects can cause illness and death, and the kepone incident. range of effects will vary depending on the Federal Estimates.—Of the two Federal toxicity of the contaminant, the concentration agencies reporting information to OTA on en- of the contaminant in food, and the amount of vironmental contaminant incidents, USDA’s food consumed. Ch II—Environmental Contamination of Food s 27

In this country, the concentration of con- Producers.— Food producers are affected taminants has been at levels that have not economically in different ways by contamina- produced immediate measurable and conclu- tion episodes. But all are affected directly sive effects in exposed populations. Estimates when the food they produce is condemned. are therefore made for the potential long- For example, food found contaminated at the term effects on exposed populations from farm level is confiscated and destroyed. This various contaminants in food. was the case for over 500 Michigan farmers whose dairy herds were partially or entirely Health costs can be estimated from such destroyed (41). In such cases, farmers either projected health effects. Costs would include replace their livestock, plant a new crop, or health care costs for treating illness and go out of business. burial expenses associated with death. Addi- tional costs would include estimated value of Farmers can be faced with severe econom- productive days or years lost from work due ic hardship, since they are not always reim- to the projected illness or death associated bursed financially for the animals or com- with the contaminant in food. All of these modities confiscated. While insurance pro- health-related costs, however, do not and grams such as the Federal Crop Insurance cannot include the emotional and psycholog- Corporation are available to cover natural ical impacts on those afflicted and their hazards which might destroy crops or live- friends and families. stock, such Federal assistance is not avail- able to farmers for losses from environmental Health costs are not available for previ- contamination. An injured farmer can obtain ous U.S. food contamination incidents. Ap- a loan at commercial rates or sue the respon- proaches and techniques for estimating sible firm for compensation. But the loan and health costs are discussed in chapter VI. the interest add to a farmer’s financial dif- ficulties, and suing for compensation can take Distributional Effects and Costs time that the farmer may not have. Distributional effects and costs involve the The commercial fisher is faced with a dif- various people, groups, and organizations ferent situation. If a river, lake, or species of who are economically affected by an environ- fish is restricted because of environmental mental contamination incident. Information contamination, the fisher whose source of in- on the extent and distribution of such effects come depends on this species or waterway and costs provides a clearer picture of the may have few employment alternatives. The total economic impact on society. This infor- alternatives depend to some degree on the ex- mation is usually couched in descriptive tent of the contamination. If the only water- terms. Those who are economically affected way available in a section of a State or a are identified but the extent of the impact is whole State is closed to commercial fishing seldom estimated in dollars. The exact distri- because of the contamination, the fisher’s bution of costs from an incident through soci- source of employment is eliminated until the ety is affected by the same five factors that restriction is ended. Since the restriction can influence the cost of condemned food. last for years (depending on the chemical sta- bility of the contaminant), the fisher either Many of the distributional effects and will have to move to other commercial fishing costs for various types of environmental con- areas or seek other employment. taminant incidents are discussed in the fol- lowing sections. The purpose of this discus- Food producers economically affected by sion is not to identify all the distributional the condemnation of contaminated food are costs but rather to demonstrate the variety of likely to incur health costs. This is because effects and costs that can result from an inci- many of the producers and their families reg- dent. ularly eat the food that they produce or har- 28 . Environmental Contaminants in Food vest. Consequently they are exposed to the handle the kind of long-term problems cre- contaminated food at greater concentrations ated by a PBB or kepone incident. The Michi- than the average consumer. This was the gan Department of Agriculture, for example, case for several farm families in Michigan. estimates it will spend $40 million to $60 mil- lion within the next 5 years to monitor and Firms Held Accountable for Environmen- test for PBBs in animals and animal byprod- tal Contamination.—In most instances blame ucts (44). This is money that could have been for a contamination incident can be estab- saved or spent for other programs if PBB con- lished. Those accountable are subject to fines tamination had not occurred. In order to re- and lawsuits. Firms admitting responsibility cover its expenses from the PBB incident, the often try to settle with producers out of court State of Michigan filed a lawsuit against both if possible. Most of the compensation is for the Michigan Chemical Corporation and the economic damages stemming from the de- Farm Bureau Services, Inc., claiming more struction of food or loss of employment. Com- than $100 million in damage (45). pensation for people whose health has been impaired as a result of eating contaminated Federal involvement is limited unless the food would be sought through civil litigation. contaminated food is part of interstate com- Such litigation, however, is rare in this coun- merce, Many of these incidents are not con- try, since the level of contamination in food is sidered by the Federal Government to involve so low that demonstrating the necessary interstate commerce, FDA may provide tech- cause and effect is difficult. nical assistance at the request of the State Fines or compensation paid by the firms government when a contamination incident is regarded to be a local problem (43). These held accountable for the contamination are, technical facilities and experts are available in fact, poor indicators of the true costs in- to all States through the Federal and regional curred by the producers. This is because the offices. Additional expenditures by the Fed- settlement costs which are frequently negoti- eral Government for contamination incidents ated or imposed bear little relationship to the are limited. Additional State expenditures, actual costs incurred. however, can be substantial. Federal expend- For example, compensation has been pro- itures are made when Federal regulations vided by Michigan Chemical Corporation and are developed and promulgated for particu- Farm Bureau Services, Inc., to many of the lar contaminants in food such as PCB. farmers whose livestock and poultry were de- stroyed following PBB contamination. Mich- Consumers. —Consumers can incur costs igan Chemical and Farm Bureau Services from an environmental contaminant incident have together paid more than $40 million in in several ways. The removal of food from compensation from a jointly established in- commerce could increase prices for that food surance pool (42). In another case involving product or other food products being sold. PCB-contaminated fish meal sold to poultry Thus, the consumer could pay more for food producers, Ralston Purina Company negoti- as a result of an environmental contamina- ated compensation for the 400,000 chickens tion incident. In order for this price increase destroyed. The cost of the compensation has in food to occur, however, a significant not been disclosed (43). amount of a food product or food products would have to be taken off the market. Such Governments.— Federal, State, and local prices of food might vary by State or region governments also incur costs from an envi- and affect certain socioeconomic classes dif- ronmental contamination incident. Although ferently. the Federal Government and most State gov- Health costs could increase as a result of ernments have agencies with programs to the consumption of contaminated food. This regulate or control food safety problems, would not affect all consumers but rather these programs usually are not funded to those who received the most exposure and/or Ch. II—Environmental Contamination of Food ● 29

those most susceptible to a contaminant, such ple, a bait and tackle store on a lake that is as children or senior citizens. While these closed to commercial and sport fishing be- costs would already be included in estimated cause of an environmental contamination is total health costs, the distributional effects likely to suffer economic hardship, Food proc- could indicate those consumers most likely to essors whose normal supply of food has been be affected. condemned because of environmental con- Indirect Costs. —Most of the costs men- tamination will also suffer economically un- tioned directly stem from an environmental less they find new sources of supply. These contamination incident. However, indirect or are just two examples of the many indirect secondary costs can and do occur. For exam- costs which might occur.

Because a limited number of substances tential hazard and 2) by surveying the uni- posing health problems already have been verse of industrial chemicals and ranking identified in food, concern exists that other them according to their potential for entering toxic substances are likely to contaminate the food supply in toxic amounts. These meth- food in the future. This concern arises from ods are discussed in more detail in chapter the number of substances presently being VII, “Monitoring Strategies. ” manufactured, used, and disposed of in the United States, and the difficulties in prevent- Of the three categories of environmental ing them from entering the environment. New contaminants considered in this report, or- substances developed to meet new needs or to ganic chemicals probably pose the greatest replace known toxic substances may create potential environmental and food contamina- unexpected environmental problems if not tion problems. This conclusion is based on the properly controlled. Byproducts of new tech- number, volume, and toxicity of the organics nologies such as synthetic fuels are also po- manufactured and used in this country (40). tential environmental contaminants. These Both trace metals and radioactive substances are described in appendix A. continue to warrant concern, but not as great There are two methods of objectively as- a concern as organic substances. The extent sessing possible future contaminants: 1 ) by of food contamination from these substances sampling the food supply for chemical con- depends on our success in preventing them taminants and ranking them according to po- from entering the environment.

CONCLUSIONS AND ISSUES

Data presented here indicate that environ- health risks were considered unacceptable. mental contamination of food is a nationwide These episodes have resulted in economic problem of unknown magnitude. Long-term, losses when contaminated food was removed low-level exposure to toxic substances in food from the market, poses health risks that are difficult to The following chapters analyze several evaluate given present techniques. Incidents issues related to the regulation of environ- of high-level contamination of food that cause mental contaminants in food. These are: human illness have not occurred in the United States, However, regulatory actions have Q Is our present regulatory system protect- been taken to restrict consumption of con- ing the public health? (Chapters 111 and taminated food in cases where the potential IV) 30 . Environmental Contaminants in Food

● Are methods used by the regulatory how should economic impacts be evalu- agencies for estimating health impacts ated? (Chapters III and VI) the most appropriate ones? (Chapters III and V) c Should regulatory monitoring be capable ● Should economic impacts be an explicit of detecting substances as they enter the part of regulatory decisionmaking? If so, food chain? (Chapters VII and VIII)

CHAPTER II REFERENCES

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