Melamine as a Food Additive - A New Case Study

A new case study was released in October titled "A Case Study of Melamine as a Counterfeit Food Product
Additive in Chinese Human and Animal Food Supply Chain Networks" by Robyn R. Mace

Traceability in the Food Supply Chain and More Melamine...

The Minnesota Department of Agriculture has found melamine in Fortuna brand sugar crackers. How much melamine is unknown at this point. The tainted product was found at Dragon Star market in St. Paul. Customers are urged to throw out any of these crackers that they may have purchased.

If only we could throw out all the regulations that prevent the public from knowing the source of their food. The Fortuna crackers are reported to have been imported to the U.S. by an Indonesian company. But that's probably all we'll know about the crackers. According to a federal report released today, the government conducted tests to determine the effectiveness of the existing tracing system and food supply chain for 40 food items, and determined that most records of what went where and when were woefully light on detail.

The link to the FULL REPORT can be found by clicking here.

Or cut and paste this into your browser.

http://www.oig.hhs.gov/oei/reports/oei-02-06-00210.pdf

"Complete Review" of FDA Ordered

President Obama has ordered a review of the FDA in light of several recent cases of food contamination and safety issues, which included melamine-tainted pet food and infant formula.

Tough Times, Cutting Corners

Shao Mingli, director of China's State Food and Drug Administration is warning that tough economic times might tempt food and drug makers to worry less about product safety and more about their bottom line.

FDA Release Comprehensive List of Tested US Infant Formula

The FDA released a complete list of the US manufactured infant formulas they tested for melamine and cyanuric acid contamination.
The full list can be found that this link.
More from the Daily Green here.

Current Good Manufacturing Practices not revised since 1986

I suppose the results will either highlight (among many other things) that melamine is widely used to process food in plants and that is where previously stated traces in our food come from, that melamine is not widely used to process foods and that is not where traces in food come from, melamine is not widely used to process food therefore the traces are coming from somewhere else, or melamine is not widely used to process foods and their are no reportable traces of melamine in food processed in the US. Assuming the survey of food processing practices also includes surveys of food quality and testing for melamine. The following is from the CFSAN website, posted November 12th.

* U.S. Food and Drug Administration *
* Center for Food Safety and Applied Nutrition *
CONSTITUENT UPDATE
Constituent Updates are also available on the web at http://www.cfsan.fda.gov/~dms/cfsupdat.html.
Announcing a Pretest of FDA's Food CGMP Survey Instrument
In an effort to provide additional protection against foodborne illness, the Food and Drug Administration (FDA) has begun the process of bringing the Federal rules that govern the safe manufacturing, processing, packing and holding of food in the U.S. up to date with modern science and technology. These rules, known as the food current good manufacturing practices, or food CGMPs, describe the methods, equipment, physical plants, and controls for producing safe processed food. They were last revised in 1986.
FDA intends to conduct a statistical survey of some 2,700 large and small domestic food facilities. These facilities will be asked to respond to the survey instrument and may do so either via the Internet or via mail, as they choose. In the next few days, FDA will begin pretesting of the survey instrument. The purpose of the pretest, which will involve sending the instrument via Internet to 50 to 60 facilities, is to ensure that the survey instrument is clear, unambiguous, elicits the information the agency needs and does not impose an undue burden on industry respondents.
The survey will seek information about five key issues relevant to the food CGMP modernization effort:
Employee training
Sanitation and personal hygiene
Allergen controls
Process controls, and,
Recordkeeping.
The results of this survey will assist the FDA in characterizing current food industry practices. While entirely voluntary, industry participation is critical if FDA is to accurately identify safe, cost-effective industry practices for modernized food CGMPs.
Responses to the pretest, as well as the actual survey, will be kept strictly confidential. All data will be collected, compiled, and kept by the independent consulting firm, Eastern Research Group, Inc. (ERG). Responses will be used only for statistical purposes. The reports ERG will prepare on this study will summarize findings across the sample and will not associate responses with a specific company or individual. ERG will not provide information that identifies companies to anyone outside the ERG study team at any time.

++++++++++++++++++++++++++++++++++++++++++++++++++++++++++

CFSAN Constituent Update
- Office of Food Defense, Communication and Emergency Response
- CFSAN Web site: http://www.cfsan.fda.gov/

The "Burden" of Contaminated Food

The New York Times article about the FDA block on Chinese dairy products explains that the manufacturer and their customers will have to test their products and share the results with the FDA in order to clear the product. The article quotes Dr. Steven Solomon, FDA deputy associate commissioner.

“We’re taking this action because it’s the right thing to do for the public health,” said Dr. Steven Solomon, an F.D.A. deputy associate commissioner.
As a result, Chinese products that contain milk or milk powder will be detained until the manufacturer or its customer has the product tested and found to be free of contamination, or they show documentation indicating that the product does not contain milk or milk-derived ingredients.
“The burden shifts to the importer,” Dr. Solomon said.

I don't understand how this is supposed to be reassuring to consumers. Lotte Koala cookies and White Rabbit candies were found on store shelves at a discount weeks after they were found to contain melamine, and we are supposed to feel comfortable knowing that manufacturers and possibly distributors are providing the testing our health depends upon? Manufacturers may already be responsible for adulterating their product - and we are supposed to rely on them for testing? Doesn't the NYT article talk about shrimp producers breading refused shrimp to take advantage of loopholes? I understand that there will be enough food blocked up at the ports to wrap around the earth a few times over. But I don't understand why the FDA isn't doing any testing themselves. Or are they? Although he meant burden of proof, Dr. Solomon's choice of words hit the nail on the head: It's a burden. The FDA sees contaminated food as a burden. Yet it is part of the job that they are supposed to be doing. What about the Import Safety Action Plan? The issue is reliability. Who tests, and who examines the results. Will results be publicized? And is testing done accurately and can consumers rely on it?

Country Of Origin Labeling Needed on Processed Foods

Today's FDA's announcement makes me wonder about the food and feed meeting this criteria that has already entered the U.S. (and other countries) and is part of the channels of trade, i.e., already on store shelves. How are consumers supposed to know what foods contain raw ingredients from China? Does the FDA or another agency have a list of worldwide manufacturers that use Chinese-made raw ingredients? The FDA or other agencies also need to do some testing of food and feed manufactured in the U.S. as well to determine whether melamine is being used as an additive or a binder.

FDA Announces "Countrywide Import Alert"

The FDA announced today that they will be blocking imports of Chinese dairy products, and food and feed products manufactured in China that contain dairy ingredients. This countrywide alert is welcomed news.

It is also good news that the "additional information" the FDA received about the scope of the melamine contamination will compel them to examine non-dairy items as well. While testing of food and feed that contains dairy from China has been the most recent focus, non-dairy ingredients from China such as wheat products, rice protein and vegetable proteins were found to be contaminated with melamine last year (pet food) and recent reports from Hong Kong indicate that Chinese animal feed (hen, fish) have been found to contain melamine as recently as last week. This indicates that the "scope" of the contamination goes beyond dairy. And beyond China. Hopefully the FDA is aware of this and will consider a wider alert that leads to better food safety and more informed consumers. Below is the update from the FDA website, Melamine section:

Update on FDA’s Investigation
November 13, 2008: As part of its ongoing strategy to address the present problem with melamine contamination of consumer products exported from the People’s Republic of China, FDA has expanded its import controls on Chinese dairy products, and food and feed products manufactured in China that contain dairy ingredients. Since Oct. 10, 2008, FDA has had an import alert in place for specific products found contaminated with melamine and melamine-related compounds. FDA has collected additional information on the scope of the melamine contamination problem in China, and determined a countrywide import alert is warranted.
This action will help ensure that only Chinese dairy products and food and feed products manufactured in China that contain dairy ingredients are not contaminated with melamine and melamine-related compounds reach U.S. consumers. No adverse health effects have been reported in the United States from contamination with melamine of dairy products or dairy containing products. But melamine is not approved for direct addition to human or animal foods and no manufacturer is allowed to deliberately add it to any food for U.S. consumers.
As part of ongoing activities, FDA will also examine a range of protein-containing products beyond just dairy and dairy-containing products for contamination with melamine and melamine-related compounds. FDA will continue to take appropriate regulatory action if these efforts uncover additional contamination.

FDA’s Warnings/Advisories
The FDA is advising consumers not to consume the following products because of possible melamine contamination:
Fresh and Crispy Jacobina Biscuits New!
Koala’s March Crème filled Cookies
YILI Brand Sour Milk Drink
YILI Brand Pure Milk Drink
Blue Cat Flavored Drinks
White Rabbit Candies
Mr. Brown Mandehling Blend Instant Coffee (3-in-1)
Mr. Brown Arabica Instant Coffee (3-in-1)
Mr. Brown Blue Mountain Blend Instant Coffee (3-in-1)
Mr. Brown Caramel Macchiato Instant Coffee (3-in-1)
Mr. Brown French Vanilla Instant Coffee (3-in-1)
Mr. Brown Mandheling Blend instant Coffee (2-in-1)
Mr. Brown Milk Tea (3-in-1)
Infant formula manufactured in China

North America imports eggs from China

Thank you to Melamine Blog reader Persephone for pointing out a Wall Street Journal article about eggs from China. The article portrays a chart with figures from the Ministry of Commerce, China, indicating that from January to August 2008 6.5% of eggs exported from China went to North America. The WSJ article was posted on Oct. 31, 2008. I would like to know where in North America those eggs went; I have not read anything more specific yet. Perhaps it's because so many of these eggs were consumed. Similar to what happened with the tainted wheat, pork and chicken last year. It's really a shame. 

When the egg situation was revealed I wanted to know more; to learn everything I could. I didn't know exactly where to start looking for answers about eggs, so on October 27th I wrote to the California Department of Food and Agriculture (since I live in California). I wrote:

I would like to know if California (or other states) import eggs or egg products (including dried eggs) from China, for sale in grocery stores, for use in processed foods by US food manufacturers, or for use in the food service industry. If so, does the CDFA or the USDA have plans to test these eggs for melamine? If so, when will the results be publicized? Also, does the CDFA or the USDA have any plans to require farms in California, and throughout the US, to use animal feed that is free from any melamine or melamine-related additive? Is there a way to find out which egg producing farms use melamine in their animal feed? Thank you for taking the time to answer my questions.

I received two replies from the CDFA; one from the Div. of Inspection Services Egg Quality Control Program:

Thank you for your question. At this time, California imports shell eggs from other states. Egg products such as liquid eggs, dried eggs, (powdered eggs), etc....are handled by USDA's Food Safety Inspection Service (FSIS) and you would need to contact them for the answer to your question. You will be receiving an answer to your feed question from someone in our feed program. If you have any other questions, please contact us. 

and one from the Animal Health Branch:

Our Ag. Code & Regs. only deal with egg quality, labeling, size, & refrigeration. We don't get into cage sizes and animal movement. You can go to the following web sight and go to the shell egg quality control program section. http://www.cdfa.ca.gov/is/regulations.html. You can also try this web site, California producers take part in it. http://www.uepcertified.com/. Thank you, Animal Health Branch.

Wouldn't adulterated eggs - eggs with melamine - be considered "egg quality"? Well, after receiving those replies I wrote to the USDA - specifically the FSIS. I asked the same questions. I have not received any reply.
And I'll be reading and re-reading regulations. Again, thank you for your comments here at the Melamine Blog. Keep them coming.

Food Task Force Created by FDA

Article from Medpagetoday.com
FDA Creates Task Force on International Food Contamination
By Emily P. Walker, Washington Correspondent, MedPage Today
Published: October 31, 2008
GAITHERSBURG, Md., Oct. 31 -- Pointing to the hazards of melamine-containing products from China, the FDA said today it is creating an internal science and policy workgroup to keep a critical eye on the international food supply.
Detecting contamination in the increasingly international food supply is "a necessary job of the FDA," said Randall Lutter, Ph.D., the agency's deputy commissioner for policy, at a meeting of the agency's science board.
And after the melamine contaminations from China -- first in pet food last year, and more recently in milk -- it is vital to develop a strategy for identifying and preventing potential illnesses, he said. (See: FDA Finds Melamine in Asian Milk Drinks)
The workgroup will have the assignment of pinpointing companies that appear to be at a high risk for contaminating the food supply with chemicals.
"There is a fundamental need for us to understand better the economic incentives and cultural norms in other countries," said Dr. Lutter. This, he added, means recognizing when spiking the food supply with chemicals is likely when it means enough extra profit for a manufacturer so that it offsets any potential penalties.
During the recent melamine outbreak, FDA officials suspect that melamine may have been added to infant formula to inflate protein levels cheaply.
In some sectors of the food industry in China, manufacturers are paid by the amount of protein in a product. Melamine costs about $1.20 per each protein count per ton, while legitimate protein costs about $6 per protein count per ton.
Melamine, which is used in some pharmaceuticals, dyes, glues and plastics, is normally not harmful to humans, but when it commingles with cyanuric acid, it becomes insoluble and can cause kidney failure.
"The suggestion is that some clever scientist used a high-quality melamine that did not have cyanuric acid," said Dr. Lutter. "It was only later that the melamine was commingled with the cyanuric acid."
But "forecasting economic infiltration is hard," Dr. Lutter said, and food coming across U.S. borders is shipped from countries with disparate regulatory requirements.
The United States virtually eliminated problem of economically motivated contamination of food produced in its own borders, largely through the creation of the FDA, Dr. Lutter said.
"It's an old problem, but fortunately it was successfully remedied during the early part of the 20th Century," he said.
But then came globalization of the food market.
"It's a symbol that the world we lived in changed, and there is a new vulnerability," Dr. Lutter said.
President Bush signed an executive order last year to establish a task force that recently issued an import safety action plan, Dr. Lutter said.
Dr. Lutter declined to comment on the specifics of the workgroup, but said it will consist of FDA employees. It is unclear whether the workgroup will also monitor possible contamination of foreign drugs.