For children’s food, heavy metals require more attention and better standards

Tom Neltner is Chemicals Policy Director and Michelle Harvey and Maricel Maffini are consultants

In June 2017, EDF released Lead in Food: A Hidden Health Threat. The report examined a decade’s worth of data from the Food and Drug Administration (FDA) and found lead detected in 20% of baby food samples compared to 14% for other foods. Eight types of baby foods, including fruit juices, root vegetables, and teething biscuits, had detectable lead in more than 40% of the samples. We closed the report with the following recommendation:

In the meantime, parents should consult with their pediatrician to learn about how to reduce lead exposure. They should also check with their favorite brands and ask whether the company regularly tests their products for lead, and ensures that, especially for baby food, there is less than 1 ppb of lead in the food and juices they sell.

As described below, we have reason to believe it will take more focused effort on the part of both FDA and food companies to ensure consistently low levels of heavy metals – lead, arsenic, and cadmium in particular – in infant’s and toddler’s diets.

Unraveling FDA data on infant and toddler foods

While preparing our report on lead in food, we filed a Freedom of Information Act (FOIA) request with FDA to obtain brand information regarding the agency’s special study of lead and cadmium in 407 infant and toddler foods publicly released in September 2016. We received that information in November 2017 in the form of 102 spreadsheets and 182 MB of data, which included previously unreleased results for total arsenic and inorganic arsenic in those same foods. (Cadmium and total arsenic are measured using the same assay method as lead.)

The information we received proved to be fairly old; the samples were collected in late 2013 and 2014. This was not evident from FDA’s webpage.

In addition, the sample sizes by brand were often very small. It appeared that FDA was building on its previous sampling of baby food rice cereals for arsenic testing by collecting a broad mix of both rice and non-rice infant and toddler foods.[1] For many brands, FDA obtained only one or two product samples. Such limited samples provide an incomplete picture of the potential variation in heavy metal levels that may occur across an individual product line. A single heavy metal level higher or lower than others may have resulted from an odd lot of raw materials, or it could be the norm.

Given the limitations of the data discussed above, the FDA information provided here should only be viewed as a dated snapshot—and cannot be extrapolated or generalized to specific brands. 

Despite the shortcomings, we decided it was best to make the data available, including the brand information, in part because it is public information. But across the different product types, the data sometimes showed a range of heavy metal levels from low to high. If consistently low levels indicate successful supply chain management practices—rather than statistical anomalies—then consistently high levels represent opportunities for improvement. At a minimum, that variation demonstrates the need for additional investigation and more up-to-date results – and potentially more work on the part of both FDA and food manufacturers.

Outreach to food companies

To learn more about the different supply chain approaches to managing heavy metals, we reached out to each of the brands sampled.

For the roughly 10 percent of companies where EDF had a contact, we reached out directly. For others, we went to company websites for contact information and either sent an email or submitted a webform. Out of 80 companies, there was only one for which we found no contact information or website. We reached out to each company up to three times. Of the 79 companies to whom EDF reached out, 40 – or roughly half – responded in some way. To date, we have had conversations with 17 (22%), including all but one of the major baby food brands. We recognize that our outreach may have not found the right person at an organization; therefore, a company’s lack of response should not be interpreted as a lack of interest in the issue.

In our outreach, we explained that we had FDA data on lead, arsenic, and cadmium in at least one product that appeared to have been manufactured under the company’s label, and that we planned to publicly release the data. We offered to:

• Share their company-specific results;
• Set up a time to review and discuss their results; and
• Provide our initial observations and recommendations.

For those companies with which we spoke, we asked how they manage their supply chain to address lead, arsenic, and cadmium levels, including testing practices. We also offered to include in our release a link to company information relevant to heavy metals management.

In an unexpected twist, we discovered that FDA had never shared the data with any of the companies, and many expressed disappointment that the information had not been provided to them by the agency. Several companies told us that some of the products analyzed were no longer being made or had been reformulated to such an extent that the product sampled no longer existed.

Corporate action varies for heavy metals

Overall, we learned that there is considerable variation in how companies address potential heavy metal contamination. Some do a bare minimum, such as ensuring compliance with standards set by the Codex Alimentarius Commission (CODEX). This is an organization representing 188 countries and the European Union that, as noted in our report on lead in food and other blogs found here and here, does not use health protection as the basis for its lead limits.[2]

A number of companies described ongoing efforts, such as monitoring for and reducing inorganic arsenic in response to previous findings on arsenic or FDA’s draft guidance. PCC Community Markets, a Seattle-based co-op with 11 stores, is a good example of an aspiring leader in this space; they had already reassessed their private label offerings for heavy metals after reading our report last summer. They had also reached out to learn more about how their name-brand suppliers were addressing the issue, but indicated that suppliers weren’t always willing to share details – apparently a frequent challenge.

Another company addressing this issue is Gerber, which described an ongoing and active agricultural and sourcing strategy specifically focused on achieving low contaminant levels. They indicated that efforts had accelerated over the past six years, resulting in changes in suppliers, grower programs, field-level sourcing, and recipes. Noting “considerable resource investment,” Gerber indicated that achieving relationships focused on continuous improvement was worth it. Several companies have expressed interest in continued engagement on the topic, and EDF is following up with those.

For all of the companies with whom we spoke, our recommendations focused on attributes of EDF’s five pillars of leadership. Chief among them was keeping consumers informed:

• Corporate goals on heavy metals should be public, time-bound, and understandable;
• Companies should talk about the systems they have in place to attain goals; and
• Progress should be tracked, preferably reported online, with periodic updates.

We also encouraged companies to increase testing to determine where heavy metals are entering their foods, set targets for heavy metal levels as low as possible, and support stronger federal and international standards that would do the same. While we maintain CODEX’s lead standards are seriously flawed, we do believe that its 2004 Code of Practice for the Prevention and Reduction of Lead Contamination in Foods provides a detailed roadmap for companies to follow. More on this in a future blog.

More action is needed on heavy metals

FDA has recently committed to reducing levels of heavy metals to the greatest extent practicable, publicly acknowledging for the first time that 1) lead, inorganic arsenic, cadmium and mercury affect children’s brain development, and 2) while levels of a metal in any particular food might be low, the agency will consider the cumulative effect of dietary heavy metals on children’s brain development. FDA can accelerate improvement on lead by promoting Codex’s Code of Practice, referenced above, and investigating high levels when found in samples from the Total Diet Study. More on this to follow.

To succeed in its commitment, FDA will also need companies’ cooperation in figuring out how best to remove heavy metals from the food supply chains. That, in turn, will require companies to determine both where heavy metals are entering food products and effective mitigation strategies, from changing raw material sources to revising processing or packaging as warranted.

Because heavy metals were detected in all food categories tested by the FDA, our advice to parents remains the same: consult with your pediatrician, and ask baby food companies to prioritize heavy metal reductions and share their work and results with you. Consider carefully companies that do not.

We fully recognize that reaching out to companies is time-consuming and can be frustrating at best. We spent almost 200 hours trying to reach 80 companies, with a staff member dedicated to follow up and coordination, and our success rate was 49%. It shouldn’t be this hard.

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How to view the spreadsheets:

Click here for a link to the Excel spreadsheets with the data. The first tab provides our explanation of the data. The second is our extract of the FDA’s response to our FOIA. The remaining tabs are FDA’s summary of the data that is online. As you review the data, keep in mind that this is a snapshot of the market approximately four years ago. The data does not necessarily reflect products currently on the market or the levels of heavy metals present in a given brand. Where provided by companies, updated brand information and links to relevant information is included. If you have concerns about a specific brand or product, contact the manufacturer for updated testing information.

[1] EDF asked for but did not receive any indication of FDA’s sampling plan or how they decided a food was for infants or toddlers.

[2] This was made clear when Codex decided to lower the limit for lead in grape juice from 50 ppb to only 40 ppb; it was clearly insufficient.