{"id":10292,"date":"2021-04-21T12:55:34","date_gmt":"2021-04-21T17:55:34","guid":{"rendered":"http:\/\/blogs.edf.org\/health\/?p=10292"},"modified":"2025-07-08T10:01:41","modified_gmt":"2025-07-08T15:01:41","slug":"a-closer-look-at-fdas-closer-to-zero-plan-to-reduce-for-heavy-metals-in-childrens-food","status":"publish","type":"post","link":"https:\/\/blogs.edf.org\/health\/2021\/04\/21\/a-closer-look-at-fdas-closer-to-zero-plan-to-reduce-for-heavy-metals-in-childrens-food\/","title":{"rendered":"A closer look at FDA\u2019s \u201cCloser to Zero\u201d plan to reduce for heavy metals in children\u2019s food"},"content":{"rendered":"

Tom Neltner, J.D.<\/a>\u00a0is the Chemicals Policy Director.<\/em><\/p>\n

This month, the Food and Drug Administration (FDA) released its \u201cCloser to Zero\u201d action plan<\/a> to reduce exposure to heavy metals in foods for babies and young children. The plan, released in response to a recent House of Representatives Committee on Oversight and Reform report and the introduction of the Baby Food Safety Act in both the House and the Senate, is a step forward since it commits the agency to specific actions and general deadlines for the first time. However, there is room for improvement, specifically the agency should:<\/p>\n

    \n
  1. Explicitly consider the cumulative effect of heavy metals on neurodevelopment when setting limits.<\/li>\n
  2. Move up deadlines for draft action levels for arsenic and cadmium;<\/li>\n
  3. Be consistent in messaging that there is no safe level of lead in children\u2019s blood;<\/li>\n
  4. Define what \u201cas low as possible\u201d and \u201cchildren\u2019s food\u201d means as soon as possible;<\/li>\n
  5. Be transparent by posting testing data quickly; and<\/li>\n
  6. Add milestones for compliance verification with action levels and preventive controls.<\/li>\n<\/ol>\n

    <\/p>\n

    FDA\u2019s plan must address the cumulative effect of arsenic, cadmium, lead, and mercury in food<\/strong><\/p>\n

    When FDA announced a new Toxic Elements Working Group following a critical report by the Government Accountability Office<\/a> three years ago, Dr. Susan Mayne, FDA\u2019s director for the Center for Food Safety and Applied Nutrition said the group was \u201ccharged with identifying, targeting, and prioritizing our efforts to achieve the public health goal of reducing exposure to toxic elements to the greatest extent possible.\u201d The point person on the effort, Dr. Conrad Choiniere<\/a>, described it as \u201ctaking a more strategic, global approach — looking at all the metals across all foods rather than one contaminant, one food at a time.\u201d He explained that the agency was focused \u201cfirst on metals like lead, arsenic, cadmium, and mercury in foods, cosmetics, and dietary supplements. These naturally occurring contaminants are present in many of the foods we eat, but can be especially harmful to children because of concerns about effects on their neurological development.\u201d<\/p>\n

    At the time, we applauded<\/a> FDA\u2019s focus on the cumulative effect of these four heavy metals on children\u2019s brain development because they are not exposed to them in isolation. Many individual foods contain more than one, and they are all too common in foods across the diet. FDA\u2019s own Total Diet Study (TDS) data<\/a> as well as Consumer Reports\u2019 2018 report<\/a> and Healthy Babies Bright Future\u2019s 2019 report<\/a> show that many foods have multiple heavy metals. And, as Dr. Choiniere clearly explained, \u201ceven though the levels of a metal in any particular food is low, our overall exposure adds up because many of the foods we eat contain them in small amounts.\u201d<\/p>\n

    Unfortunately, in the Closer to Zero plan issued three years after the working group was created, FDA does not address the issue of the cumulative effects of heavy metals in the diet. Instead, the agency\u2019s milestones address the risk one contaminant at a time, starting with draft action levels for lead by April 2022, arsenic by April 2024, and cadmium and mercury at an undefined later date. The sequential approach makes it difficult to consider the combined effects. Ideally, they would be issued together.<\/p>\n

    In addition, the plan\u2019s research activities and associated milestones do not address the issue. The omission is surprising because the agency\u2019s own scientists have conducted innovative studies<\/a> suggesting that when mercury is present, the adverse effects of arsenic, cadmium, and lead are worse; they also showed that arsenic and cadmium have additive effects. While more research is needed, the data reinforce the need for FDA to expressly account for the cumulative effect when setting limits.<\/p>\n

    We recommend that the agency address the cumulative effect of heavy metals on neurodevelopment by:<\/p>\n