Maximum allowable limits | Sumfood

Posted in Clean Eater, Consumer, Food Security, Food Systems, Locavore, Low Carbon Eater, Vegetarian on Nov 12, 2018

Or, how much poop are you allowed in a scoop?

National and international regulatory bodies set guidelines for food production, storage, transportation and sale. As part of these regulations, they identify what the allowable amount of contaminants are for different food groups and it may come as something of a surprise to know that the food we eat is not ‘sterile’.

Natural contamination occurs and that somewhere, possibly in a basement laboratory, food scientists have determined that an average of 6 rodent hairs in 25 gm of ground capsicum is a level that warrants action (5 rodent hairs is ok). This all seems a bit yuck and a bit arbitrary but the Food and Drug Administration (FDA, Code of Federal Regulations, Part 110.110) allows the FDA to “establish maximum levels of natural or unavoidable defects in foods for human use that present no health hazard The FDA set these action levels because it is economically impractical to grow, harvest, or process raw products that are totally free of non-hazardous, naturally occurring, unavoidable defects.”

The action by the FDA recognizes that natural production methods are not flawless and, as we see increasing consumer demand for natural products, it is perhaps timely to be reminded that natural production is more difficult to control – if we want sterile products then we need to be looking in a different aisle in the supermarket. Contamination can occur at any stage of the food production system, for example, pre-harvest through insect infestation of plant material or post-harvest rodent contamination could occur.

Recognition that it is difficult to control every aspect of food production means that we need to know what an acceptable limit is, and what is not. Acceptable in this sense means that the contamination does not impact on human health. It is also important to note that as scientific methods improve the ability to detect contaminants will also improve. This could lead to revised acceptable limits and identification of new contaminants. The FDA’s levels are recorded as action levels whereby if the contaminant is detected at that level or higher then action will be taken against the producer, supplier or processor.

Some of the more interesting action levels include an average of one or more insect (or insect equivalent, that is, parts of insects) per 50 gm of cornmeal or an average of 100 or more insect fragments per 25 gm of curry powder. Fig paste cannot contain an average of 13 or more insect heads per 100 gm and wheat cannot have an average of 9 mg or more of rodent excreta pellets or fragments per 1 kg.

Perhaps, however, the best number to throw out around the watercooler is the action levels for canned or dried mushrooms. Firstly, a disclaimer. Mushrooms are a great source of protein and fibre and white button mushrooms are a good non-animal source of vitamin D. Secondly, the mushroom fly, the mushroom phorid, cannot feed nor survive on anything other than fungal mycelium (i.e. mushroom) and, according to entomologists at Penn State University, neither the adults nor the larvae are known to cause human health issues. Armed with knowledge that mushrooms are good it’s interesting to note that the FDA take action when they identify an average of over 20 or more maggots of any size per 100gm of drained mushrooms and proportionate liquid or in 15 gm of dried mushrooms. However, for slightly larger maggots (2 mm or longer), action is taken after an average of 5 or more maggots per 100 gm.

While the FDA rules are designed to protect human health and the action limits are set, it does beg the question of who decided these limits, and what the science is behind the limits. The FDA consider that anything that exceeds these limits is “adulterated” and, therefore, subject to enforcement action under Section 402(a)(3) of the Food, Drug, and Cosmetics Act.

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