Strategies for limiting transmission of POPs through the ... · PDF file4 November also...

Strategies for limiting transmission of POPs through

the food chain

Alan Dowding

Chemical Safety DivisionFood Standards Agency

www.food.gov.uk

Sources of POPs in the Environment

• Atmospheric dispersion of smoke and other emissions from point sources

• Secondary or diffuse emissions – e.g. from contaminated land or old landfill sites

• emissions from urban areas – e.g. releases of contaminated indoor air from buildings

• Inappropriate storage or disposal of materials or equipment containing POPs

• Run-off from urban or industrial areas into the aquatic environment• Deposition of contaminated sediment onto land due to flooding or

dredging• ‘Natural’ sources such as dioxins in certain kaolinitic clays

Minimising the Release of POPs to the Environment (Slide 1)

• Identify potentially harmful chemicals, including POPs– e.g. REACH

• Avoid the manufacture and/or use of POPs or potential POPs– e.g. restriction on the use of PCBs– e.g. ban on certain PBDE formulations– e.g. phasing out the use of PFOS for fire foam

• Minimise industrial emissions of POPs– use safer alternative chemicals, improve pollution abatement etc– regulation of major industrial installations under PPC

• Minimise pollution of the marine environment– e.g. the 1992 OSPAR Convention

Minimising the Release of POPs to the Environment (Slide 2)

• Avoidance of diffuse or multiple point source emissions– regulation of on farm burning of waste– raising public awareness

• e.g. proper disposal of old pesticides• e.g. the risk of producing dioxins by burning waste such as PVC insulated

copper cable– ensuring safe storage and disposal of POPs-containing equipment or

materials• Avoidance of spreading contaminated materials onto land

used for food production– e.g. don’t spread incinerator ash onto land, as happened with ash

from Byker Incinerator– e.g. monitor sewage sludge or other bio-solids, such as paper mill

waste, before spreading them onto farmland.

Average upper bound adult dietary intakes of dioxins & dioxin-like PCBs in 1982, 1992, 1997 & 2001

0

2

4

6

8

10

1982 1992 1997 2001Year

pg/W

HO

-TEQ

/kg

bw/d

ay

PCBsDioxins

UK TDI = 2 pg WHOTEQ/kg bw/day

Contaminated Land

• Identify contaminated land sites – e.g. former industrial sites such as chloralkali works, incinerators

or sites where pesticides or other POPs may have been manufactured, stored or used.

– e.g. sites where contaminated waste could have been disposed• Restrict the use of contaminated sites for food production –

especially for grazing or foraging livestock• Remediate or manage affected land to minimise the transfer of

POPs to the food chain• Be aware that flood-prone land near rivers with urban or

industrial catchments can have elevated levels of contaminants such as dioxins and PCBs

• Historical and current spreading of sewage sludge can result in increased levels of POPs in agricultural soil

Pathways for the Transfer of POPs from the Environment into Crops and Herbage• Atmospheric deposition is generally the main contamination

pathway for foliage and fruit

• External contamination with soil or dust containing POPs can also contribute to overall contamination of herbage or crops

• Transfer of most POPs from soil into roots is generally insignificant although slightly higher concentrations often tend to accumulate in the peel. (However, perfluorinated compounds may behave differently.)

• Translocation of most POPs between different parts of plants is generally negligible. However, translocation of dioxins from roots to fruit and leaves has been reported for plants in the genus Cucurbita (i.e. squashes or courgettes etc).

Transfer and Uptake of POPs from the Environment by Grazing and Foraging Livestock• Ingestion of herbage

– Herbage will always contain at least traces of certain POPs due to their ubiquitous presence in the environment

• Ingestion of silage or fodder crops• Ingestion of soil

– To varying extents, cows, sheep pigs and poultry all ingest soilwhilst grazing or foraging and this can be a significant source of exposure to POPs, especially at sites where historical contamination has occurred.

– Silage and fodder can also contain appreciable quantities of soil• Contaminated drinking water

– Livestock should be provided with clean drinking water and prevented from drinking contaminated river water etc

• Inhalation– This is generally a minor exposure pathway, but may lead to

appreciable exposure for some POPs in certain situations

Transfer of POPs into Animal Food via Contaminated Feed Components

• Citrus pulp– The contamination of Brazilian citrus pulp was traced following an

observed increase in dioxin levels in milk• Belgian dioxin crisis

– This was caused by transformer oil contamination of edible oil used in animal feed

• Kaolinitic clay used as a binder in some compound feed products– Dioxins naturally occur in certain kaolinitic clays– This caused increased dioxin levels in eggs and in farmed catfish– Kaolinitic clay contamination of potato waste that was used as feed

resulted in elevated dioxin concentrations in pork and milk.• Fish meal or fish oil sourced from regions with high dioxin and/or

PCB levels– e.g. from the Baltic

• Silage or fodder crops, at a local level, can be relatively contaminated

Monitoring Contaminant Levels in Food and Feed

Monitoring can fulfil four main purposes• To establish ranges of background concentrations of

particular types of contaminant in various food, animal feed or feed component products.

– This information helps advise the Commission when setting Action Levels and Maximum Permitted Levels (MPLs) for contaminants such as dioxins and dioxin-like PCBs

• To provide robust scientific data on which to base advice to consumers, recommendations to the food industry

• To monitor trends in contaminant levels in food and feed over time and from different regions

• For enforcement of Statutory Limits and testing the effectiveness of MPLs and Action Levels in reducing the levels of POPs in food and animal feed

Setting Maximum Levels and Action Levels for Dioxins and Dioxin-like PCBs in Animal Feed (Slide 1)

• Animal feed can account for a major fraction of exposure of livestock to dioxins and PCBs

• Therefore effective controls on levels of these POPs in animal feed and animal feed components can significantly reduce contaminant levels in milk, meat, offal and eggs

• The aim of MPLs and Action Levels for dioxins (and from 4 November also dioxin-like PCBs) in feed is to prevent grossly contaminated feed or feed components from being fed to animals and contamination being transferred to animal-derived food products

Setting Maximum Levels and Action Levels for Dioxins and Dioxin-like PCBs in Animal Feed (Slide 2)• This will be achieved by preventing the use and sale of feed or

feed components that exceed the MPLs and triggering action to trace and reduce or eliminate the sources of contamination if the action levels or the MPLs are exceeded

• Batches of feed component or additive that exceed MPLs must not be mixed with less contaminated feed in order to bring the overall concentration below the MPL. Instead, any product that exceeds the MPL must be not be used for feed or food.

MPLs for Dioxins and Dioxin-like PCBs in Animal Feedingstuffs (Slide 1) European Parliament and Council Directive 2006/13/EC amending Directive 2002/32/EC

Dioxins Dioxins plus dioxin-like PCBs

a Feed materials of plant origin with the exception of vegetable oils and their by-products 0.75 1.25

b Vegetables oils and their by-products 0.75 1.5c Feed materials of mineral origin 1.0 1.5d Animal fat, inlcuding milk fat and egg fat 2.0 3.0

e Other land animal products including milk and milk products and eggs and egg products 0.75 1.25

f Fish oil 6.0 24.0

gFish, other aquatic animals, their products and by-products with the exception of fish oil and fish protein hydrolysates containing more than 20% fat

1.25 4.5

Products intended for animal feed

Maximum Level (ng WHO-TEQ/kg for feedingstuff with a relative moisture content of 12%)

MPLs for Dioxins and Dioxin-like PCBs in Animal Feedingstuffs (Slide 2) European Parliament and Council Directive 2006/13/EC amending Directive 2002/32/EC

Dioxins Dioxins plus dioxin-like PCBs

h Fish protein hydrolysates containing more than 20% fat 2.25 11.0

i

The additives, kaolinitic clay, calcium sulphate dihydrate, vermiculite, natrolite-phonolite, synthetic calcium aluminates and clinoptilolite of sedimentary origin belonging to the functional groups of binders and anti-caking agents

0.75 1.5

j Additives belonging to the functional group of compounds of trace elements 1.0 1.5

k Premixtures 1.0 1.5

l Compound feedingstuffs, with the exception of feed for fur animals, pet foods and feed for fish 0.75 1.5

m Feed for fish. Pet foods 2.25 7.0



Action Thresholds for Dioxins and Dioxin-like PCBs in Animal Feedingstuffs (Slide 1) European Parliament and Council Directive 2006/13/EC amending Directive 2002/32/EC

Dioxins Dioxin-like PCBs

a Feed materials of plant origin with the exception of vegetable oils and their by-products 0.5 0.35

b Vegetables oils and their by-products 0.5 0.5c Feed materials of mineral origin 0.5 0.35d Animal fat, inlcuding milk fat and egg fat 1.0 0.75

e Other land animal products including milk and milk products and eggs and egg products 0.5 0.35

f Fish oil 5.0 14.0

gFish, other aquatic animals, their products and by-products with the exception of fish oil and fish protein hydrolysates containing more than 20% fat

1.0 2.5



Action Thresholds for Dioxins and Dioxin-like PCBs in Animal Feedingstuffs (Slide 2) European Parliament and Council Directive 2006/13/EC amending Directive 2002/32/EC

Dioxins Dioxin-like PCBs

h Fish protein hydrolysates containing more than 20% fat 1.75 7.0

i

The additives, kaolinitic clay, calcium sulphate dihydrate, vermiculite, natrolite-phonolite, synthetic calcium aluminates and clinoptilolite of sedimentary origin belonging to the functional groups of binders and anti-caking agents

0.5 0.5

j Additives belonging to the functional group of compounds of trace elements 0.5 0.35

k Premixtures 0.5 0.35

l Compound feedingstuffs, with the exception of feed for fur animals, pet foods and feed for fish 0.5 0.5

m Feed for fish. Pet foods 1.75 3.5



Maximum Levels for Dioxins and Dioxin-like PCBs in Food (Slide 1)

• Maximum levels for dioxins were set under Commission Regulation 466/2001 as amended by Council Regulation 2375/2001 and have applied since 1 July 2002

• The aim of Commission Regulation 466/2001 was to provide an increased level of consumer protection by keeping contaminants at levels that are toxicologically acceptable and to exclude grossly contaminated food from entering the food chain

• Regulation 466/2001 also ensured consistency of enforcement across the EU

• From a toxicological point of view, any maximum level should apply to both dioxins and dioxin-like PCBs. However the limited data available at that time meant that specific limits that would cover dioxin-like PCBs could not be set.


• However, Regulation 466/2001 committed the Commission to reviewing the legislation with a view to including dioxin-like PCBs in the limits. New limits were agreed in November 2005 and are specified in Commission Regulation 199/2006

• As dioxins and dioxin-like PCBs share toxicological properties, it was agreed to set a limit for the sum of dioxins plus dioxin-like PCBs and not for the two classes of chemicals separately. These new limits will come into force on 4 November 2006.

• To ensure a smooth transition, the Regulation makes provision for the existing limits for dioxins to apply in parallel to the new limits for dioxins plus dioxin-like PCBs. However, consideration will be given by 31 December 2008 to dispensing with these separate limits for dioxins.


• The Commission has a general commitment to review maximum levels set under Commission Regulation 466/2001. Consequently Commission Regulation 199/2006 will be reviewed by 31 December 2008 with a view to establishing maximum levels for other foodstuffs, possibly including lower limits for infant and baby food.

• Apart from protecting consumers from dioxins and dioxin-like PCBs, nutritional needs must be addressed. Therefore, for example, there is a temporary derogation for Sweden and Finland allowing the domestic sale of fish caught from the Baltic in which concentrations of dioxins and PCBs exceed the maximum level.

Maximum levels for dioxins and for dioxins plus dioxin-like PCBs in various food products (Slide 1)Regulation (EC) 199/2006

Maximum levels Sum of PCDD/Fs (WHO-TEQ)

Maximum levels Sum of PCDD/Fs and dioxin-like

PCBs (WHO-TEQ)

3.0 pg/g fat 4.5 pg/g fat2.0 pg/g fat 4.0 pg/g fat1.0 pg/g fat 1.5 pg/g fat

6.0 pg/g fat 12.0 pg/g fat

4.0 pg/g fresh weight 8.0 pg/g fresh weight



* A new consolidated version of the Regulations will refer only to 'poultry'** The liver limit only applies to the animals specified under 'meat and meat products'

Milk and milk products, including butter fat

-of poultry and farmed game*-of pigs

Liver of terrestrial amimals and derived products thereof**

Muscle meat of fish and fishery products and products thereof with the exeception of eel

Food

Meat and meat products- of ruminants (bovine animals, sheep)

- Muscle meat of eel (Anguilla anguilla ) and products thereof

Maximum levels for dioxins and for dioxins plus dioxin-like PCBs in various food products (Slide 2)Regulation (EC) 199/2006

Maximum levels Sum of PCDD/Fs (WHO-TEQ)

Maximum levels Sum of PCDD/Fs and dioxin-like

PCBs (WHO-TEQ)3.0 pg/g fat 6.0 pg/g fat

-- of ruminants 3.0 pg/g fat 4.5 pg/g fat

-- of poultry and farmed game 2.0 pg/g fat 4.0 pg/g fat

-- of pigs 1.0 pg/g fat 1.5 pg/g fat

-- mixed animal fats 2.0 pg/g fat 3.0 pg/g fat



Food

-Vegetable oil and fats

Marine oil (fish body oil, fish liver oil and oils of other marine organisms intended for human consumption)

Hen eggs and egg productsOils and fats

- Animal fat

Action Levels for Dioxins and Dioxin-like PCBs in Food

• In addition to statutory limits, ‘action levels’ were established under Commission Recommendation 2002/201/EC as amended. These have been superseded by action levels specified in Recommendation 2006/88/EC

• The Recommendation, in conjunction with Commission Regulation 466/2001 and Commission Directive 2002/69/EC is part of a strategy to reduce the presence of dioxins and dioxin-like PCBs in the environment, food and feed

• The ‘action levels’ are a tool for ‘early warning’ which should trigger a proactive approach by competent authorities and operators to identify sources and pathways for contamination and to take measures to reduce or eliminate them

• Action levels, as well as maximum levels, will be reviewed in the light of data accumulated for the EU monitoring programme for levels of dioxins and dioxin-like PCBs in food.

Action levels for dioxins and for dioxins plus dioxin-like PCBs in various food products (Slide 1)Commission Recommendation 2006/88/EC

Action level for PCDD/Fs (WHO-TEQ)

Action level for dioxin-like PCBs (WHO-TEQ)

1.5 pg/g fat 1.0 pg/g fat1.5 pg/g fat 1.5 pg/g fat0.6 pg/g fat 0.5 pg/g fat





Note: Target levels for the sum of dioxins and dioxin-like PCBs will be set by the end of 2008

- Muscle meat of eel (Anguilla anguilla ) and products thereof

Milk and milk products, including butter fat

- of pigs

Liver of terrestrial amimals and derived products thereofMuscle meat of fish and fishery products and products thereof with the exeception of eel

Food

Meat and meat products- of ruminants (bovine animals, sheep)- of poultry and farmed game

Action levels for dioxins and for dioxins plus dioxin-like PCBs in various food products (Slide 2)Commission Recommendation 2006/88/EC

Action level for PCDD/Fs (WHO-TEQ)

Action level for dioxin-like PCBs (WHO-TEQ)


-- of ruminants 1.5 pg/g fat 1.0 pg/g fat-- of poultry and farmed game 1.5 pg/g fat 1.5 pg/g fat-- of pigs 0.6 pg/g fat 0.5 pg/g fat-- mixed animal fats 1.5 pg/g fat 0.75 pg/g fat



0.4 ng/kg product 0.2 ng/kg productNote: Target levels for the sum of dioxins and dioxin-like PCBs will be set by the end of 2008

Hen eggs and egg products

Food

Fruits, vegetables and cereals

Oils and fats- Animal fat

- Vegetable oil and fats

Marine oil (fish body oil, fish liver oil and oils of other marine organisms intended for human consumption)

Possible Future Legal Limits for POP-like Contaminants (Slide 1)• The EU has produced a form for recording the monitoring results

for BFRs in food

• EFSA has specified that the following compounds should be monitored as a minimum requirement:

– PBDEs 28, 47, 99, 100, 153, 154, 183, & 209– HBCD-isomers (α, β & γ)

• The following compounds have also been suggested for monitoring– Other PBDEs and PBBs– Decabromodiphenylethane– Hexabromobenzene– bis(2,4,6-tribromophenoxy)ethane

• This will possibly lead to action levels and/or maximum levels for some or all of these contaminants in certain food products

Reducing levels of POPs associated with crops used for food and animal feed (Slide 1)

• Reasonable measures can be taken to minimise exposure via POPsin soil, dust or soot adhering to certain food or fodder crops

• e.g. Washing and peeling fruit and vegetables.– The uptake and translocation of POPs such as dioxins and PCBs in

plants is generally negligible (but plants in the cucumber family may be an exception). The small amount of uptake of chemicals such as PCBs that does occur in root crops and potatoes tends to be confined to the peel. However, traces of soil adhering to vegetables would usually be a more significant source of exposure to POPs.

• Fodder and silage should be harvested with care to minimise contamination with soil.

– e.g. Do not cut silage immediately after flooding or when thepasture is muddy

Reducing levels of POPs associated with crops used for food and animal feed (Slide 2)

• Historically, it was possible for livestock to graze on pasture immediately after spreading sewage sludge. Apart from the risk of contamination with pathogens, this was also a significant source of exposure to POPs present in the sludge. However, this is no longer possible under ‘The Safe Sludge Matrix’ guidelines,

Reducing dietary intake of Dioxins and dioxin-like PCBs from Fish Oil dietary supplements (Slide 1)

• Fish oils contain high levels of omega 3 fatty acids – mainly eicosapentanoic and docosohexanoic acids, anti-oxidants and lipophilic vitamins. However, they also tend to contain quite high levels of dioxins and PCBs.

• Manufacturers can reduce intake of dioxins and dioxin-like PCBs from fish oil dietary supplements by:– Sourcing fish from cleaner waters – e.g. the South Atlantic– Revising the recommended dosages – especially for children

• However, there is a requirement under Commission Regulation 199/2006 for manufacturers to reduce levels further – especially PCBs

Reducing dietary intake of Dioxins and dioxin-like PCBs from Fish Oil dietary supplements (Slide 2)

• Purification techniques are being developed for removing dioxinsand dioxin-like PCBs without depleting the beneficial nutrients

• Activated carbon can remove PCDD/Fs and non-ortho PCBs, but it is not very effective for mono-ortho PCBs

• Volatilisation procedures – e.g. ‘cross-flow stripping’ – have been found to be effective at removing dioxin-like PCBs but not dioxins

• Using both complimentary approaches in tandem has been reported to be effective at achieving low levels of both dioxins and dioxin-like PCBs in fish oil.

Advice to Consumers and Producers

• Reduce the risk of eating lots of highly contaminated food by having a varied diet with individual types of food be obtained from several sources rather than from a single supplier.

– e.g. During the foot and mouth disease epidemic, there was concern that dioxins in smoke from pyres could contaminate nearby pasture and milk from surviving cows. Therefore the FSA issued precautionary advice that people who consume whole milk and milk products only from animals within 2 km of pyres should vary their diet to include milk and milk products from other sources.

– e.g. The FSA advises that consumers should eat at least two portions of fish per week, of which one should be oily. Girls and women who may have a baby are advised to limit their consumption to two portions per week whilst all other consumers are advised to limit their consumption to four portions per week. As some non-oily fish species contain higher levels of dioxins and PCBs than others, people who eat a lot of fish should vary the species of fish they eat.

Some potential disadvantages of strategies for lowering POPs levels in food (Slide 1)

• The concentrations of dioxins and PCBs in fish are likely to increase with age. Therefore there might be a temptation to catch smaller/younger fish in an attempt to achieve lower dioxin and PCB levels. This could be at the cost of depleting fish stocks.

• For ethical reasons, it may be preferable to consume free-range eggs but they are likely to contain higher levels of dioxins andPCBs than eggs from hens reared entirely indoors.

Some potential disadvantages of strategies for lowering POPs levels in food (Slide 2)

• Prior to their introduction, there was some concern that the MPLsfor dioxins in feed, whilst being effective at excluding consignments of feed with gross contamination, might also remove from the market some feed supplies that would pose no significant risks to consumers of animal products.

• Enforcing MPLs does require considerable resources and is a significant extra burden for producers and enforcement authorities.

Median TEQ Concentrations (ng WHO-TEQ/kg fat) of Milk Samples on Flood-prone and Control Farms Stratified by River System and Sampling Date

October 1998 March 1999 August 1999River System

Flood-prone

Control Flood-prone

Control Flood-prone

Control

Doe Lea/Rother/Don 5.46 (6) 4.01 (6) 4.45 (6) 3.79 (5) 2.04 (6) 2.13 (6)

Trent 4.67 (7) 3.02 (8) 3.97 (7) 2.47 (8) 2.42 (6) 1.49 (8)

Dee 1.73 (4) 1.97 (6) 1.70 (5) 1.91 (6) 1.09 (5) 1.05 (6)

Total 4.29 (17) 2.85 (20) 3.29 (18) 2.66 (19) 1.70 (17) 1.46 (20)

NB Figures in parentheses are the number of samples

Source: Lake et al (2005) Environ. Sci. Technol. 39: 9033-38

Congener profiles in soil from flood-prone and matched control farms (Farms 9 & 10)

0% 20% 40% 60% 80% 100%

% of Total WHO-TEQ

Fm 9 - Flood - Oct'98

Fm 9 - Flood - Aug'99

Fm 9 - Non-Flood -Oct '98

Fm 10 - Control -Aug '99

2378TCDD12378PeCDD123478HxCDD123678HxCDD123789HxCDD1234678HpCDDOCDD2378TCDF12378PeCDF23478PeCDF123478HxCDF123678HxCDF123789HxCDF234678HxCDF1234678HpCDF1234789HpCDFOCDF

Congener profiles of dioxins in milk from flood-prone and matched control farms (Farms 9 & 10)

0% 20% 40% 60% 80% 100%

% of Total WHO-TEQ

Fm 9 - Flood - Oct'98

Fm 9 - Flood - Aug'99

Fm 10 - Control -Oct '98

Farm 10 - Control -Aug '99

2378TCDD12378PeCDD123478HxCDD123678HxCDD123789HxCDD1234678HpCDDOCDD2378TCDF12378PeCDF23478PeCDF123478HxCDF123678HxCDF123789HxCDF234678HxCDF1234678HpCDF1234789HpCDFOCDF

Summary: Main Strategies for Limiting Transmission of POPs Through the Food Chain (Slide 1)• Continue to reduce environmental levels of POPs – this is

effective and probably ultimately the most important strategy

• Understand the mechanisms and pathways for the transfer of various POPs through the food chain

• Focus on dealing with predominant sources of POPsentering the food chain – e,g. controlling contaminant levels in animal feed can be very effective

• Monitor levels of POPs in food and feed on an ongoing basis

• Introduce specific achievable limits based on robust monitoring data. However, ensure that the limits are proportionate and sustainable. Where practical and necessary, consider making existing limits more stringent

Summary: Main Strategies for Limiting Transmission of POPs Through the Food Chain (Slide 2)• Where levels of POPs in food or feed are found to be high:

– Prevent unacceptably contaminated food or feed from being consumed

– Investigate the cause of contamination and take measures to reduce or eliminate the contamination source

• Continue to raise general awareness regarding the sources and/or causes of contamination of food

• Disseminate effective methods for minimising transmission of POPs through the food chain, or, where possible purification techniques for removing them – e.g. for fish oil

• A varied diet and sourcing particular types of food from different suppliers can reduce the risk for individual consumers of being exposed to high levels of particular POPs

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