In comments submitted to the FDA, Consumer Reports notes that a number of studies in recent years have shown that heavy metals, especially inorganic arsenic (iAs), lead, and cadmium, are more hazardous than previously thought. New studies have found adverse effects, particularly neurobehavioral effects, at lower and lower levels. CR maintains that there is enough data on the toxicity of heavy metals for the FDA to set mandatory standards or limits on baby foods and fruit juices for infants and children, and that the timeline for FDA’s Closer to Zero program is too prolonged.