September 20, 2012
Dr. Margaret Hamburg
Commissioner
U.S. Food and Drug Administration
10903 New Hampshire Avenue
Silver Spring, MD 20993
Michael R. Taylor
Deputy Commissioner for Foods
U.S. Food and Drug Administration
10903 New Hampshire Avenue
Silver Spring, MD 20993
Dear Commissioner Hamburg and Deputy Commissioner Taylor:
Consumers Union, the public policy and advocacy arm of Consumer Reports, is writing in regard to Consumer Reports’ tests of arsenic in rice and rice products, which will be published in our November 2012 issue. Our testing, which included 200 samples of more than 60 different products, found inorganic arsenic in virtually every sample, at concerning levels. As you know, arsenic can be not only a potent human carcinogen but may also result in other health problems. We therefore urge the U.S. Food and Drug Administration (FDA) to set standards for arsenic in food, to prohibit the use of arsenic-containing drugs in livestock and poultry, and to limit the arsenic allowable in manure used on rice fields.
We welcome FDA’s ongoing testing effort of over 1,000 products, and commend you for making public the results of the first 200 samples completed. This is important information for consumers as well as for the scientific and public health communities, and we appreciate you making this issue a priority.
Standards for Arsenic in Food and Beverages
We urge FDA to move expeditiously to set standards for arsenic levels in food, especially in products where it is well known to accumulate. Earlier this year, Consumer Reports released the results of our tests of arsenic in apple and grape juices. Based on those findings, we asked that FDA set a federal standard of 3 parts per billion (ppb) for these juices, which are consumed often by children. We understand that FDA has already completed a guidance document related to arsenic in fruit juice; we strongly urge the agency to release this guidance as soon as possible.
Based on our new research into rice and rice products, we respectfully request that FDA adopt a standard limit of 120 ppb of inorganic arsenic in rice, and develop standards for other rice products that reflect levels of consumption in the most at-risk populations. A standard of 120 ppb for rice could be met by 73 percent of the rice we tested. In addition, we urge FDA to issue guidance about the consumption of rice products, especially for pregnant women and children. We also respectfully request that FDA advise that children under the age of 5 should not consume rice milk on a routine basis; such advice has been given by the Food Safety Authority in the United Kingdom.
Arsenical Drugs in the Food Supply
We also believe that by taking arsenic out of food production, the amount of arsenic that ends up in our food can be greatly reduced. Arsenic-containing drugs are currently permitted to be fed to poultry and pigs. We commend FDA on the steps it took to test for inorganic arsenic in broiler chickens, and we were encouraged by Pfizer’s decision to cooperate with FDA and voluntarily, temporarily remove one arsenical drug, Roxarsone, from food production in 2011. However, more than 100 veterinary drugs containing arsenic remain approved by FDA for use on pigs and poultry. We urge FDA to withdraw approval for all arsenic containing drugs, including nitarsone, carbarsone and arsanilic acid, in food production.
Arsenic in Manure Used as Fertilizer
Finally, we urge FDA to reduce the arsenic in manure from chicken production, which is often used to fertilize rice fields. FDA should issue standards for arsenic in manure used on rice fields, which has been reported to have arsenic levels as high as 40,000 ppb.1
In addition, we respectfully request that FDA reduce arsenic in the food supply by prohibiting the feeding of chicken coop floor wastes to cattle. Consumers Union is a signatory, along with other groups, of a petition on this issue submitted to FDA in 2009.2 We look forward to the Agency’s response to this petition.
We appreciate the serious attention that you and your agency are giving to this important issue, and urge you to take action promptly to protect public health.
The complete results of our tests are attached.
Sincerely,
Urvashi Rangan, Ph. D.
Director, Consumer Safety and Sustainability
Jean Halloran
Director, Food Policy Initiatives
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1attle fed litter. Webb Jr KE and JP Fontenot. 1975. Medicinal drug residues in broiler litter and tissues from cJournal of Animal Science, 41(4): 1212?1217.
2 http://www.foodanimalconcerns.org/PDF/FDA%20Chicken%20Litter%20Petition_final.pdf