Friday, October 10, 2008

Melamine hysteria #3 - a missed opportunity, or negligence...?

Apparently the melamine story goes back 18 months to early 2007, when it was first recognized that precious pets in the US were dying of renal failure. The problem was soon traced to the presence of very high levels of melamine in the incriminated pet food. Since melamine does not occur naturally in food, the source was quickly traced to intentional spiking of wheat gluten so as to fool chemical assays for N2 that there was more protein in the gluten than there actually was in the pet food. The amount of melamine in the pet food was more than 1000 ppm (1 ppm = 1 mg/kg). This led to the largest pet food recall in US history.

The scandal prompted the FDA to pay greater attention to produce from China, particularly those that depended on the chemical assay of N2 (Kjeldahl and Dumas methods) as an indicator of protein content.

It is now recognized that melamine has found its way into the food chain, possibly through the use of the common pesticide cyromazine. Small amounts of melamine in food is acceptable as it is not a particularly toxic chemical. But it is thought now that melamine may act synergistically with a co-contaminant cyanuric acid to produce the renal toxicity.

The story is better reviewed here:

After the 2008 Olympics, the scandal with respect to infant toxicity hit the front page. A detailed account can be found here:

According to a CNN report, ... "Levels of melamine discovered in batches tested varied widely, from as much as 6,196 milligrams per kilogram to as little 1.3 milligrams per kilogram.".

The question I have is this:
Why did it take so long for the regulatory authorities to begin policing melamine content in food products?

For one thing, it should have been very clear 18 months ago that the old chemical assays for N2 were inadequate, and those should have been replaced by a good LC-MS/MS assay for melamine. For some strange reason this was never done. Complacency or negligence? Was it a case of everyone waiting for something to happen? Could it not have been expected, that what happened to small furry animals could also happen to babies, and other members of the human species?

To be fair to the AVA, they were just following the idiocy of other regulatory agencies, now having a lot of egg on the face. But I feel they have not been as professional about this as they should have been. The implications following the pet food scandal should have been obvious (although much better now of course with hindsight) back in 2007. A better assay, and more careful scrutiny would have been appropriate. Now they, like many other food regulators are scrambling to manage this mess, which should not have been allowed to deteriorate to this stage anyway.

Now, nobody really knows what the AVA is doing. Information from the authority trickles out almost grudgingly...and in confused fashion. My sources tell me they have pulled all products from China. No one has any idea what products have been tested, and what have not. A short list of products that fail testing have been put out, but we have no idea what assay the AVA uses and what the implemented concentration limits of melamine are.

The AVA website is full of general motherhood statements with no real information. We are told that "AVA adopts a risk-based approach towards ensuring food safety. Food products identified through trend studies to be of high potential health risk, or have a history of poor food safety record are placed under strict import control (high risk). These products require pre-market assessment such as the requisition of health certificates or laboratory analytical reports to certify the safety of the products, or inspections and/or sampling, at the points of import."
In other words, AVA only does sampling checks (how frequent, how representative these sampling is, we have no idea) and requires nothing more than the importer to provide documents from the Chinese factory certifying quality of the product (ho hum....). Clearly, the AVA wants us to just trust them implicitly, and blindly...i.e. like little blind mice! *sigh*

For infant formulas, these are the published AVA requirements:

Microbiological Tests:

  • Total colony count
  • E. coli
  • Staph enterotoxins
  • Salmonella
  • Bacillus enterotoxins#
  • Clostridium botulinum#
  • Enterobacter sakazakii
  • Sterility test for food in hermetically sealed containers

Chemical Tests:

  • Aflatoxins M1
  • Heavy metals#
  • Pesticides residues#
  • Polychlorinated biphenyls (PCBs)#

# Upon request by AVA

duuuhhhhhh...............! Anyone there heard of melamine?

I think AVA owes us an explanation, big time...really big time!!

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