Comments on Economically Motivated Adulteration

1. Comments on Economically Motivated Adulteration Xuman Amanda Tian Research Associate, Food Safety Program Center for Science in the Public Interest atian@cspinet.org FDA Public Meeting on EMA College park, Maryland May 01, 2009

2. CSPI • The Center for Science in the Public Interest is a bi-national NGO representing consumers in both the US and Canada • 900,000 subscribers to the Nutrition Action Health Newsletter in U.S. and Canada • Publishes Outbreak Alert database

3. Consumer Confidence Americans’ confidence in food safety is plummeting… • 78% of consumers do not believe that food is safer now than a year ago • 48% decline in consumer confidence • 46% worry about getting sick from food • 52% have only some or little confidence in the food inspection system Sources: University of Minnesota, Consumers Union, AP-Ipsos, Food Marketing Institute, USA Today

4. Consumer Concerns About Imported Foods CSPI Survey Results (August 2008)

5. Economically Motivated Adulteration (EMA) Problems can occur in foreign and domestic products: • Food attributes that are more vulnerable to EMA • Recent examples of EMA domestically and internationally • Further steps that U.S. regulators can take to predict and prevent EMA

6. Vulnerable Food Attributes • Dairy • Seafood • Egg • Grains • Beverages • Spices • Oil • Sugar

7. Melamine in Chinese Dairy Products • Melamine was added in Infant formula and other dairy products to appear to have a higher protein content. • By November 2008, China reported an estimated 300,000 victims, six infants dead from kidney stones and other kidney damage, and a further 860 babies hospitalized.

8. Melamine in the U.S. Infant Formula • Nestle, Mead Johnson, and Abbott Laboratories • More than 90% of all infant formula in the U.S. • Melamine & Cyanuric acid • Information was not made public • FDA set new standard – 1 ppm – after it was found in domestic product

9. Pet Food and Animal Feed Recall in 2007 • Over 150 brands of pet food and 1,000 products were recalled by a number of companies • Melamine and cyanuric acid tainted ingredient-wheat gluten & rice protein concentrate from China • Melamine added as a binder to fish and livestock feed in Ohio and Colorado.

10. Antibiotics in Seafood from Southeast Asia-U.S. • Approximately 80% of the seafood bought in the U.S. is imported. Most of the imported shrimp comes from places such as Thailand, China, the Gulf of Mexico and other Asian countries. • Chloramphenicol was found in imported Thailand, Vietnam and Chinese shrimp and crawfish (2002) • Indonesia’s shrimps were found to be infected by viruses and contaminated by chloramphenicol (2004) • Chloramphenicol is routinely found in imported shrimp (2004) • Among 2% of imports tested by FDA, 10% of the samples have been tainted with Chloramphenicol (2007) • FDA detected malachite green in seafood from China (2006) • FDA blocked the importation of several varieties of seafood due to continued malachite green contamination (2007)

11. Antibiotics in Seafood from Southeast Asia-International • EU food authorities detected unacceptable levels of chloramphenicol in imported shrimp from China, Vietnam, Indonesia, Thailand and India (2001) • EU continues to prohibit Cambodian seafood exports from entering Europe (2005) • EU decertified all shrimp from Pakistan (2007) • Canada imposed a 100 percent inspection policy on seafood exports from Vietnam after Vietnamese seafood products repeatedly tested positive for chloramphenicol (from 2003 to 2005). Japan did it in 2006 and Russia in 2007.   

12. Strategies to Improve Consumer Protection • Funding • Clarification of roles • Improved import procedures • Focus on prevention • PRIORITIZATION OF FOOD SAFETY

13. FDA’s 2007 Food Protection Plan Includes a New Vision PREVENTION: Build safety in from the start INTERVENTION: Risk-based inspections and testing RESPONSE: Rapid reaction, effective communications

14. New Legislation in Congress • Farm-to-Table Authorities • Prevention/Intervention/Response Model • Better allocates resources across all risks/agencies • Reduces “Promotion vs. Regulation” conflicts • Some bills consolidate profusion of agencies under focused leadership • Adds needed enforcement authorities

15. What Global Consumers Need • Harmonization of international standards for: • Farm-to-table preventative approaches • Effective auditing at national, international levels • Traceability • Greater information-sharing worldwide • Safe Food International

16. New Leadership on Food Safety • In February 2009, President Obama said: [W]e are also strengthening our food safety system and modernizing our labs with a billion dollar investment, a portion of which will go toward significantly increasing the number of food inspectors, helping ensure that the FDA has the staff and support they need to protect the food we eat.

17. Contact Information Xuman Amanda Tian Research Associate, Food Safety Program Center for Science in the Public Interest 1875 Connecticut Ave, NW Suite 300 Washington, DC 20009 Phone: (202) 777-8377 Fax: (202) 265-4954 E-mail: atian@cspinet.org On the internet: www.cspinet.org and www.safefoodinternational.org