Comments on the Proposed Draft Code of Practice for Source Directed Measures to Reduce Contamination of Food with Chemicals (Agenda item 15a)
Draft Maximum Levels for Lead (Agenda item 15 b)
Comments on the Proposed Draft Maximum Levels for Tin (Agenda Item 15 c)
Discussion Paper on Cadmium (Agenda Item 15d)
Position Paper on Arsenic (Agenda Item 15e)
Discussion Paper on Dioxins (Agenda item 15f)
Proposals for the Priority Evaluation of Food Additives and Contaminants by JECFA (Agenda Item 16)
118) The Committee recalled that its last Session had agreed to circulate the Proposed Draft Code of Practice prepared by the Delegation of Sweden for comment and consideration at its next meeting. The Committee discussed whether the text should be advanced to Step 5 in its present state or returned to Step 3 for further development.
119) Some delegations stressed that source directed measures were the most important measures to reduce contaminants in foods. Other delegations felt that the objectives and the scope of this document should be clarified. In reply to these remarks, the Delegation of Sweden proposed that the document should focus on environmental contaminants and should include other amendments to address the comments received. Moreover, the Committee agreed that the reference to substances which were outside its terms of reference, e.g. pesticide residues, should be removed from the document.
Status of the Proposed Draft Code of Practice for Source Directed Measures to Reduce Contamination of Food with Chemicals
120) The Committee agreed to return the Proposed Draft Code to Step 3 for redrafting by the Delegation of Sweden, in order to incorporate the comments received, and consideration at the next session.
121) The Committee recalled that its last Session had accepted the offer of the Delegation of Denmark to review the draft maximum levels for lead in light of the appropriate risk assessment for children. The Delegation of Denmark highlighted the changes proposed to certain maximum levels in view of the data received. The Committee expressed its appreciation to the Delegation for its important work on lead.
122) Several delegations felt that the background of each level proposed should be made more transparent by the inclusion of appropriate references and that additional specific levels should be considered. In addition, some delegations pointed out that the data used should be quality assured and that intake figures should reflect regional diets as much as possible.
123) Some delegations expressed the view that in order to achieve progress, the draft maximum levels should be advanced further in the Procedure and the levels for which there was general agreement should be finalized. Other delegations felt that this document was not yet ready for advancement to Step 8 because JECFA would re-evaluate lead in June 1999 and additional quality assured data was necessary.
124) The Delegation of Turkey pointed out that a single level for all fruit should be reconsidered in order to recognise the specific contribution of different types of fruit to total intake, and in particular the level proposed for raisins was too low. The Delegation of the United States expressed its concern about exposure for children and stressed the need for data of good quality on food produced according to GAP and GMP. This view was supported by the Delegation of the Philippines, who also stressed the need to consider levels of lead in fishery products from aquaculture and from other regions like Asia, and offered to provide data.
125) The Secretariat suggested to ask for comments on the appropriate methods of analysis as there was a reference to methods for certain levels, and to include the current lead levels in commodity standards in the revised document. The Delegation of Denmark indicated that this would be taken into account in the review. The Chairman urged Denmark, and all other countries responsible for redrafting documents, to finalize their revision before the October 1st 1999 in order to circulate the revised document well in advance of the next meeting to facilitate further progress.
Status of the Draft Maximum Levels for Lead
126) The Committee agreed to return the Draft Maximum Levels to Step 6 for redrafting by the Delegation of Denmark, with the assistance of the United States, on the basis of the above discussion and the comments received, with the understanding that the revised document would include appropriate references for the levels proposed.
127) The Committee recalled that the 30th Session had agreed to circulate at Step 3 the recommendations in a paper on tin prepared by Australia, Indonesia and Thailand, and revised by Australia, for maximum levels of 200 mg/kg in liquid canned foods and 250 mg/kg in solid canned foods.
128) Some delegations and the Observer from Consumer International argued that the proposed levels were too high, especially in view of the occurrence of acute toxicity (gastric irritation) at 150 mg/kg as reported by JECFA in its evaluation. Some delegations felt that if the proposed levels were adopted, this could be seen as allowing poor manufacturing practice. Some delegations proposed lower levels for all canned foods, with some exceptions for certain foods, including high acid foods if needed.
129) Other delegations pointed out that the acute toxicity mentioned was questionable and no long term effects had been reported. These delegations also explained that lower levels were not achievable for some high acid foods such as pineapple and that these proposed levels were based on technological need as well as safety. The Committee agreed to keep these issues under review and to ask JECFA to review acute toxicity of tin as a matter of priority.
130) The Delegation of Australia recalled that, as previously explained in the last session, "sacrificial" tin was necessary in these products to protect can integrity, an important food safety function, and pointed out that as tin was not necessary for low acid canned foods, the discussion of a limit for such products was not a relevant food safety matter.
Status of the Proposed Draft Maximum Levels for Tin
131) The Committee agreed to advance the proposed levels of 200 mg/kg in liquid canned foods and 250 mg/kg in solid canned foods to the Commission for adoption at Step 5 (see Appendix IX).
132) The Committee recalled that the 30th Session had accepted the offer of Denmark to revise the discussion paper for circulation and further consideration. The Delegation of Denmark presented a list of proposed maximum levels which had been revised in view of the comments received and the Committee discussed whether this list should be circulated at Step 3. The Committee recalled that the Draft Guideline Level for Cadmium in Cereals, Pulses and Legumes was at Step 7 as it had been initially considered by the Committee on Cereals Pulses and Legumes and forwarded to the CCFAC for finalization after the adjournment of the CCCPL. It was also noted that cadmium was scheduled for evaluation by the 55th JECFA Meeting in 2000.
133) Several delegations felt that it would be appropriate to forward the levels included in the discussion paper for comments at Step 3 in order to achieve progress on cadmium, in view of important public health concerns associated with this contaminant. Some delegations referred to their written comments on the specific levels proposed (such as potatoes, horse meat and soybean) and the Committee noted that further discussion would be required on the levels and the commodities concerned. The Delegation of France proposed to include mushrooms in the same category as leafy vegetables (instead of vegetables).
134) The Delegation of the United States stressed the importance of a thorough risk assessment in order to establish maximum levels; in particular, the bioavailability of cadmium and its accumulation in different types of vegetables due to the soil or other factors should be considered carefully, and quality assured data was necessary for that purpose. The Delegation therefore proposed to wait for the JECFA evaluation of cadmium before circulating the levels in the Step Procedure. The Delegation of Japan supported this view and pointed out that the changes to the levels and commodities proposed in the list had not been discussed in detail and further consideration should be given to the whole issue after the JECFA evaluation became available. The Delegation offered to provide to JECFA the results of several toxicity studies on cadmium contamination which were currently underway. Other delegations proposed to defer the decision pending evaluation of cadmium by JECFA.
135) Several delegations mentioned the possibility to proceed with the establishment of levels which were non controversial but to wait for further data when specific problems existed. A number of delegations observed that there would be enough time to take into account the JECFA evaluation in the elaboration procedure, but the circulation of specific levels at Step 3 would contribute to focus the discussion and comments and would facilitate further consideration of cadmium contamination. The Delegation of the United States pointed out that it should be clear that Maximum Levels for Cadmium would not be finalised until JECFA had examined data on the bioavailability of cadmium and provided a risk assessment for the Committee.
Status of the Draft Guideline Level and Proposed Draft Maximum Levels for Cadmium
136) The Committee agreed to return the Draft Guideline Level for Cadmium in Cereals, Pulses and Legumes to Step 6 and to circulate the other maximum levels at Step 3 for comments and consideration at the next session (see Appendix X). The Delegation of Japan reserved its position on this decision.
137) The Committee decided to ask the Delegation of Denmark to finalize the position paper in the light of comments received, and agreed that it would form the basis for future work until such time as routine methodology became available to determine toxic arsenic compounds in food.
138) The Committee recalled that the last session had accepted the offer of the Delegation of the Netherlands to prepare a discussion paper on dioxins for consideration at its next session. Some delegations pointed out that source directed measures were the most important solutions for this contamination problem, that there were analytical problems and that it would be premature to set maximum limits. The Committee asked delegations to gather information on this issue, especially on international trade in the most contaminated commodities, dairy products, fish, fish oil and meat (fat) and to send this information to the Delegation of the Netherlands.
139) The Committee agreed that the Delegation of the Netherlands would revise the discussion paper for circulation and consideration at its next session.
140) Mr. J. Dornseiffen (the Netherlands) introduced the report of the informal Working Group on Priorities for JECFA. The Committee agreed with the priorities proposed by the Working Group for both food additives and contaminants with the following amendments and comments.
141) As regards "nutritional consideration of calcium in food additives", the Delegation of Canada, which had proposed this entry, explained their concern that the calcium intake from calcium salts additives may result in the total calcium intake limit being exceeded. The Committee therefore agreed to delete the reference to "nutritional consideration".
142) The Committee agreed to add tin to the priority list of contaminants, for the assessment of its acute toxicity. At the request of the JECFA Secretariat, the Committee prioritized the first four contaminants for consideration by JECFA, in the following order: Ochratoxin A, cadmium, dioxins and dioxin-like PCBs, and fumonisins.
143) The Committee agreed on the priority list for food additives and contaminants presented in Appendix XII. The Committee agreed to request additional comments for additions or amendments to its Priority List, preferably well documented and in time, for consideration by the next session.
