Document 4vnpe0oz2XMEX6V7LNK0ByrZj

BY JOSEPH HIGHLAND JOSEPH HIGHLAND it director ol the Tone Chemicals Program ol the Envt* ronmifitel Oelente Fund in Washing* Ion, D.C. THU FIRST EVIDENCE that (ood supplies had become contaminated with polychlorinated biphenyls (PCBs) was reported in 1966. when fish from various Swedish waters were shown to contain these chemi cals.1 Since then, PCBs have been identified as contaminants in food supplies around Hie world. They have been found in pike taken from a lake m Finland, in tnollusks and marine fish from Scottish waters, in a wide variety of fish caught in the St. John River system, in wildlife in California, and in trout and salmon taken from-Lake Michigan13 More recent findings indicate that contamination by PCBs continues to be widespread. Within the last few months, striped bass caught in the Hudson River have been found to contain as much as 90 parts per million (ppml PCBs. while pike caught in the Baltic-Sea were shown to contain 0.31 ppm PCBs in their muscle and up To 190 ppnt in their ovaries.* * Moreover, plankton from the Baltic Sea, upon which many fish feed, contained levels of 25 ppm PCBs in their fat.4 The federal government currently conducts three separate programs in which the contamination of foods by PCBs is measured, the fda (Food and Drug Administration) Pesticide Surveillance Program, the FDA Total Diet Program, and the USDA (U.S. Department of Agricul ture) Surveillance Program. The FDA Pesticide Surveillance Program, which began in 1968, was developed to gather information on the levels of pesticides, as well as of PCBs. in foods and animal feeds based on a statistical sampling program designed to cover specific geographical regions of the U.S. The program is intended to assure the safety of the human food sup ply by screening and removing shipments of foods containing PCBs or pesticides in excess of established tolerances. Commodities covered under this testing program include dairy products, eggs, lish, animal feeds, fruits, vegetables, and processed foods. In the FDa Total Diet Program, the levels of pesticides, PCBs, and trace heavy metals in sample diets are measured. Twice a month, a diet approximating that which would be consumed in a two-week period by a hypothetical fifteen* to twenty-year-old male is collected at retail stores in five regions around the U.S, The foods are prepared in the appropriate manner and then divided into twelve basic food composite classes, including meat, fish, poultry, and leafy vegetables. Each com- What IS acceptable? poiite elm n then inilyttd for con taminants The usoa Surveillance Program consists of periodic sampling end anal ysis of mem end poultry for chamtcal contaminants. including reus Simpiei re liken from federally impeded ilaughlef houses. Levek of PCBi in Food A summery of the finding* regarding rex in the ihrce eurvey end surveillonec programs ere llstod in T*ble l.1 **! Although the dete ere ineompiele, it is evident from this tsble (hit ecu continue to contiminite our food. ^Results of I he FOa Pesticide Surveillince Program eppesr to indicate n Increase in the extent of eonlatnine lion, while thoae of the USDA Surveil lance Program indicate e decrease: this epperent conflict mey be expleined by i ha fact that dlffarant fooda are eampled in there program!, end it ii quilt potiiblt that contamination of some kinds of fooda has decreased while It hei tncreeeed in othcre. The epperent decree* in UP icvele of PC It reported in the PDA Total Diet Program Survey belween flacii year 197 3 md thl first fcglf of Dm) yeer 1914 mutt be viewed with cau tion. During the first half of fiscal year 1914, the average FCg leva 11 for' mile and other dairy products, for cg|s end egg products, end for enimtl feed in gredients were equal to ot greater then tnoee reported for fiscal year 1911. Tent in HW| hMwih r in* FOA FetliMet af*eni*nM nun" Irrr lie mt wen el twin Site miHjmi le iar. Hi me imsmi ti uccr In eaeeee el IUHIWM eeeeeteUH revels. [iDliHimai, Vet. IS, Me, 2 TABLE 1 COMPILATION or DATA FROM FEDERAL SOURCES FDA Pesticide Survelltinee Program rw P Iwipn HrwK CmlaMniM 1966*71 15,000 3.2 Fiscal 1973 Fiscal 1974 7,8*2 1,723 4.0 5,4 FDA TotM Diet Program Survey Nemew el ceeipetllt VIM NriRt 1968-71 Fiscal 1973 Fiscal 1974 900 360 360 6 6 4 USDA SurveUlance Program v*ar NVWMT f 1971 Fiscal 1973 (Poultry only) Fiscal 1974 (Poultry only) 4,175 1,037 574 4.0 2.6 1.0 LtIHlI ff Con'trMfMUO" "detectable" (dm, specifically! 1*10 ppm) "dtttctabi*" "datectabie" UnH of efPl*iMNl*n tract -- 0.3( ppm tract -- 60 ppm trace -- 0.05 ppm Co*Uim*4tJo* trace -- 15 ppm tree* -- 4 ppm 1.25 ppm Then why It there an epperent de crees* between 191] end 1914? In large part, this reflects an apparent de erases in the number of fith ihat were found to be conteminaled with pc as. In fiscal yaar 1911. 62.2 percent of the fish santplei exemined contained rcie ranging from traca amounts to 123 ppm. In the first half of fiscal year 1974, only 3S.1 percent of the temples checked were contaminated, and the level* found ranged from trace mounts to 9.1 ppm. However, Ihe fish date reported for fiscal year 1913 in cluded mostly frethwtler fish, in which res conttminetion hat been shown to be greatest, while during the first hail of ftsee) yeer 1914 the samples consifted mainly of merine fish. Since the templet are not comparable, the apparent decrease it* probably reftec. lion of the difference in levels of irc u contamination between freshwater and merine fjih rather thin an uidication 13 HONS 216462 of i general decline in i*CIi in Fish. In addition to ihei* otiiemtionf, numerous specific incidents of rta co mamma non of food lliie been re* potted by tile fda and llte USDa. In l 70. the Campbell Soup Company de* lecied high levels Of FCPs (26.1 ppm on a fat hxxtsl in chickens grown in _|dew York llalc At a mult. U0.45O "chickrni were destroyed. in July IV7I. the Monsanto Company informed the >UA that large amounts of frth meal might hive been contaminated with yi us during the patteunajiion process, due to a leak in the heating tyilem el the company's East Coast Terminal in Wilmington. North Caroline. An Invtsligation by the IDA revealed that the leak had begun in April 1971 and had continued through July 1971. Contam ination of the fish meal was verified, and. at a mull. o*r 123,000 pounds of ill products and M.000 chickana ware dattroyad. That lama year, tht FDA at notified that high levalt of rc*i 120 ppm) had bean found in Swift and Company turkeys. At e re mit, tpproaimataly 1,000.000 buds ware kept from market.1 Thete inci dents and tht rttuiti of tha federal turveiilanct programs demonscrats further that contamination of food by Peat it not a new phenomenon: it it a con tinuing problem which hat resulted in part trom tht continued indiscriminate discharge of PC Is imo the eavironment, and it it on* which must be slim mated because of the severe health haurdt posed by these compounds, "Acceptable Dietary Intaha" The FDA has calculated what it termed an "acceptable deily dietary In take" for Peas in the human dial - or a level of peas which, if ingeated for an extended period of time, would b* toxicologicaUy insignificant. Even if the validity of such a concept ie ca mmed. the basis for establishing sucb a level must he evaluated,* In this connec tion, th* pda's final environmental impact statement for rulemaking on vc*t' indicated that both animal and human toxicolofical data were used ta eslsblisli an allowable dietary intake for human beings. According to data then available (1973), long-term sludiee of dogi and iais showed "no-effect levels" <llte dote level* below which (he effects looked for were not observed) of 10 ppm for three commercial lypvs of vent tAroclore 12*2. 123d, and 1260) fed in (he diet. Employing (he Stan dard 1,00-1 o-l safety factor used in applying results of animal experiments lo human health stantlardt, a no-rl'fect level for human beings, based on data derived from Iht dog experiments, * Id . It appears that the metab olism and excration of . PCBs, especially of Aeoclora with high chlorine content, are even slower than for some of the most persistent pesticides, such as dietdrin and DDT. calculated to be an intake of 0.002S milligram per kilogram of body weight pet day. From the data on rati, a fig ure of 0.003 milligram per kilogram of body weight was obtained. On th* bitia of the teals in dogs, the atlowsbla level of pc > inukt ta a man weighing 70 kilograms (about 133 pounds) was flgurad to be 0.173 mllbfrtm per day (To kilograms a 0.0023 milligram). Th* human toxicological dau uaad In determining the allowable daily dose were derived from investigations of human Peg poisonings in Japan. In 1961, over 1.000 Japaneee persona ex perienced pc* pononmg after consueaing rule oil contaminated with Kanechlor 400 *'* in addition to cadiing haadachfi. swelling of eyelids, tempor ary loas of vision, and many other symptoms, PC*s stored in the adipose tissua (connective tissue eonlauung stored cellular tat) of pregnant woman wert passed through tlw piecental wall to the fetuses. As a result, nine of the tan live-born babies had anueually grayish, darkened Skin, and moat were born underweight. The outbreak wee interpreted by the ida to have the following implieslions for pc* intake standard*:* "Since 2,000 milligrams was re ported to he the average total doet causing an effect in the Japanese, it is pomibla that 200 millimama total doeape PC*a lapplyin* a safety ftetor of 10 to 1) may be tolerated over a much more protracted period of time with out oven advene effect if daily expo* ure is held to minimal levels. This would pvrmtt ingestion of d micro grains 10.004 milUpranil per kilogram body weigh) per day in a 70-kilugram man. Since the lowest total dose pro ducing an effect in inun in ihe Japa nese incident was 300 milligram*, a similar analysis leads io an allowable protracted ingestion of I microgram (0.001 milligram) per kilogram body weight per day as derived from a 70kilogram man." On the basis of these data, the t OA arrived si an allowable dote of rct (for a 70-kilogram man) of 70 to 2*0 microgrami per day - or 0 07 io 0.21 milligram per day - compared lo the 0.17 J miDignm-per-day permianbl* level nlablUhed on the baits of tha dog experiment!. The validity of the** calculations is vary questionable. how ever. Particularly suspect are Ihe ettimelas lhai had to be made of dome received by individual Japaneea. as well as llu arbitrary assumption that a safely factor of 10 lo !~k> sufficient to determine a safe level of intake foe a "protracted'period of time," la addi tion, Ihe calculations fail to consider tht poiantial tong-tana effects cauaad by stored rc* rrudues. Furthermore, according to H. Bhementhal (acting director. Division of Toxicology, Bureau of Foods, FDA) in the time stnea theae calculations an made, ihvrt have been two important experimental observe(tone eonceri^g rest which make Iha previously eatenlated allowable daily intake level obeokii:1 First, recent studies by J. R. Allen and his collatfuti on iha affect* of tow-level exposure of nonhuman pefmtttt lo rc at must bt coatodsrad.*1 * * ** * ** The trfacts seen in these studies of monktys are similar in appearance and persistence io iha symptoms of th* human pononing In Japan. Moreover, (bet* symptoms wara documented at dietary intake level* m tow as 2.3 ppm (equivalent to about 2.3 milligrams per kilogram of body weight). To data, a no-vffact lev*! foe rc*s in monkeys has not been estab lished. This would indicate that dogs ami rate trs not pertkuUrly reliable subjects for lean relating (o primal**, since they art no! as sensitive at an primates to many of th* toxic effects of rest. Second, Alton's work indicatat that ha use of groat observations of toxic ity are nos reliable in th* study of PCP*.11 Allen observed thet routine (oncological evaluations of rat* which were fed 100 ppm Aroctor 124* for on* year revealed no abnormaliliea in growth, mortality, or hematology However, more aophtxticattd teats showed that theta rale eipcrienctd drantctily altered fsl and tiiohmeeol matabottsm at well at changes in liver tig* and structure. Therefor*, tveu if an altowabto human daily tlosaga foe rcPt alculeltd from animal toxKOtog- ictl data wart acceptable. Iht basts foe Hit FDA's 1972 calculi! lone would ha seriously questionable. Th* chemical nature of FCDi may help lo explain m pan why they are sutauulely anil chronically toxic. Tht - uirtti IfPft HONS 216463 them .cal. hav* a low solubility in ,irr hut art highly soluble in f*(, ihcrelnre, they 'end 10 accumulate and concentrate in the body', fal stores rather than being rapidly meUboliteti and excreted. It appears that tht me tabolism and excretion of **CBs, cifhtcially of Aroclors with high chlorine content, ore even (lower than for (Om* of il<e moil persistent pesticides. such i dieldnn and uni.1* Thus, after in gestion. t*cni persist in the body for lonp period, of lime and may thereby elicit chronic effect I. Eicessive Intake Is Common The fda'i acceptable daily PCI intake level of 75 lo 210 microprams per day for a 70-ktloprain man seemi debatable It best A. I. Weasel, scientific coor dinator of the fda, has pointed out,1 "It ti quite clear that the acceptable daily ret intake of 75-210 micro|ranii per day could easily be exceeded by an adult eonsuminf tome of the heavily contaminated foods in hie diet." Table 1, liken directly from Wesstl's testi mony,' illustrates (his point clearly; Consuming t ticidy diet of combined foods from (he list would product con sistent over-expotura to rets if etch food had the maximum allowed con centration of nets flistod onder the heading "Temporary Tolerance Ippm]"). As Wetael conclude!, "Even whan fCbs are pretent at the [ptrmkaaibla) tolerance level, it would be possible for an adult, with normal dietary habits, to expped 17J micrograma (0.175 milbgrem) of Pets par day." Further more, adults with "normal dietary habits" are not the only people who are vulnerable. Perhaps at even greater risk are those large groups within rha population (such at sport fishermen or people who require spatial diets) who consume above-average quantities of PO-eonttmuiettd foods, or nursing babies who ingest rest in rheir mother!' contaminated mitk and who, for natural biochemical reasons, have a very limned capacity for meuboiiilng foreign tubitancoa such al PCBg, A. Kolbye. Jr., amociate director for science. Bureau o( Fooda, PDA, and H. Btumenihsl are clearly correct whan Ihey say, respectively:' '* `'Infants or young children could also readily aacead the tolerable daily eipoture" and, "Thus, the bail evi dence indicates that children wold be more susceptible to the poison ini caused by unmstsboliacd rets, sines TABLE 2 RELATIVE CONTRIBUTION TO ACCEPTABLE OAILY INTAKE fl7* meg/g) Y POODS SUBJECT TO PCB TEMPORARY TOLERANCES ' Tvee er Peae SirvIHt *1 7tl Tfthfiriry TWitirbb Ipm| id****** fUlive AhB9HB( PCVt Ceeirieeiten ip AOl Milk Cheese Poultry Eggs Frth Packaged Food tOO ml (3.5 cups) 100 g (3-5 oz) 200 0 (7 oz) 100 g (2 eggs) 200 f (7 oz) ) 00-200 0 (3.S-7.0 oz) 2,5 (f*t bH) 0.1 (whou product) 2.3 (let basts) 0,6 (whole basis, assuming 23% tei> 3.0 (fat barn) 0.3 (whole basts, assuming 10% fat) 0.3 0 meg 60 meg 100 meg B0 meg 3.0 3,000 meg 10.0 (Packaging) 10-60 meg* 46% 33% 36% 29% 360% 6-33% *Baied on 1971 ro* Survey that 10 ppm seat in packaging ran result in migra tion ot 0,1 -0,6 ppm ecas to packaged food. XaMnear imii eeeMIMae Ike street! el rcl eeuenmt ei nee eit wtwi i* i sts. gnuiienment. Vei. If. No. a HOMS 2164*4 IS PCPi ** eteaac treat teas m*pe| met** we mi* IMS iimm, '\ ~ of phoiotrapht and lead-in rxrerpn. photo ctpuont. and prepare non of moil graphi and illatlralioni vMri appear in environment article,. NOTU 1 -.: iir-:*,? . a./* J * 57. .. I ^ * . ' I'i r. 'o* .1 : *4 * ' Tm* .they have not developed effective wy of eliminating them from the body." Need for ReavaluatlM The FDA't temporary tolerancat for " real in food are both inadequate tad inappropriate: <he acceptable doily Cow cakttleiad in 1972 it now obao. fete in lighi of nioro recent findings -More importantly, however. tho appro pnoKMu of any "eeotpteble dally dotr" for rear it highly queetionabla m light of naw tvidaaca dantonawarln* ih< carcinogenicity of thaaa conw pound! in tipthaMMil MiMh * Sine* than ta at praaml ao adaMUIa evidence that any level of intake of a Tht USDA Survtiilanoa Program consists of ptriodie sampling and analysis of mtats and poultry for chamical eon* tamioantt, including PCBs. eareiaogaa ia left, the tntirt concept of an ernpradf* daily doaa for careuio- ganic tubettneet nidi at rest ia con tradictory and settaUfically untup- porubM. Our growing concern about the con tinued contamination of food aupptiee by ret* refkcta an evar-incrauing awaranaaa of the aatratna health hat- irdt poaad by thaaa compounds. Fatf- eral aampling and tunreiUanca programs have continually demonitrated tbe preaenea of rent in our food tupply. and tbe canting temporary tolerance levele for rent eelebliahad by the rDA have been insufficient to protect tha public health. A naw regulatory pos ture oaadad which takes into ac count recent evidence of chronic ef fect* caused by tow-level dietary in take* of rent and. even more impor tantly, lhe naw evidence nibeuatuling tha carcinogenicity of thaaa com pound* tn laboratory animal*.'* Tht niIt of i hit artitlt at originally upmured war "ren le Food!- A Look It Ftdtral (/merriment ktlponlihililiet " Tht fuMirerr end F.duort of Cnnronmrnl ora rtiptimibU for tht pukkihti rrrier and tubiiilrt. ttlattton I. weeeea. r.a,, iMimav tr - coi Nm read tempt eamerieii.-- *e*a eno orua A#mmH WMMiiffgM, O.C. Imniim rr*m HilrlM OiliCf, OxMf n*. Tftto-991)), t. 1w--WIIMI* M.. tMlto*ny *n 'C9* in Mgw AynJi'Af MtltfisH," am* an* Qrvl O-C. umigm tom iimmg Ctoru's Oltog, 0**a*f to*. TIN401SI. ' I. a.. ciwmiuHto* *r Niytwrmmi Vigtofiyi an* ODT in lm toftnfya* 7>to( IIM," IW. MM. fWu tie |T. * 4. togMay, 'MCI la'Ap Stln tow SIM* UtoV " Mato Tift tTW, l*Me Iti 1971. tv unto, M., rn Nv, "Occwftott af DOT am* PCI Cgmtotoi m Oamc Hamm n Afm* tr*m <9# tyrw* Adm**a*a*a.`* lAtor, ML, 7>I9*. 1974. 9. Li***. g. KMiimgw, am* M, i^tto, HKI Rimmi m MMKtto am* ttolm** to tf*a ft**mi*M*fii Chr *f nmiam*." M, Cftoto. e*M*<n. ?g*Mn 1974. 7. CamafiuMM, M . itfimto? *m r>PCft i Maw 7*** TilMiW Fto am* Qrg* 44mm, watofing*n. O.C. (asgtoam trwm n**n9 Ctohf 0Bca, 0*<to #*. 79MMISI. 9. Fto am* Dewf toi*m*m i M* Aaal ItorgMMtoi nagnt |utmMi 9Ma*tott*t am PMf --lartoato* tognffC 1979. Pe 7. 9e Hwattww, to., rrl**t**** Slw9v *m Vuaha. a Pgaamai Catoa* ay 9 k* Oft Cam ummiito witfi a Cimmimi* Mam* af Mr cm*# Mac#* toamamyto," tutor. Maatt* Mw |:1I9. 1971. 19. ftutotatoto. m., "to *wKt af ***< *f lmctiwt liimMiaing *i Paitoim hii Vitofto am* *f AMmai 9ap*rMm>ntt,' Cmtof, Haatoii* tow*., l>lS9e 1971. II, Aoarn, j.9^ "toffMH af in* Ngmanmm ImmsM la m*fy<mt*dtoat** !anam yf ta*^ i*r*.M *a*raito* toag*ato*M, U<ll7i 1999. 19. Atm. J.9.. C.A- Cato****, an* 0 A- tof 1MI. "toamgi litoti af Itoft-Tmm. Li* Us* (igaufi *1 Nanmumam mrnt* t* A*y*fii*rmgia9 to*Wanya," ?**Ht, a** A#0. totoWto--l., 19*449. 1974. 11. l9t9t'l. B-A. am* lH. Alton. *f agfyttrtgtmatto topnawyfg *m 9a*rWa*H*m l 19* MftoM*,** 7*Mtttom Rlill to9*e Mi 199. 1979. |1. IgiwiM 9A. Rj. Mato, an* J. 9Aitom. "Riiiwsfito Prt(nfMM tn aaw M to*mmays (agawg t* t*w L*a af Mvtotototto to*mamyM fAmatos IIML" *a*a am* c**. Tnml, m yw. l. Aitom. j.to.e a*. ftofMcii *m# i.e. mi*, **rgaM* MaMiwnas to toan**w ai RftoM 1* Mawnm. QMiftomaa, am* (urMtot *f #*4a99ftoffiata9 to*m#nr4s" Aram. 9*al. Ciwim. TatoaL, tiM, ltf. li HMWtotot RiDw "Mm* Tiawiiv af MytoWMaM Rtotvtyamt ctmtotmn an* RMaM CtoAKiRt11 e*c Cftotoat ** * T*to**l Jam. 1974, *. 449. 19, ACh !*% itoinwiy n "*c 9a m MPto Fggg Mto*to 9*tol*.,` 7*** n Orid* tofWRw gaa*mm*gm. 0-C. <awa*t49a trgm ........tag Ctokl Offto*. bnmi m* 79M99UA )*. Mmaeaupn, " Lf*ar Twman m man aw Mrf )199.r> lr* fto 0*.m. *rep*tfu*entlo.,toft"tWotMmSMyuftetAtada*toart C*mf. MMAfat Oto. It uaftn 1979 90NS 216445