COOPERATIVE EXTENSION UNIVERSITY OF CALIFORNIA
ENVIRONMENTAL TOXICOLOGY NEWSLETTER

Vol. 9 No. 1 February 1989

FOOD SAFETY ISSUES

TABLE OF CONTENTS

I. Introduction
II. Appreciating Consumer Food Fears
III. Independent Testing of Foods for Pesticide Residues
IV. Food Safety and Pesticide Enforcement Initiative
V. Veterinary Toxicology Notes: Drug Storage on Dairy Farms

I. Introduction

The presence of pesticide and drug residues in foods continues to be a public issue of concern, and there are very good reasons why this is so. One reason is the attention it gets in the media, and the fact that some enterprising individuals have used this concern to develop businesses that provide private testing to help prevent exposure to these residues. The premise used in advertising these programs is that such residues are "harmful" (I have seen this stated point-blank, on signs in one market). Indeed, such programs could not be successful marketing strategies unless pesticide residues are perceived to be harmful.

To people who perceive that pesticide or drug residues in foods are harmful, they ARE harmful; their perception is their reality. While such residues do not cause me concern as a toxicologist, they may be of considerable concern to others with different life experience. These concerns are all based on health, and as such they are rather emotional issues. In many cases, discussing such emotional issues from an intellectual perspective (offering facts) results in no communication. If we are to be effective in addressing peoples concerns about residues in foods, it is necessary to understand why they are concerned, which means that the communication of information must be in two directions.

Dr. Helene Swenerton, Nutrition Specialist, UCD, recently sent me an article published in Food Engineering. The author, Dr. Kristen McNutt is the president of Consumer Choices Unlimited, Inc., and she has a Ph.D. and is also a lawyer. I wrote to Dr. McNutt and requested permission to reprint this article in the ETOX newsletter, because I believe it is one of the most comprehensive and concise statements that I have seen about the current situation. Dr. McNutt quickly and graciously assented to having it reprinted, for which I am very grateful. Those of us involved in public communication must become more aware of the importance of addressing food safety issues from the point of view of the public, not from our own, otherwise we will be doomed to continued failure to address their real concerns. We must also be more willing to spend more time communicating with the consumers who are not familiar with agriculture; urban populations who have little or no familiarity with pesticide or drug use in food production. This means developing newclientele, non-traditional clientele in the sense that they are not agricultural producers at all. Such programs will become more and more important as the interface between agricultural and urban communities expand, which is sure to happen in a state whose population grew by more than 700,000 last year.

Also included in this issue is an article written by Dr. Carl Winter about one of the commercial pesticide residue testing programs currently operating in California. I think you will find it very interesting, and particularly relevant to Dr. McNutt's article.

II. Appreciating Consumer Food Fears

Kristen McNutt, Ph.D., J.D.

Most people I know are afraid of something. A manager claims to be too busy to donate blood but really is frightened of doing so. A financially successful neighbor has never traveled out of the U.S. because his inability to understand foreign languages makes him feel vulnerable. A special friend is uncomfortable flying in airplanes and I can't relax when the dental hygienist simply cleans my teeth. Some of my friends' fears seem irrational to me and mine to them, but that makes them no less real.

The failure of scientists and business executives to appreciate consumer food fears is another example of one person's choice seeming unreasonable to another. Our inability to appreciate their perspective has created significant problems for the food industry. Proposition 65 is already draining dollars from more productive investments and costing business and consumers dearly. Reducing preservatives in food because of consumer fears could compromise the level of safety traditionally enjoyed by many products. Unless we learn to understand each other better, useful technologies such as irradiation and biotechnology might be rejected and new products die on the shelves. Both the industry and the public lose.

Why We Can't Understand

Most discussions I have heard in scientific and business circles regarding consumer attitudes about food safety start with the premise that consumers are wrong. Rarely do my peers acknowledge that we, the learned experts, might need to make some changes ourselves.

Half of communications is listening, a difficult skill for people who start with the assumption that they are always right. Far too often, as soon as we hear something with which we disagree, a mental switch flips. We stop hearing and thereafter concentrate only on how to correct the speaker's "misinformed" view.

Graduate student food technology seminars train us to defend our position rather than stress the weaknesses in our data interpretation. Business schools emphasize thinking through competitors' strategies, but ultimately engrain into MBAs the same commitment to proving the validity of one's own perspective rather than understanding those who oppose it. Lawyers, in contrast, realize they must know the opposition's arguments as well as their own, but rarely are they intracorporate consumer advocates.

Another deterrent to our appreciating consumer concerns is, ironically, the objective thinking that is so critical to being good scientists and effective business managers. Career advancement comes from controlling our emotions, ruling out unproven considerations, and emphasizing only quantifiable factors. If we can't measure it in the lab or in dollars and cents, we rule it out of our analysis.

Lastly, even our expertise per se impairs our ability to discuss food safety in a meaningful way with consumers. Because we can't talk in language they understand, we conclude they are unable to make risk assessments for themselves. The fault then becomes theirs, not ours.

The dilemma spirals downward when our proposed solution is their trusting us because, we say, the science is too complicated for them to understand. Our perception of their ignorance makes us reluctant to admit risk which is real, though small in our opinion. Their natural reaction is to suspect that we are hiding something bad from them.

Scientists' trivializing, even laughing at, consumers' fears of chemistry is evidence of our insensitivity. Perhaps we should examine some chinks in our own armour. I had friends in high school who refused to take chemistry because they were afraid of being hurt in the lab, not just worried about failing the course. Their fears were no sillier than my dreading gym class because of the embarrassment of my repeatedly missing the basket. Our valedictorian would have been humiliated had he been required to take shop.

Why Consumers Are Afraid

Consumers' concerns about food safety go far beyond hazards that can be measured in LD-50s or other quantifications of toxicity. The data we use to prove safety, numerical probabilities and statistical significance, are not very persuasive to people who worry about nonscientific variables.

Fear of the unknown is high on the list of consumer concerns. For many people, it is easier to confront a serious danger than to cope with not knowing how dangerous something is. Consumer concern about any risk possibly related to cancer, and more recently to AIDS, cannot be separated from their fear of the unknown. The risk of food poisoning, even heart disease, is easier to cope with because the causes seem better understood.

Weighing human health hazards against dollars is emotionally difficult, even for some economists and risk assessment experts. It's an even tougher concept for nonscientists although they do it, probably subconsciously, quite often in their daily routines. Consumers compare price and safety when choosing among lawnmowers, selecting a home security system, and deciding between generic and prescription drugs. But these choices do not require them to put a specific price on one life or calculate the hospital bills if their bargain does not deliver as well as the more expensive alternative. When food safety risks are reduced to such measures, this balancing of life versus dollars is far more offensive. If the benefits of a technology or ingredient yield dividends for stockholders but no relief for consumers at the cash register, it is no surprise that they give more careful scrutiny to whatever risk might accrue to them.

Our current quantitations of safety omit many considerations important to consumers. Since these variables seem scientifically irrational to us, we leave them out of our neat calculations. From a common sense point of view, their evaluation criteria are reasonable but rarely have I heard a scientist acknowledge their importance.

They, but not we, would include in the food safety assessment formula a factor to measure who makes the decision. The closer the choice is to the consumer, the more positive is the value of taking that risk. Most people would also add an index which measures whether the risk is voluntary versus something imposed on them without choice. Manmade risks lose points; risks imposed by nature are easier to swallow.

Other considerations overlooked by the experts but important to many consumers hinge primarily on moral values. The comparison is between good and evil, not safe or unsafe. If allowing a risk gives an advantage to the big guy over the small one, it is far less than worth taking. If the risk affects some people more than others, most consumers would rule against it on grounds of unfairness. Potential harm to children or others less capable of protecting themselves is far worse than imposing risk on others. If the danger cannot be easily recognized, it is more offensive. If it is purposely hidden, their response is defiant rejection.

Consumer assessment of risk is also influenced by simple human nature. Harm at a later date seems less risky than being hurt tomorrow. Dangers which are acute are more threatening than those which are chronic. Things they have already experienced are not as upsetting as those which have never happened before.

Mandate for Change

Learning how to improve communications about food safety is becoming even more critical. The goal is not to eliminate consumer fears but to put them in perspective. Apathy about food safety is far more dangerous to the food industry, as well as to consumers, than is their exaggerated fear.

New refrigerated products and greater sales from the deli case mandate our helping consumers understand the responsibility they share with manufacturers and retailers for the safety of these products.

The generation doing most of the cooking today grew up with canned or frozen products which required less care in the home. Men, with varying degrees of enthusiasm, are fixing food even though their mothers never taught them how to cook, much less instilled in them basic food safety precautions in the kitchen. New equipment such as ice cream makers and home preservation accessories, is creating a different and challenging environment for safely preparing foods at home.

What Can We Do?

Some of the needed changes fall to consumers, but they aren't reading this column. How can the readers of Food Engineering help resolve the current situation?

• Listen to consumers, your neighbors, friends and family...beyond the point when you disagree.
• Unmask your feelings. Sometimes all consumers need is to know that you understand that they are afraid. Letting them know you hear them can reduce their anxiety and clear the way for exchanging ideas.
• Respect their intelligence. They deserve it.
• Factor their concerns into your calculations. They are the ones being asked to take the risk.
• Be honest about real risk, regardless of how small. If you are afraid to give the straight facts about carcinogenicity and toxicity, you feed the consumer misconception that they should fear any level of risk.
• Make as much information available as is reasonably possible. Don't prejudge their reactions, hide the truth or try to protect them from their ignorance.
• Stop giving cliched responses such as "we have the safest food supply in the world." This may be true but it is irrelevant to the concerns consumers want to hear.
• Learn from consumers and let your own common sense into the reasoning process. Giving credence to nonscientific values does not negate scientific assessments.
• Your willingness to believe them could be the first step in their being willing to believe you.

Reprinted from Food Engineering, September 1988

III. Independent Testing of Foods for Pesticide Residues

Carl K. Winter, Ph.D.
Extension Toxicologist
University of California, Riverside

The recent increase in consumer concern regarding pesticides in the food supply has led to the birth of a new phenomenon in the food industry - independent testing of foods for pesticide residues and certification of foods as being "clean" or "residue- free" following analysis.

Independent testing of foods has proven to be a widely publicized and highly controversial item. Consumer advocates and environmentalists have supported these new programs, citing that such programs offer consumers additional choice and protection from the potential hazards of pesticide residues. On the other hand, the majority of agricultural producers, government agencies, and University scientists have opposed these programs on the grounds that independent testing programs are marketing gimmicks that prey upon consumer concerns by promoting fear and misinformation. Opponents of the programs maintain that the programs are unnecessary due to the insignificant risk posed by pesticides in the food chain and serve to undermine the much more comprehensive pesticide testing programs by State and Federal agencies that are already in existence.

The most active independent certification service in this controversy is an Oakland, California operation called NutriClean. This firm has engaged in contracts with a number of California produce growers and with major California retailers such as Raley's in Northern California and Ralph's and Irvine Ranch Farmers Market in Southern California. A couple of smaller retailers in the Bay Area are also using the service. Nutriclean also currently does business with retailers and growers in the Pacific Northwest, Michigan, and Virginia.

NutriClean offers two basic programs. One of these is a Dock Screening program which involves retail-level monitoring of fresh fruits and vegetables. The other program is a Certification Program that allows growers to make "no detected residue" claims on their products from specific fields.

The Dock Screening program involves a very limited and random sampling of fresh fruits and vegetables purchased by retailers who have paid to participate in the NutriClean program. NutriClean's 1988 Dock Screening program sampled only nine fruits and vegetables - oranges, apples, potatoes, tomatoes, peaches, grapes, carrots, corn, and lettuce, and analyzed for only 14 pesticides. At the present time, a few additional commodities have been added to this program and chemical analysis has been expanded to include a few additional pesticides.

NutriClean maintains that the Dock Screening program provides participating retailers with information about pesticide residue findings from specific suppliers. This information may allow the retailers to determine which suppliers are offering fruits and vegetables with the lowest levels of pesticide residues. In the event of the detection of illegal residue levels, NutriClean is required to notify the appropriate enforcement agency. It should be noted that food shown to contain detectable, but legal, levels of pesticide residues following chemical analysis in this program is still sold in the produce sections of the markets of the participating retailers.

The Certification program offered by NutriClean is paid for by participating growers. Growers involved in this program are required to submit full disclosure of all pesticides applied to their products during all stages of production, from seed treatment through post-harvest production. Following the final pesticide application, "worst-case" field samples are taken and analyzed by laboratories contracted by NutriClean for residues of any of the pesticides used by the grower that might be expected to leave residues on the final food product.

If laboratory results indicate that residues of the pesticides from the grower's disclosure list are not detected, the product is certified to be "free" of detectable pesticide residues. This food is marketed as "containing no detectable residues" in the markets of retailers who also participate in the program. Produce certified in this fashion is not allowed to be advertised as "containing no detectable residues" in markets that do not participate in the NutriClean program. Again, as is the case with food analyzed in the Dock Screening program, if legal residues are detected, the food will still be sold but will not be advertised as "containing no detectable residues."

On the surface, it might appear that the NutriClean programs are providing a valuable service to concerned consumers. A 1987 consumer attitude survey indicated that over three-fourths of consumers view pesticide residues in foods as a serious matter of concern. This is reflected in the success of NutriClean's program at the retail level. One Raley's executive recently indicated that the response to the program was unprecedented and that Raley's was having difficulties keeping the NutriClean- certified products on the shelves. Although the majority of the scientific community considers the risks from pesticide residues in foods to be insignificant, what can be the harm in providing additional testing of residues for consumers who are unaware of the relative risks or are skeptical of the views expressed by scientists and government agencies?

From a purely economic standpoint, it should be pointed out that NutriClean is in business to make money. Retailers and growers involved in the NutriClean program are footing the bill to participate in the service. The cost of chemical analysis is significant. A single, routine analysis may cost several hundred dollars and specific tests for chemicals that are difficult to detect may increase these initial costs dramatically. The costs of the retailers and growers for their participation in the NutriClean program must be recovered; most often, consumers are ultimately required to pay for this service in the form of increased food prices.

The presence of the NutriClean program and the subsequent amount of media and consumer attention it has received has fostered the development of several important and inappropriate implications.

The first implication is that the foods certified to be free of residues are safer than foods which have not been certified. It is somewhat ironic that the same foods certified at Raley's are also sold to other retailers who do not advertise that the foods are free of residues. Additionally, the majority of food items tested by government agencies using far more comprehensive testing have also been shown not to contain detectable levels of pesticides. As an example, results from the California Department of Food and Agriculture's (CDFA) routine marketplace sampling program, which analyzed over 7,000 food samples for residues of over 100 different pesticides from more than 200 types of foods in 1987, showed that no residues were detected in 80 percent of the samples.

Our preoccupation to desire fruits and vegetables that are free of pesticide residues also erroneously implies that any detectable level of a pesticide residue represents a health hazard. This violates the fundamental principle of toxicology that states that the risk associated with a chemical depends both upon the toxicity of the chemical as well as the amount of exposure to the chemical. Scientific evidence has shown that foods containing small amounts of pesticide residues do not appear to pose risks significantly greater than foods from which residues have not been detected. This is particularly important when one considers that our analytical capabilities allow for the detection of residues at extremely low levels. Routinely, pesticides can be detected in foods at levels below one part per million, which is roughly equivalent to about one ounce of a material in more than thirty tons. Residue findings involving tens of thousands of analyses over the past decade have indicated that typical human exposure to pesticide residues in foods is at levels about one hundred thousand times below the levels which have caused even minimal toxic effects in laboratory animals.

The creation and acceptance of the NutriClean program has also led to the implication that State and Federal residue testing programs are inadequate. In actuality, the government programs are far more comprehensive than NutriClean's program. In 1987 alone, CDFA analyzed over 13,000 food samples for pesticide residues. From 1982 to 1986, the U.S. Food and Drug Administration's (FDA) Los Angeles District Laboratory analyzed nearly 20,000 samples. While NutriClean's program routinely analyzes for only a handful of different pesticides, CDFA's program routinely screens for over 100 and FDA's program screens for over 200. Other existing CDFA and FDA residue analysis programs are capable of the detection of several other pesticides that cannot be analyzed using the routine screening procedures.

Consumer concerns about pesticide residues in their foods, which appear to be heightened through the existence of firms such as NutriClean, have led many consumers to change their purchasing habits. A recent survey indicated that 18 percent of consumers are now taking additional steps to minimize their exposure to pesticide residues by taking actions such as buying more organically-grown produce (at a greater cost) or purchasing only produce that has been grown in season. It has been proposed that both approaches could theoretically increase the health risks of consumers. Consumption of organic produce may increase human exposure to naturally-occurring toxins since many of these chemicals are produced in greater amounts when plants are subjected to stress from insects, weeds, and fungi. In many cases, the use of pesticides, or other cultural or biological processes, may reduce plant stress and subsequently decrease levels of natural toxins. Reliance on produce that has been grown in season may serve to decrease total consumption of fruits and vegetables. Recent scientific evidence has indicated that consumption of such foods may reduce the risk of some human cancers.

The greatest problem with our emphasis on the insignificant risks from pesticide residues in foods is that it clouds our ability to focus upon much more important concerns. In the area of food safety, there are significant areas of concern which are largely ignored. In terms of food safety priorities, the FDA considers pesticide residues in foods as only its fifth priority, and far less of a concern than 1) microbial contamination of foods (deaths occur every year from microbial contamination), 2) nutritional imbalance and malnutrition, 3) environmental contaminants, such as lead and mercury, and 4) naturally- occurring toxins. In the area of pesticides, a far greater potential for human health effects exists for pesticide applicators and for field workers. In both cases, numerous poisoning cases are reported in California each year. As a result of the widespread concern regarding pesticide residues, fueled by operations such as NutriClean, the public is desiring additional government testing of pesticide residues, which would appear to be a poor use of the taxpayers' dollars. The money would be much better spent on the more serious food safety and pesticide safety concerns.

In summary, while the NutriClean program would appear to be a reasonable and legitimate service provided to responsible food retailers and to concerned citizens, it may ultimately serve to the detriment of the consumer. Independent, commercial testing of foods for pesticide residues may promote fear, perpetuate misinformation, and increase the public's distrust of effective regulatory programs. It also hurts consumers in the pocketbook and influences the allocation of valuable and finite government resources to insignificant issues while neglecting more important ones.

IV. Food Safety and Pesticide Enforcement Initiative

John Kabashima (Farm Advisor in Orange County) recently gave me a copy of some literature sent out from Assemblyman Lloyd Connelly's office about plans to institute a new initiative called the "Food Safety and Pesticide Enforcement Initiative." Briefly, this initiative would require that no pesticide could be used in California unless it can be proven safe, and that it will not leave unsafe residues in or on foods. It would also require the state to test processed foods for pesticide residues. To quote from the literature, "We can stop the spread of deadly pesticides on our food."

Included in the literature is part of an article presumably taken from the San Francisco Chronicle titled "Half of Food Pesticides Undetected". Included in this article is this statement: "Recent polls, including a nationwide survey this year by the Food Marketing Institute, have found that pesticide contamination is the top food worry of consumers, but the OTA (Office of Technology Assessment) report said regulators place greatest emphasis on food contamination by microorganisms and drugs." This statement suggests that regulators are not addressing the most important problems. What it actually means is that consumer concerns do not reflect the measurable food hazards. I base this statement on information that was received from the office of Dr. George Meyerholz, Program Leader for Veterinary Medicine, USDA Extension Service, and dated December 15, 1988. The data specifically relate to animals and animal products, however they demonstrate just why our regulators are so concerned with microbial contamination of foods. I am presenting only portions of the article he sent, but would be pleased to supply the entire article to anyone who is interested.

According to Food and Drug (FDA) estimates, 33 million Americans contract foodborne illness annually. About $420 million are spent on medical costs and $7.3 billion lost because of reduced productivity annually.

According to testimony before the Senate Committee on Agriculture, Nutrition and Forestry in 1987, three major foodborne diseases caused the following estimated losses: 1) salmonellosis, $553 million, 2) campylobacteriosis, $723 million, and 3) congenital toxoplasmosis, $215 million. Trichinosis, beef tapeworm, brucellosis, listeriosis and other foodborne diseases caused much smaller losses. However, diseases can be severe for some high risk populations such as elderly, ill and very young in our society.

However, the majority of foodborne outbreaks occur as the result of improper attention to detail in food service establishments and in the home according to a scientific status summary prepared by the Institute of Food Technologists Expert Panel on Food Safety and Nutrition.

The Federal Government spends approximately $520 million annually protecting our food. Regulatory action, surveillance andeducation help to reduce microbiologic contamination and food borne illnesses. Education programs are needed to teach producers, processors, food handlers and consumers good practices to increase food quality and safety programs. Consumers also need to be educated on how animals are produced to provide plentiful, wholesome, safe and reasonably priced food.

There are very good reasons why our regulators put major emphasis on microbial contamination of foods, and there are very good reasons why consumers are more afraid of pesticide residues in foods. Our job in Extension is to help provide a wide perspective that is so often lacking in sensationalistic literature.

V. Veterinary Toxicology Notes: Drug Storage on Dairy Farms

Dairymen are being debited on their inspection by an authorized sanitarian if animal drugs are improperly stored in the dairy barn. Current regulations as described in the pasteurized milk ordinance mandate that:

• Only cattle drugs be stored in the dairy barn.
• Drugs approved for lactating cow use be stored separately from drugs not approved for lactating cow use. Inspectors have generally accepted separate shelves in the same medicine cabinet or refrigerator as long as the shelves are clearly marked "Lactating cows," "Not for lactating cows."
• Prescription drugs and drugs repackaged by the veterinarian for dispensing must be clearly labelled, including use directions, withdrawal/withholding times, precautions, veterinarian's name and address. Date of dispensing and expiration date should also be included.
• Inspectors have generally not debited dairymen for storage of such products as topical medication, vitamins, minerals, saline or aspirin in the dairy barn.

The purpose of this regulation is to reduce the risk of inadvertent contamination of milk supply with non-lactating cattle medicine or non-cattle-approved products. If a dairyman is in doubt about current enforcement of this regulation in his area, he should contact his approved sanitarian. Practitioners need to properly label dispensed drugs, maintain records of drugs dispensed and their directions, and advise clients on proper storage of medications.

Larry Hutchinson, Extension Veterinarian, Pennsylvania State University in PSU Herd Health Memo, December 1988.

Art Craigmill
Extension Toxicologist
UC Davis

Carl Winter
Extension Toxicologist
UC Riverside

Mike Stimmann
Statewide Pesticide Coordinator
UC Davis