Chicken Fillets to Chicken Toys - The Uncertainty in Regulating Against Persistent Organic Pollutants
Persistent organic pollutants (POPs) were responsible for the recall of nearly 160,000kg of Chilean chicken entering the US, and the banning of the plastic toy named ‘Shrilling Chicken’ by two European countries. What is striking, and similar, in both these cases is the fact that while one country may recall or ban consumer goods for POPs contamination, it does not necessarily mean the same goods will automatically be banned or eliminated from all markets.
The real danger from POPs is the uncertainty in what constitutes ‘safe’ levels, if that can even be established, and the inability to create a homogenous regulatory platform to control POPs on a global scale. In the instance of the Chilean chicken, the USDA’s Food Safety and Inspection Service (FSIS) instigated no recall of their own as they deemed the chicken of ‘negligible risk to consumers’ and had already allowed over 80,000kg to be distributed in the US, leaving it to the government of Chile to notify US officials1 that the chicken tested positive for dioxins. While in the case of the ‘Shrilling Chicken’, the toy was included in the Rapid Alert System for Non-Food Dangerous Products. (RAPEX) Report 2013-33 notified by Sweden2 due to the presence of up to 10 percent short chain chlorinated paraffins (SCCPs); it was also in a subsequent notification and ban for other reasons than POPs in the Czech Republic in 2014 (RAPEX 2014-29)3, but its first appearance in RAPEX dates back to 2008 (RAPEX 2008-10)4.
WHAT ARE POPs?
As a result of the chemical revolution at the turn of the 20th century, agriculture and industry by the post-war 1940s were sold on the promise of increased efficiency methods in pest and disease control, crop production and industrial applications from the widespread proliferation of thousands of new chemical compounds. What no one realised however was that once released into the world these chemical substances were here to stay – hence the name persistent organic pollutants (POPs).
POPs are resistant to photolytic, biological and chemical degradation, and their properties allow them to travel thousands of kilometres in the atmosphere and hydrosphere, despite their lipophilicity, before deposition and eventual transfer into the global food chain.
The dangers of even low concentrations of POPs making their way into the food chain have been well researched, with toxicity to humans and wildlife (especially marine) suspected to cause among others: carcinogenesis, immune dysfunction, neurobiological disorders and reproductive and endocrine disruption. It is because of these dangers, highlighted during the many high profile cases in the 1960s and 1970s, that regulation and control of POPs is now a worldwide concern.
The major paths of POPs exposure to humans are:
- Food: via POPs deposition on land and in waterways then invertebrate-to- animal-to-human food chains; plus residues in foodstuffs
- Soil: via global distillation of POPs followed by human ingestion or absorption through skin; persistent residues of banned POPs
- Indoor: via air and dust contamination from materials in buildings, furnishings, packing materials, and electronic and electrical appliances containing PCBs, PBDEs, SCCPs
- Toys and other products: via chemical ingestion from placing object in mouth (i.e. SCCP)
- Air: via fumes produced from burning of items containing PCBs, PBDEs; heating of transformers or burning of various waste materials
- Wearing: via wearing, human absorbs POPs (i.e. PFOS)
GLOBAL AGREEMENTS AND EU/US REGULATIONS RELATED TO POPS
Several international agreements exist related to POPs control, including but not limited to:
- The Stockholm Convention (in effect since 2004)
- United Nations Economic Cooperation for Europe (UNECE) Protocol to the 1979 Convention on Long-Range Transboundary Air Pollution on Persistent Organic Pollutants (in effect since 1998)
- Aarhus Protocol On Persistent Organic Pollutants (In effect Since October 2003) Established In 1998
- Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal (in effect since 1992) established in 1989
- OSPAR Convention for the Protection of the Marine Environment of the North-East Atlantic (in effect since 1998)
- Rotterdam Protocol on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade (in effect since February 2004) established in 1998
In the EU specifically, POPs control falls under the Regulation (EC) No 850/2004 (including amendments)5 which implements the requirements of the Stockholm Convention6 and the UNECE POPs Protocol7: while in the US8, at least six different governmental agencies combine to combat the threat of POPs to the environment and consumers. Yet understanding the complexities of how to keep consumer goods and feed or foodstuff within the myriad levels of acceptance within the various EU/US regulatory bodies is a complex and demanding task.
Further information on POPs, how to ensure compliance to regulations controlling their use in consumer goods, the contamination of feed and foodstuff, and best practice recommendations for any manufacture involved in goods which may be subject to POPs can be found in a soon to be released SGS white paper. To pre-register for a copy please click here.
5 EU Commission - Persistent Organic Pollutants
6 Stockholm Convention
7 UNECE - Protocol on Persistent Organic Pollutants
8 US EPA - POPs - A Global Issue, A Global Response