What Happened
Codex Alimentarius Commission (Codex), the international standard-setting body for foods and food ingredients, is approaching Step 7 of 8 in its process to set maximum levels (MLs) on lead in dried culinary herbs and bark spices (such as cinnamon and cassia). The latest draft calls for 2,000 parts per billion (ppb) for the culinary herbs and 2,500 ppb for bark spices.
The draft indicates that 98.1% of the culinary herbs and 95.9% of the bark spices can meet those limits and be considered “as low as reasonably achievable” (ALARA). As we noted in a blog last year, Codex generally assumes for lead contamination that ALARA means that at least 95% of the ingredients must meet the ML. This formulaic approach is not based on health impacts and is contrary to FDA’s Closer to Zero program since it effectively removes the incentive for industry to do any better than the worst 5% of the international marketplace.
In anticipation of the June meeting to consider the draft, the U.S. Delegation, led by USDA and FDA, requested comments on the draft proposal from those who signed up for notice. Unleaded Kids submitted comments on the draft proposal.
We repeated calls asking for the U.S. Delegation to push harder for tighter standards and recommended MLs of 1,000 ppb. This would be the same level that New York State has set for most spices. FDA has yet to set an action level but has recalled cinnamon over 2,000 ppb.
Why it Matters
We explained in our comment that a woman who was a big fan of both cinnamon and culinary herbs and relied on a brand with lead contamination at the draft MLs would have blood lead levels of 28 µg/dL by age 30 based on EPA’s All Ages Lead Model.1 This could happen without her knowledge since only baby food companies are required to test their products for heavy metals and make the results publicly available.
A blood lead level of 28 µg/dL is extraordinarily high according to CDC! The Occupational Safety and Health Administration (OSHA) considers a blood lead level of 25 µg/dL as serious and warrants an inspection. It is just below the level at which the American College of Occupational and Environmental Medicine (ACOEM) and Association of Occupational and Environmental Clinics (AOEC) recommends medical removal from work. And this scenario considers no other source of lead exposure although lead is commonly found in other foods, homes, and workplaces.
If the woman consumed only half the amounts of those big fan who regularly add lots of herbs and spices, her blood lead level would be about 7 µg/dL. This is still more than twice the level at which the ACOEM would advise women who are or may become pregnant to avoid occupational lead exposure that would elevate the BLL to be greater than or equal to 3.5 µg/dL.
The figures below show the distribution of lead levels in dried culinary herbs (Figure 2) and dried bark spices (Figure 3) from the draft document Codex is considering.
Figure 2: Lead concentration data distribution (mg/kg) in dried culinary herbs.
Figure 3: Lead data distribution (mg/kg) in dried bark.
Our Take
Put simply, it is difficult to Make America Healthy Again if food is adding lead to kids’ brains and to people’s hearts.
- We assumed that starting at age 20, the women ate 8.89 grams per day of herbs and 0.4 grams per day of cinnamon, which the document described as a “worst case consumption scenario.” ↩︎