Methods for Monitoring in the Environment
Methods for Monitoring Human Exposure
Safeguards Against Acrylamide Exposure
Absorption, Distribution and Metabolism
Primary Sites for Toxicity
Mechanism of Action
Risk Assessment and Management
Introduction to Policy
Decision Makers and Stakeholders
Policy: DECISION MAKERS AND STAKEHOLDERS
When developing public policy concerning acrylamide, the needs and concerns of all stakeholders and decision-makers must be considered. The primary stakeholders in acrylamide policy include government agencies, research organizations, the food and restaurant industry, consumer advocacy groups and consumers themselves.
Many federal agencies are involved in food regulation and policy in the United States including the Food and Drug Administration (FDA), the United States Department of Agriculture (USDA), the Centers for Disease Control and Prevention (CDC), and the Environmental Protection Agency (EPA). Other federal agencies are involved in food policy, but acrylamide policy in the United States is limited primarily to these agencies.
The FDA oversees all domestic and imported food sold in interstate commerce including shell eggs but excluding meat and poultry. The food safety role of the FSA includes enforcement of food safety laws governing these products by:
- Inspecting food production establishments and food warehouses,
- Reviewing of food additives,
- Developing moral codes, ordinances, guidelines and interpretations,
- Establishing good food manufacturing practices and production standards,
- Working with foreign governments to ensure safety of imported food products,
- Requesting manufacturers to recall unsafe food products and monitoring those recalls,
- Conducting research on food safety
- Educating industry and consumers on safe food handling practices (53).
The FDA has been the primary agency in assessing the need for a policy regulating acrylamide in food in the United States. It has been working in collaboration with other federal agencies in this regard including the USDA, CDC and EPA. The specific actions and goals of the FDA concerning acrylamide policy will be discussed below.
Federal government agencies are actively involved in research to ascertain the need for a policy regulating acrylamide in food. International research and policy developments in addition to worldwide media attention following the Swedish report have provided the impetus for American government agencies to examine this issue. The current consensus is that further research is needed before any policy decisions can be reached. It is also clear that these agencies are seeking the most convenient and inexpensive ways to reduce human exposure to acrylamide. The federal government is also motivated to work with other stakeholders. By working with these other stakeholders, they can minimize cost (agencies involved in research use their own funds to conduct research) and, hopefully, future conflicts. The FDA is also striving to involve the consumers through education programs and risk communication. Consumer involvement has already begun through FDA sponsored public hearings and information on the FDA website. Federal agencies are also concerned about inciting public fears through educational and media campaigns. Specifically, they want to ensure that consumers continue to eat a balanced diet and continue to cook foods thoroughly in order to avoid other food-borne disease (54).
Food-related industries would potentially be greatly impacted by a U.S. policy regulating acrylamide in food. Research to date has revealed certain foods that tend to have higher-than-recommended levels of acrylamide. Industries that produce and serve these foods would be most heavily impacted. Acrylamide can form in foods during both the production and preparation of foods, so the restaurant industry would be affected as well. If a policy were put in place to regulate acrylamide in food, these industries would incur increased costs to control the levels. They would also be subject to increased risk of litigation. In extreme cases, they may have to abandon production or service of foods whose levels could not be brought into the acceptable range. Even if public policy were limited to consumer education, the food industries would be affected. Media attention and public concern could also lead to decreased demand for their products in addition to increased risk of litigation for these industries. Food labeling requirements could have these same effects. In summary, food-related industries would not be motivated to support public policy of any sort to regulate acrylamide in food. However, given that policy discussions are proceeding at the government level, these industries are motivated to be involved in order to develop policy that incurs the least cost and risk for them. As discussed above, food-related industries have been invited by the FDA to participate in research. Since the FDA does not control the funding and work of independent researchers, there is the risk that such research could be biased.
Consumer Advocacy Groups
Consumer advocacy groups work to develop research and policy that protect public interests. The Center for Science in the Public Interest (CSPI) is an advocacy group whose primary focus is health and nutrition. The following is CSPIs mission statement: The Center for Science in the Public Interest (CSPI) is a consumer advocacy organization whose twin missions are to conduct innovative research and advocacy programs in health and nutrition, and to provide consumers with current, useful information about their health and well-being (B3). In June 2003, CSPI released a Petition to Establish Interim Acceptable Levels for Acrylamide in Major Food Sources. The recommendations of this petition include:
- Set interim acceptable limits on the amount of acrylamide for categories of food that provide the most acrylamide to Americans (with particularly protective limits for infant formulas and baby foods)
- Deem any foods whose levels exceed this limit to be adulterated because it bears or contains any poisonous or deleterious substance which may render it injurious to health (as defined by the Federal Food, Drug and Cosmetic Act). Under the Federal Food, Drug and Cosmetic Act, the FDA has the authority to seize adulterated food and to seek criminal penalties against someone selling it.
- Use best available industry practices to set interim acceptable limits for acrylamide in different classes of food.
- Encourage food companies to test their foods for acrylamide levels and provide this data on a confidential basis. Acceptable limits for classes of food could then be established using the median value of sampled brands for each class of food. Ample data on certain classes of food already exist that may be used to set the limit for these foods. Other classes of food will require more data collection before this limit could be set.
- Food companies whose products exceed the acceptable limit will be expected to either stop selling their product or modify manufacturing practices in order to get the level below the acceptable limit. Companies who do not comply are subject to enforcement under the Adulterated Food section of the Federal Food, Drug and Cosmetic Act (55).
Consumer advocacy groups such as CSPI are motivated by their desire to protect consumer health and well being. Their recommendations tend to be more restrictive with emphasis on policies that enforce stricter regulations. Often, as in the case with acrylamide, their recommendations are in opposition to the wants of industry.
Consumer education regarding acrylamide in food is limited at this point. The report from the Swedish researchers did generate media attention worldwide. However, little media attention has been given to the issue since its release in 2002. In the United States consumer education has primarily been limited to public meetings and internet articles. These sources are not accessible to many consumers. Many consumers would be in favor of a more extensive education program that is accessible to more people. Once consumers are aware of the risks posed by acrylamide in food, they will be able to make more informed choices about what they eat. However, if the policy is overly restrictive, consumers may face changes in their favorite foods or even elimination of some of these foods. For example, if their favorite brand of French fries has an unacceptably high level of acrylamide, the producers may need to change their recipe or even discontinue production. Therefore, many consumers would likely not favor strict regulations of these foods unless the risk is very high for them. However, many consumers would likely favor some degree of regulation so that they do not have to worry about acrylamide in everything they eat.