Best Practices for Chemical Hazards

Chemical hazards present a rollercoaster of risk for food producers and processors, in part because chemicals themselves are introduced to food systems from a broad mix of sources and through an array of applications. Chemicals used in food production and handling environments can be naturally occurring in air, water, or soil or they can be man-made. They can be used as food additives or compounds for formulation and functionality in final products, in cleaners, sanitizers, and detergents used on food-contact surfaces and equipment in food facilities, and in pesticides or herbicides at on-farm operations.

Chemicals, whether present in foods unintentionally or intentionally, pose a hazard when their levels become harmful to humans, either due to unintentional addition or excessive presence. The best way to mitigate the risks posed by chemical contaminants—whether allergens, mycotoxins, or toxic chemicals—requires a strong Hazard Analysis and Critical Control Points (HACCP) program. A robust hazard analysis will enable the food producer or processor to identify potential chemical hazards associated with raw materials, processes, and final products, and effective CCPs will put in place the actions, measures, and controls that will prevent, eliminate, or reduce those hazards.

Here are some suggested best practices to help mitigate chemical hazard risks that not only are current challenges for today’s food industry but have made recent headlines.

Synthetic or Man-Made Chemicals

Per- and polyfluoroalkyl substances (PFAS), a group of synthetic chemicals widely used in industrial and consumer goods products, have garnered a lot of attention from the clinical and regulatory communities in recent years. Termed “forever chemicals,” PFAS persist in the environment and are unintentionally added to foods in which they come into contact. These chemical substances are known for their water- and grease-resistant properties and are utilized by the food industry for several food-contact applications. Four types of PFAS have been authorized by the U.S. Food and Drug Administration (FDA) for use in making non-stick coating for cookware, as a durable resin for gaskets and other food processing equipment components, as processing aids for making other food-contact polymers, and in paper/paperboard food packaging as grease- and leak-resistant containers such as fast-food wrappers and microwave popcorn bags.

However, there are thousands of different PFAS compounds, and some have been shown to be hazardous to human health. Some of the most studied include perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS). These two specific PFAS chemicals have been detected in both the environment and in human blood samples worldwide, and initial studies have associated them with infertility, stunted human growth and development, injury to the liver, and cancer.

Notably, litigation involving major manufacturers such as DuPont and 3M, makers of Teflon and GORTEX, adds urgency to addressing this issue. Regulatory bodies and environmental agencies in various countries are working to establish guidelines and regulations to monitor and control PFAS contamination, including the 2021 U.S. initiative that was launched by the Biden-Harris Administration to tackle PFAS pollution (PFAS Roadmap 2021). Efforts are underway to find alternatives that possess similar functional properties of PFAS but without the associated environmental and health risks. However, the full extent of the health risks associated with PFAS exposure is still being researched and scientists are working to better understand the potential long-term effects of PFAS on the environment, people, and animals.

Best Practice: Identify potential sources through a comprehensive risk assessment in the facility, production processes, and supply chain. Select PFAS-free materials by choosing food packaging and processing equipment that are PFAS-free. Have a robust supplier assurance program and work with your suppliers, manufacturers, and co-manufacturers to use alternative materials without the need for PFAS. Also, assess your supply chain to ensure that the materials and products you are using do not contain PFAS. For example, request documentation and samples of the materials used in packaging. Test and monitor your products regularly for the presence of PFAS, including both raw materials and finished products. Finally, stay informed about the latest regulations and guidelines related to PFAS in food and beverage, which tend to be fluid, to ensure compliance with any new or updated regulations.

Chemical Compounds and Food Additives

The chemical compound known as brominated vegetable oil (BVO) is a complex mixture of triglycerides treated with bromine, which has been used as a food additive in the United States since the 1920s. BVO has the unique property of increasing the solubility of flavoring agents in beverages, preventing them from separating and floating to the surface. This makes the flavor more consistent throughout the product. It is often used in beverages like sodas and sports drinks that contain citrus oils, which can be challenging to blend with water-based solutions.

However, after the state of California banned its use last fall, citing evidence of negative health effects on humans, the FDA announced that it also would consider revoking the federal regulation authorizing the use of BVO based on recent clinical studies (FDA 2023). Scrutiny arose from the bromine content, especially in cases of overconsumption leading to iodine deficiency and potential related health issues like thyroid dysfunction. According to the agency’s website, “The FDA conducted studies that clearly show adverse health effects in animals and in levels more closely approximating real-world exposure. Therefore, the FDA can no longer conclude that this use of BVO in food is safe.” The studies were done in collaboration with the National Institute of Environmental Health Sciences’ Division of Translational Toxicology. The results from the studies “demonstrate bioaccumulation of metabolism, and toxic effects on the thyroid—a gland that produces hormones that play a key role in regulating blood pressure, body temperature, heart rate, metabolism and the reaction of the body to other hormones,” the website stated. The comment period on the revocation of authorization for use of BVO in food ended on Jan. 17, 2024.

Best Practice: Again, it is important to stay informed about regulations as they may change based on new scientific knowledge about the amounts of chemical compounds or food additives that can be safely included in products. If evidence begins to mount indicating that a food additive may be considered a chemical contaminant, the best practice is to look for alternative ingredients that are considered safe. A good example is that some beverage manufacturers have opted to reformulate their products to remove BVO or use alternative emulsifiers long before regulations require them to do so.

Naturally Occurring Chemical Contaminants

Many people may not realize it, but the soil in which we grow crops plays a crucial role in the safety and quality of the final food products we eat. Sometimes, the soil contains tiny amounts of substances called heavy metals that, when too much is present, can affect the safety of the crops. Examples of heavy metals include lead, mercury, cadmium, arsenic, nickel, and chromium, among others. These metals are found in the earth’s crust and can be released into the environment through natural processes such as weathering of rocks and volcanic activity.

While they are naturally occurring, human activities such as industrial processes, mining, and the use of certain agricultural and technological practices can significantly increase the levels of these metals in the environment. Elevated concentrations of heavy metals can pose environmental and health risks, as they may be absorbed by and accumulate in soil, water, and other organisms, including plants and animals. As a result, traces of dangerous heavy metals have been found in foods from rice and cereals to nuts and spinach. The challenge of foodborne metal contamination has gained heightened significance, underscored by recent studies revealing a link between exposure to heavy metalsin food and the risk of cancers and other life-threatening diseases. Reports also have highlighted elevated metal levels in infant food, prompting removal from retail shelves, and notably, excessive lead levels detected in children’s fruit puree pouches.

Achieving zero contaminants, chemical or otherwise, in the environment is challenging. Ongoing legal cases, such as Perrigo v. State of California, highlight the complexities, especially in products like dry infant formula. The FDA’s Closer to Zero initiative launched in 2021 is the regulatory action plan for reducing exposure to chemical contaminants, including lead, arsenic, cadmium, and mercury, in foods made for babies and young children, one of our most vulnerable and high-risk populations (FDA 2021).

Best Practice: First, employ interdisciplinary research involving geologists, soil scientists, farmers, and experts in other relevant fields to address heavy metal issues, and then, modify soil pH to reduce chemical contaminants in crops at the front end of the value chain. Just as chefs taste their dishes before serving to ensure quality, scientists and farmers test the soil to see that its composition is of good quality for growing crops. If it has too many metals, it’s time to make some adjustments, so the first step or best practice is to test the soil.

The next step is a bit like adding ingredients to a mixing bowl, which is to make a pH adjustment. We use substances, often natural ones, to make the soil more acidic or less acidic, depending on what the plants need. Think of it as a recipe—sometimes you add a pinch of salt to balance the flavors. In our soil recipe, adjusting the pH is like that pinch of salt, which ensures our plants get the right nutrients without taking in too many heavy metals.

These steps are not a one-time fix; therefore, continuous monitoring is the crucial final step where we keep an eye on the soil, making sure it stays just right for the plants. Simply put, happy soil equals happy plants.ft