Food Safety Analysis, LLC


Consumer Oriented Food Testing

"Finding the occasional straw of truth in a great ocean of confusion and bamboozle requires vigilance, dedication, and courage. But if we don't practice these tough habits of thought, we cannot hope to solve the truly serious problems that face us - and we risk becoming a nation of suckers, a world of suckers, up for grabs by the next charlatan who saunters along."

- Carl Sagan, The Demon-Haunted World: Science as a Candle in the Dark, 1995

The late Dr. Sagan was a physicist and cosmologist, not a food safety guy. Nevertheless, these words have broad applicability and are certainly relevant to food safety.

Elsewhere on this web site, a consumer may find much relating to the safe handling of food by food manufacturers and others in that business (or supporting businesses). Certainly, a consumer understands that the government (FDA and USDA) has agents monitoring the food coming into the market. The question, however, is how frequently is this done. The answer, most of the time, is not often enough. Food recalls occur with dismal regularity, yet many of our politicians tell us that our food is safe and argue that government testing of the food supply amounts to onerous over-regulation of the industry. To save money in these bad fiscal times, such folk even advocate defunding FDA and other regulatory agencies. Consumers might be forgiven for wondering who is looking out for them.

We keep being told that we are now part of a global economy, without being told exactly what that means. One thing it means is that our supply chains, for all sorts of goods, including food, stretch around the world. We already know that China has become a manufacturing powerhouse. It is also no slouch at food export and that brings up issues. On or about 7 April 2011 a Mrs. Chen purchased a kilogram of pork from a market located on Yang Gao North road in Shanghai, China. That night her family used some of the pork to make dumplings. The leftover meat was placed on a small table in the kitchen. At 11 p.m., Mrs. Chen went to use the toilet but noticed a blue light coming from the kitchen. That blue light was coming from the leftover pork itself - the meat was releasing a phosphorescent blue light! On 10 May 2011, Mr. Huang Shuo's article entitled "The recipe of China's food safety crisis" was published in the people's daily online. Excerpts from this article were reprinted 16 May 2011 in Food Safety News. In this article, Mr. Shuo reviews some of China's food safety issues including: melamine-tainted milk powder, salted duck eggs containing cancer-causing dyes, plaster tofu, etc. Fortunately, chemical laboratories around the world have since learned how to test for melamine in milk. That may be why some of China's milk dealers have learned that old, tanned leather ground into a fine powder works equally as well as melamine to give watery milk that high quality, "robust" look. Do they realize (or care) that much of such old leather was first tanned with (and most likely still contains) the heavy metal chromium VI, a known human carcinogen?

Mr. Andrew Schneider produced an investigative report on honey published in the Food Safety News of 1 Aug 2011. He explained that years ago, in 2001, China was found to be dumping honey onto the U.S. market (dumping means selling a product at a cost of less than the cost of production in an effort to artificially manipulate market share to the dumper's advantage). As a result, Chinese honey faced a stiff import tariff (as high as $1.20 per pound). The Chinese were said to respond by extensively filtering honey so as to remove all traces of the pollen grains that the bees had originally deposited in the honey they made. Why do this? Well, examination of pollen grains provides a reliable indication of the geographic source of the honey. So, if one is trying to sell Chinese honey to the United States and yet avoid the anti-dumping tariff, say by transshipping it through India or Vietnam, filtering out the pollen grains is a good way to cover one's tracks. In addition, such ultrafiltered honey is now easier to dilute with corn syrup or other sweeteners. Furthermore, Chinese honey may also contain lead and possibly other toxic heavy metals. The FDA is reported to have said that it is doing as best as it can. Between January and June of 2011, just 24 honey shipments were stopped from entering the United States. During that same period, 48 million pounds of honey were allowed in. Of that amount, 37.7 million pounds were said to have come from India. Beginning June of 2010, the European Union refused to allow the import of Indian honey because it often contained lead and also antibiotics such as chloramphenicol (said to causer DNA damage in children) and also because the paperwork associated with these shipments was defective and could not conclusively prove that the honey did not come from China. The consumer might well wonder whether, in this case at least, FDA's "best" is good enough. The alternative is to wonder why the United States has become a dumping ground for contaminated and/or fake honey that has been banned in the EU. Over the past couple of years, Justice Department lawyers and investigators from the Department of Homeland Security launched a series of indictments and arrests of 23 German, Chinese, Taiwanese and American corporate officials of nine international companies. They were charged with conspiracy to smuggle more than $70 million worth of Chinese honey into the U.S. by falsely declaring that the honey originated from countries other than China. Nevertheless, India is still shown to export much more honey to the United States than U.S. honey producers say India is able to produce from within its own country. On the other hand, certain U.S. distributors of such crystal-clear, ultrafiltered honey were said to argue that their consumers demanded this very clear honey because they took that clarity as an indication of a higher quality than the more natural honey, which was, of course, slightly cloudy with pollen.

Fruit juice is another illustration of the state of food safety in the U.S. About the middle of September 2011, The Dr. Oz TV show reported the presence of arsenic in various brands of apple and grape juice. At issue was the fact that the EPA's arsenic limit for drinking water is 10 parts per billion (ppb) and FDA has used that same standard for bottled water. Arsenic levels in juice were found to be significantly higher than that. For example, Mott's apple juice ranged between 4 ppb and 16 ppb. Juicy Juice apple juice ranged between 2 ppb and 22 ppb. Gerber's product ranged between 3 ppb and 36 ppb. No attempt was made to explain the rather extreme variation observed in these results. This television show was, at first, greeted with considerable derision. Dr. Richard Besser, the medical editor for ABC News, called Oz's claims "extremely irresponsible" and said it was like "yelling fire in a movie theater." The FDA's first response was to say that Dr. Oz's commissioned study was flawed because it measured only total arsenic and not organic arsenic. The FDA claimed that only the inorganic form of arsenic was toxic and that organic forms were harmless. Later, FDA performed its own testing which apparently showed arsenic levels substantially lower than those reported on the Dr. Oz show. Still later, Consumer's Reports published an expanded study which did analyzed for not only the arsenic levels overall but also parsed the heavy metal content into organic vs. inorganic arsenic. This study basically confirmed the original study published by Dr. Oz adding that most of the arsenic found was indeed the inorganic, toxic, carcinogenic form of arsenic. At this point the FDA did an about face and promised to reconsider setting formal regulatory limits for arsenic. While many lessons may be drawn from this unfortunate episode, among the most important is the fact that it is the public that must oversee the overseers. If any statement made during this circus was "irresponsible" it must have been the blanket assertion that organic arsenic is harmless and may be safely ignored. Methylated and dimethylated arsenic are indeed organic forms of arsenic. Neither is as toxic as inorganic arsenic but both are toxic in and of themselves. FDA has since admitted this point. This point, however, can hardly be viewed as news. After all, during World War I, tetramethyldiarsine (cacodyl - CAS 471-35-2) was considered for use as a poison gas on the battlefield. During the VietNam war, the di-methylated arsenicals cacodylic acid (CAS 75-60-5) and sodium cacodylate (CAS 124-65-2) were combined in a formulation used as a defoliant called Agent Blue. Sodium cacodylate is listed under EPCRA Section 302 as an "Extremely Hazardous Substance." Cacodylic acid is listed as a "CERCLA Hazardous Substance" having a Reportable Quantity (RQ) of only 1 lb.

Laboratory testing is expensive. It involves the use of expensive equipment whose acquisition and maintenance costs must be amortized and this equipment is often handled by specially-trained people who, quite rightfully, expect reasonable compensation for the years they spent in training. Cut the costs and you cut the quality. A laboratory test whose quality has been compromised is not worth doing (nor talking about). If the cost cannot be lowered below a level needed to assure quality, then (to be affordable) the cost needs to be spread out among several consumers. It is this latter tack that seems the most reasonable.

A consumer may want to know the arsenic and lead content of a particular type of apple juice (or honey or anything else) from a given manufacturer. To do so, she may download and fill out one of the shared cost form found below this paragraph and send it in along with a check for $5.00 to the address indicated on the form. This analytic request will be logged in upon receipt. Nothing can be done until sufficient funds to cover the requested work are received from other consumers who happen to want the same product tested for the same analytes. Once enough is collected to pay for the testing, purchase the product to be tested and pay the overhead expenses incurred by Food Safety Analysis, the product will be purchased and tested. Results will be emailed back to all those who participated in the exercise by sending in their five dollar "share" of the analytic and processing costs. This heavy metal testing will be performed using analytical methods that are standard for the industry and the latest, state of the art, equipment (Inductively Coupled Plasma - Mass Spectroscopy - ICP/MS). Controls and standard curves used by the analytical laboratory will be reviewed by Food Safety Analysis, LLC so that the results obtained are reviewed. Results of this quality will stand their ground in any venue.

Shared Cost Arsenic & Lead Order Form

A consumer who wishes to receive results without the delay necessarily incurred in waiting for others to share the costs for each analysis may elect to send in the sample to be tested and to pay the full analytic cost at once. Of course, there is nothing to prevent individuals from forming consortia among themselves and appointing one individual to send in a prepaid testing request with the understanding tht he/she will share any results received. In that case, information will be provided only to the individual whose name is on one of the forms listed below. Speed of analysis is not the only reason a consumer may choose to take this route. Fully prepaid costs will always be lower than the shared cost model because there is considerably less overhead involved when the testing is fully prepaid from the outset and the product to be tested has been sent in along with the analysis request.

Prepaid Prepaid Arsenic & Lead Order Form

Prepaid or cost sharing, results will be returned to the consumer(s) involved as soon as the final results are in and reviews completed. Consumers may do with their results what they will. If the results seem to be be suggesting a story a consumer is not happy with, that consumer is encouraged to contact the company involved, local health departments (or other appropriate jurisdictions) as well as any regulatory bodies that may be involved. Check the following link for ideas on reporting problems discovered in the course of testing:

Who Ya Gonna Call

In addition, Food Safety Analysis, LLC will undertake to keep track of the results over time. Once between 200 and 500 analyses have been completed for different lots of the same product, a report will be constructed showing the analytic variability observed in testing for that product. This report will be offered at a reduced rate to all the consumers who participated in ordering the testing being reported on over that time period. This report will be in the form of a e-book (in the Adobe ePUB electronic format). This same report will then be available for sale to the general public for a reasonable charge. Such information is generally difficult for the public to obtain. With sufficient participation by the general public, such information will be available. Please note that such heavy metal testing will all show results for total metal only. No attempt will be made to differentiate between, for example, total and organic arsenic. Such results are much more trouble and time-consuming to obtain and therefore much more expensive. This expense would appear to render such analyses inappropriate as a consumer service.

This purpose of this plan is not to harass companies delivering safe food for public consumption. indeed, results may vindicate the product being tested as safe. Rather, it is a way to ensure that the consumer's voice is heard in the food safety debate. Furthermore, there is nothing to prevent any manufacturer confident in their product offerings to participate in this study by subsidizing all or part of such consumer-driven testing on behalf of their customers as a good-will gesture and then using the results to advertise that company's products.


Total mercury analysis is available, although, for methodological reasons, this analysis must be treated as separate from the other heavy metal analyses mentioned above.

All forms of mercury are toxic. Mercury is a rather unusual metal. The nature of the toxicities involved are unusual as well. A standard measure of how toxic something is may be provided by the so-called Lethal Dose (50%) or LD50. Simply stated, the more toxic something is, the less of it will be needed to kill off one half of a suitable test population of organisms. The toxicity of a toxicant will vary according to how it is delivered into the test organisms. Since we are concerned here about the toxicity of mercury in our food, our primary measure of toxicity should be oral, where the toxicant is delivered by mouth to the test subjects. Acute toxicity measures death of the test subjects within an hour or two of toxicant administration. Toxicity varies according to the species of test organism used. The sex and age of the test subjects may also alter the toxicity observed. The usual units of measurement are milligrams per kilogram or mg/kg. A kilogram (by definition) contains one thousand grams. Each gram (again by definition) contains a thousand milligrams. So, a kilogram must therefore contain a million milligrams (1,000 x 1,000 = 1,000,000). A rat is often used as a test subject for such studies. A rat weighs about a kilogram. So, if one milligram of a toxicant is fed to 30 rats and 15 of those rats are dead in a couple of hours, a toxicologist would say that the acute oral rat LD50 of this toxicant is one part per million or 1 ppm (or 1 mg/Kg of bodyweight).

Dimethyl mercury is one of the forms of organic mercury. It has an acute oral rat LD50 of 50 micrograms per kilogram (LD50 = 50 mcg/kg). A microgram is a millionth of a gram. It is also one thousandth of a milligram. Either way, a kilogram contains a billion micrograms (1,000,000 x 1,000 = 1,000,000,000 or 1,000 x 1,000 x 1,000 = 1,000,000,000). An LD50 of 50 mcg/kg may also be expressed as 50 parts per billion or 50 ppb.

There is a conceptual problem here that often stands in the way of real understanding. Most consumers don't have a good, seat-of-the-pants notion of just how small a microgram really is. Think of it this way: The oils and salts of a normal human fingerprint usually weigh about a microgram. So, stamp you thumb on your desktop and you will have added roughly one microgram (0.000001 grams) to the weight of your desktop.

A toxicant is called extremely toxic if it shows an LD50 lower than 5 ppm. Dimethylmercury has an acute oral LD50 one hundred times lower than the level which defines extreme toxicity. Fortunately for us humans, we don't often see dimethylmercury in our food. Unfortunately, we do encounter plenty of its close cousin, methylmercury.

A toxicant is considered highly toxic if its LD50 ranges between 5 and 50 mg/kg. Since methylmercury is found in the environment, its acute oral LD50 values have been determined using a variety of test organisms. These data are derived for methylmercury where chloride was the anion so that in all of the following examples the CAS number of the toxicant was: 115-09-3. Moving sequentially from least to most resistant the LD50 results were: hamster - 15 mg/kg; guinea pig - 21 mg/kg; quail - 26 mg/kg; rat - 30 mg/kg and mouse - 58 mg/kg. However, the National Institutes of Health (NIH) report that the susceptibility of mice to this toxicant is highly strain and sex specific. For example, a single dose (at 16 mg/kg) of this toxicant to male mice of the C57BL/6N Jcl strain resulted in the death of four out of six male mice. However, no increase in the mortality of female mice was observed until the dose was increased to 40 mg/kg at which dose four out of six female mice died. The basis of this sexual difference in toxicant sensitivity is not known.

Methylmercury has a number of effects. It disrupts mitochondrial electron transport. This will effect oxidative phosphorylation, the production of adenosine triphosphate (ATP) a key energy intermediate of cells. However, its major effect is on the brain. The disruption of electron transport increases the amount of reactive oxygen produced. These free radicals deplete glutathione and cause neuronal injury. Finding human volunteers for a methylmercury toxicity study is likely to be difficult and certain to be unethical. This means that standards for methylmercury exposure in humans are going to be based more upon the epidemiology of brain function more than toxicological data. Nevertheless, experiments of nature have given us insight into the effects of methylmercury on humans.

Methylmercury is a potent fungicide, often used to coat seeds and protect them from mold attack. Such seeds were never meant for human consumption, although mistakes do happen. One such mistake occurred in Iraq in 1971/72 when treated wheat was ground into flour which was then distributed to certain rural communities who used it to bake bread, which was promptly consumed. This tragic episode resulted in the 6,350 cases of severe brain damage and 409 fatalities but it also provided a valuable, real world example of human methylmercury intoxication.

The fact that we know a great deal about methyl mercury's effect on humans is what makes FDA's comments on this subject seem so mysterious. FDA has put together a large collection of information on various kinds of hazards found in fish (Fish and Fishery Products Hazards and Controls Guidance, 4th Edition - April 2011), yet, out of these 476 pages, FDA has devoted only a one page chapter on the subject of methylmercury (Chapter 10 - Methylmercury). This chapter says almost nothing about this toxicant.

Previously, the LD50 values of methylmercury were reported for a variety of test organisms. If we ignore the mouse data because the difference in the susceptibility between the sexes seems both unique and confusing, we find that the rest of the test organisms gave a reasonably tight distribution of LD50 values which averaged about 23 mg/kg. Since we know that the brain is the target organ for methylmercury toxicity, it seems reasonable to conclude that a larger-brained organism would be more susceptible than a smaller-brained animal. The ratio of human brain size to body weight is considerably greater than the ratio found in the rat, guinea pig, hamster and quail (i.e., the human LD50 is expected to be lower than 23 mg/kg). Let us continue to use the average value for the sake of argument even though we know it may be an overestimate.

A large can of tuna fish has a net weight of 340 grams. If it contained no more than 1ppm of methylmercury, it would contain a total of 0.34 milligrams (340 micrograms) of methyl mercury in the can. It is easy to use this ingredient to produce a tuna macaroni casserole sufficient to serve as the main course for a family of four, two adults and two children. Let us also make the assumption that in this family, the father's weight was 175 lbs, the mother's was 125 lbs, one child weighed 75 lbs. and the other weighed 50 lbs.

Mercury Ingestion from Canned Tuna Fish
Body Wt. (lbs.) Body Wt. (Kg.) Portion Size (oz.) Proportional to Body Weight Portion Size (grams) Proportional to Body Weight Micrograms of Methylmercury per Kilogram (2 oz. serving) Multiple of EPA and NAS MeHg Reference Dose (0.1 mcg/kg/day)

The above table provides two types of information. The first of these is the assumption that the portion an individual will eat is dependent upon that individual's body weight. If that were the case, then Dad would eat a quantity of tuna fish just slightly larger than a quarter pound hamburger patty, not an unreasonable amount of food. The calculation is straightforward. The combined weight of this family of four adds up to 425 pounds or 193.1 kilograms. Together they ingest 340 grams of tuna fish and so get a dose of methylmercury from that tuna fish meal equivalent to 1.76 micrograms per kilogram of body weight (340/193.1).

The question now is to determine what is a safe dose of methylmercury. The Joint Food and Agricultural Organization/World Health Organization Expert Committee on Food Additives (JECFA) have determined a provisional tolerable weekly intake of 0.5 micrograms/kilogram of methylmercury for adults. Since a week contains seven days, one could say that this level amounts to 0.07 micrograms/kilogram/day. Both FDA and Health Canada agree that this level is reasonable for adults although Health Canada has lowered the provisional tolerable weekly intake to 0.2 micrograms/kilogram of body weight for the most susceptible population, very young children.

Despite saying that methylmercury has no discernable threshhold level in its toxic effects, the EPA has nevertheless proclaimed that a daily reference dose of 0.1 micrograms/kilogram of body weight/day should be reasonably safe (i.e., 0.07 rounded off to the nearest tenth). This is also the same "safe" level cited by the National Academy of Sciences and by FDA. The FDA has further stated that, on average, Americans consume some three fish meals per week. Yet, after our hypothetical family of four has ingested one large can of albacore tuna, the daily reference dose suggests that this family should not have another methylmercury-laden meal like this for 17.6 days. The example above assumes that methylmercury is present in the canned albacore tuna fish at its regulatory limit of 1 ppm (i.e., microgram/gram). Perhaps this assumption is not borne out in reality. Perhaps the methylmercury contamination is really quite a bit less and so the worrisome questions being asked do not apply. Unfortunately, they do apply. FDA has already published the average methylmercury content of a number of fish products. Albacore tuna fish is said to have an average methylmercury content of 0.853 ppm (i.e., 0.853 micrograms/gram). When the average methylmercury content of this product is known to be 85% of the regulatory limit, it means that there is very little, if any, safety margin. A consumer might therefore be forgiven for wondering if the regulatory limit is set at 1 ppm not so much to ensure the safety of the consumer as to allow for the distribution and sale of a contaminated product. Furthermore, in the case of a product such as albacore tuna fish, where the average contaminant load is known to be 85% of the regulatory limit, it seems reasonable to ask how that average is distributed. Are some brands less contaminated than others? Also, what fraction of the cans tested were actually above the regulatory limit?

Of course, the serving size is designated by the food manufacturer and is given on the label. Of course, the use of an unrealistically small serving size may be of advantage to a manufacturer whose labeling information depends upon serving size. For example, the caloric content, fat content, sodium content, can be made to appear less than it really is. By the same token, any contaminant levels represented on a serving size basis rather than by weight will appear to be smaller as well. For example, some tuna fish labels carry the rather unrealistic serving size of 2 oz. on their labels. You can see that if each family member eats a 2 oz. portion, the adults will fall within a reasonable safety zone but the children will get a much larger proportion of mercury per kilogram (Hg/Kg).

Of course, the consumer is free to ignore unrealistically small designations of serving size as provided by the manufacturer. The example above assumes that a 175 lb. man will consume slightly more than a quarter lb. of tuna fish and that a 125 lb. woman will consume slightly less than a quarter lb. In a special page devoted to issues of methylmercury ingestion by pregnant woman, FDA reported that the average serving size of albacore tuna by women was actually six ounces, or 3/8 of a pound. This seems a more realistic serving size.

So, let's recalculate using a six ounce serving size for the 125 lb. woman in our example and FDA's average methylmercury load of 0.853 micrograms per gram for albacore tune fish. A six ounce serving is equivalent to 170.1 grams, so the "realistic" methylmercury dose per meal for this "average" woman is (0.853 x 170.1) 145.1 micrograms or (145.1/56.8) 2.55 micrograms per kilogram of body weight. According to published safety guidelines discussed previously (0.1 micrograms/kilograms of bodyweight/day), this lady should not eat tunafish again for about 26 days, almost a month. Yet, FDA tells us that, on average, Americans eat fish for three meals a week and that, in the case of heavily contaminated seafood like albacore tuna, prudence would be satisfied if fish meals are cut back to one meal per week. Americans deserve better from their food safety agencies than this kind of contradictory confusion. That is the whole point behind empowering consumers to monitor the safety of their own food.

A scientifically defensible analysis will be returned to every customer (or group of customers who chose to participate in a shared-cost option). What any consumer chooses to do with these analytic results is entirely up to that customer. Food Safety Analysis is not a lobbyist organization and has no agenda. Theoretically, a free market should determine the success of food manufacturing enterprises. However, safety concerns often don't show up on mere inspection. They become apparent only after careful analysis. Until now, the consumer has never had access to such analysis and has had to rely upon government regulatory agencies. Lately, certain politicians have called for defunding these same regulatory agencies, apparently with the knowledge that this will hamstring their regulatory efforts and so compromise their effectiveness. It is well to remember that neither USDA and FDA were originally created merely to provide employment to experts. They were created in response to public outrage. It remains the job of the public to watch the watchers and to inspect the inspectors, even as the technology involved increases in sophistication. It is certainly true that the heavy metals analyses are only a small part of all that needs to be done. On the other hand, this is a solid and high quality part. If this effort is successful, other analytic entities may be inclined to offer other kinds of testing to the public and so "fill-in-the-blanks" as it were.

It is also important to keep in mind that many food manufacturers actively strive to offer the public the safest product possible. Only the consumers can identify these companies and reward them with their business. Heavy metal analytic information (such as offered here) received from anyone other than the consumer (i.e., yourself) might well be viewed as a conflict of interest.

Mercury Analysis Consumer Shared Cost Order Form

Mercury Analysis Consumer Prepaid Order Form

Click on one or more of the links on the lines above to open the Adobe Portable Document File (PDF) of the Consumer Order form you need. Print out this form. Filll it out completely and send it to: Food Safety Analysis, LLC; 108 North Maple Road # 162; Saline, MI 48176.

ADOBE Acrobat software will be required to open the PDF files. If you don't already have this software on your computer, you may download it for free from the link below:

Adobe Acrobat Download

Copyright © 2012 by M. Mychajlonka, Ph. D.