Category: Animal Rights & Environment

By Shems Jud

Trawl gear modifications produce reductions in bycatch, fuel use and seafloor contact – all with increased catching efficiency.

Over the past couple of years EDF’s Pacific team has been privileged to work with fishermen, scientists, fishing net manufacturers and many others on a three-stage project to demonstrate the feasibility of improved trawl net designs on the West Coast. The video shown here describes the amazing progress we’ve made together and indicates a path-forward for disseminating our results to fishermen everywhere.

Our video tells the story of:

• Trawl gear innovations developed by fisherman Giuseppe Pennisi, of Monterey, California
• The work of Dr. James Lindholm, of Cal State University, Monterey, along with his team of remote operated vehicle (ROV) consultants and a hardy band of grad students.
• The Trawl Gear Modifications Workshop we convened last summer, which brought together researchers, fishermen, regulators and gear manufacturers from the West Coast and Alaska to view underwater fishing footage and share their expertise.

That workshop was so well received that a second one is already being planned.

Please feel free to share this video with your family, friends or colleagues. There are lots of good stories in U.S. commercial fisheries these days, and the more people who learn about them the better!

P.S. Many people contributed to this project, but our special thanks go out to NOAA Fisheries and the Saltonstall-Kennedy Grant Program.

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By Jack Pratt

Jack Pratt is Chemicals Campaign Director

Today, EDF joined a group of advocates in filing a petition that could force a ban on lead in hair dyes. Over the last several decades, we have gone to great lengths to reduce lead exposure—from eliminating the use of lead in gasoline, to tackling legacy uses in paint and water pipes. Yet, somewhat incredibly, lead is still permitted in hair dyes in the United States. Unfortunately, the evidence indicates that use can have an impact not only on the men who use it (it is seemingly exclusive to men’s dyes) but can have an impact on kids in the house too. That’s why FDA should take action and reverse their decades-old approval of lead in hair dyes.

No one contests that lead is a potent neurotoxin, with an especially devilish impact on

kids. Children with elevated blood lead levels can see life-long impacts, including lost IQ points, ADHD and other significant cognitive and health impacts. While there are still critical areas that require attention—such as the lead pipes providing drinking water to millions of Americans and the hazard of old lead paint—decades of work on lead policies has made a real impact, resulting in significant declines in children’s exposure. Some of these policy initiatives were quite dramatic, like removing lead from gasoline, but the societal impact has been well worth the trouble.

For all that work, it is surprising—astonishing really—that an intentional, purely cosmetic use of lead remains permitted. Today you can walk into almost any drug store or supermarket in the United States and purchase a so-called “progressive” men’s hair dye that could contain as much as one gram of lead. While use of lead acetate in hair dyes is prohibited in Canada and the European Union, the U.S. FDA approved of such use in 1980. That approval included only minimal restrictions—a vague warning label and that the dye only be used on the scalp, not on facial hair. The levels of lead in the product are allowed to be as high as 6000 ppm. To put that in perspective, three years before FDA’s decision, the Consumer Product Safety Commission banned the sale of household paint containing more than 600 ppm of lead.

The petition filed by EDF and our colleagues cites cases where users of such hair dyes have noticed real health impacts, including one user who didn’t realize it should not be used on facial hair and lost feeling in his hands and feet. He did not return to normal for a year.

Perhaps more notably, however, the petition cites major advances in science since the 1980 FDA decision that show the risks go beyond the users themselves and put other members of their family at risk. One such study showed lead contamination from the hair dyes—especially on surfaces touched after using the hair dye like blow-dryers, combs and faucets—and found these surfaces had up to 2,804 micrograms of lead per square foot. In 2001, the U.S. Environmental Protection Agency (EPA) said that more than 40 micrograms of lead per square foot on the floor posed a hazard to children.

I certainly understand the desire for a youthful appearance—I’ve got more than a few grey hairs myself. But as the parent of two small children, there is simply no contest for where my priorities lie, especially since there are many hair dyes that do not contain lead. I’m sure that many, if not most, users of these products have no idea they could be putting their health and that of their families at risk. FDA now has 6 months to review the petition and make a final decision. This should be a no-brainer—FDA should take action to protect Americans from this unnecessary source of lead exposure.

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By Tom Neltner

By: Tom Neltner, J.D., Chemicals Policy Director and Maricel Maffini, Ph.D., Consultant, Environmental Defense Fund

Since September 17, 2016, most facilities storing, processing, or manufacturing food are required to identify and, if necessary, control potential hazards in food under a Preventive Controls Rule promulgated by the Food and Drug Administration (FDA) pursuant to the FDA Food Safety Modernization Act of 2011 (FSMA). Some foods have had similar requirements in place for years. For example, fruit and vegetable juice processors have been required to have a Hazard Analysis and Critical Control Point (HACCP) Plan since the early 2000s.

The driving force behind the law and the rules has been reducing the hazard of pathogenic contamination in food. However, the Preventive Controls Rule defines a hazard broadly to include any chemical, whether a contaminant or an additive, that “has the potential to cause illness or injury.”

In this blog, we will explore how the requirements of the Preventive Controls Rule apply to chemical hazards using lead as an example. We chose lead because it is known to cause injury and clearly meets the definition of a hazard. It is well-established that there is no safe level of lead in the blood of children leading to lower IQ and academic achievement, and increases in attention related behaviors. We also know it is all too common in food that toddlers eat. And scientific evidence indicates that much of the lead in food gets into children’s blood.

Four potential sources of lead in the food supply chain

Lead can get into food in different ways including:

• Absorption from contaminated soil into the roots, leaves, and, possibly, fruit. Soil may be contaminated from past use of lead arsenate pesticides or air deposition from burning leaded gasoline.
• Contact with contaminated soil during production or harvesting. For example, soil may get into a head of lettuce or on an apple that falls to the ground.
• Leaching from food handling equipment such as that made from brass or plastic that had lead intentionally added. Until 2014, brass used in drinking water applications could contain up to 8% lead and still be called lead-free. If such brass were used in pumps and valves in food production, leaching of lead into food may occur. Similarly, lead has also been used in PVC plastic as a stabilizer, although it has been phased out in U.S. and Europe. It is important to note that lead is not approved by FDA to be intentionally added to anything that contacts food. If any leaches into food from these sources, the lead would be considered an unapproved food additive. That would render the food adulterated and, therefore, illegal to sell. Note that a supplier’s claim that a material is “food grade” is no guarantee that its use is legal.
• Contamination of food or food contact materials during processing such as lead from deteriorated paint in the building.

Elements of a Food Safety Plan

Under the Preventive Controls Rule, most facilities storing, processing or manufacturing food must have a written Food Safety Plan that consists of seven items:

1. A hazard analysis to identify and evaluate known or reasonably foreseeable hazards;
2. Preventive controls to ensure hazards are significantly minimized or prevented and food will not be adulterated;
3. Risk-based supply chain program to protect raw materials and ingredients from hazards;
4. Plan for recalls should they be necessary;
5. Procedures to monitor preventive controls to assure they are consistently performed;
6. Corrective action procedures if preventive controls are not properly implemented; and
7. Verification procedures to validate that preventive controls are adequate and effective, other procedures are being followed, and plan is reevaluated at least once every three years.

The path forward

The FSMA food safety planning requirements put in place a systematic approach for food manufacturers to prevent food safety problems rather than react when they arise. This includes problems that can result from chemical hazards as well as pathogens. The goal is to ensure that consumers are not exposed to adulterated food, whether because it contains “any poisonous or deleterious substance which may render it injurious to health” or it contains an unapproved food or color additive.

A robust food safety plan for lead and other chemicals such as perchlorate would go a long way to protect children and pregnant women from unnecessary exposures to chemicals known to impair brain development, and the businesses from unnecessary risk.

What a Food Safety Plan would say for lead

To comply with the regulations and mitigate risk, the food manufacturer/processor’s written food safety plan is required to identify lead as a hazard if it is reasonably foreseeable that lead could get into food either as a contaminant or from its intentional addition to materials such as brass or plastic used in food handling equipment.

If the plan identifies lead as a hazard, the company must evaluate the risk by assessing (1) the severity of the illness or injury if the hazard were to occur, and (2) the probability that the hazard will occur in the absence of preventive controls. The plan must also develop and implement preventive controls to assure lead levels are significantly minimized or prevented and the food is not adulterated. The controls would likely include:

Next, the company must identify how the preventive controls would be monitored to spot implementation problems, explain how a recall would be conducted if lead were found to exceed the maximum amount identified in the plan or is present as an unapproved food additive, and describe what corrective action would be taken to prevent future recalls.

Finally, the food manufacturer/processor must reanalyze its Food Safety Plan at least every three years or when:

1. There is a significant change in the activities conducted at the facility that creates a reasonable potential for a new hazard or creates a significant increase in a previously identified hazard;
2. The food manufacturer becomes aware of new information about potential hazards associated with the food;
3. An unanticipated food safety problem occurs; or
4. The food manufacturer finds the preventive control, combination of preventive controls, or the food safety plan as a whole is ineffective.

The Food Safety Plans are not made publicly available, but they must be made available to FDA on request or during an inspection. Potential downstream buyers and retailers most likely can obtain a copy through their own supply chain management programs.

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