FDA sets these action levels because it is economically impractical to grow, harvest, or process raw products that are totally free of non-hazardous, naturally occurring, unavoidable defects.
Over 1,000 different types of bugs are eaten by cultures throughout the world. In parts of Mexico, Africa and Asia, insects such as water bugs, locusts, termites, ants and grubs are common foods. But as Sylvia Branzei observes, “The gross fact is, we eat many bugs and bug parts without knowing it. Most foods have insect contaminants. (1)
Health inspectors know this and they even allow a set number of bugs, bug parts, and rodent contaminants in foods. These amounts are called DALs, or Defect Food Action Levels.
Experts at the Food and Drug Administration (FDA) decide on how much contamination is to be allowed in foods sold for human consumption. There is no question regarding 'how much' since it would be impossible to produce food that had no contaminants whatsoever. The FDA's Food Defect Action Handbook establishes the amounts of contaminants permitted in about one hundred plant-derived foods. At or below these levels, the FDA has determined that the defects—however icky,--are harmless. (2)
Under the regulations in the FDA handbook, a hefty bowl of spaghetti is permitted 200 or so bug fragments—one for every gram of pasta—fifteen fly eggs, and a #. Add a pinch of FDA-acceptable ground oregano and it might be # with one hundred bug bits and a rodent hair. A few spoonfuls of sauerkraut could include fifty thrips- a small slender bug pointed at both ends. (3)
Here are some other examples of FDA guidelines for maximum levels of 'certain impurities' in some foods.
Food--Maximum Defect Action Level
Brussel sprouts--10 aphids per ounce
Shelled peanuts--1 insect per 5 pounds
Peanut butter--9 insect fragments per ounce
Chocolate--3 or more rodent hairs per 100 grams (a typical chocolate bar is about 40 grams)
Broccoli (frozen)--Average of 60 or more aphids and/or mites per 100 grams
Cocoa beans--10 mg or more mammalian excreta per pound
Sesame seeds --5 mg or more mammalian excreta per pound
Hops--Average of more than 2,500 aphids per 100 grams
Raisins, natural & golden--Average of 40 mg or more of sand and grit per 100 grams of natural or golden bleached raisins
Wheat--Average of 9 mg or more rodent excreta pellets and/or pellet fragments per kilogram
With chemicals we talk about a few parts per million, parts per billion, or even parts per trillion. With animal excreta, note that 10 mg per pound is equivalent to 20 parts per million. These are serious parts per million!
The FDA sets these action levels because it is economically impractical to grow, harvest, or process raw products that are totally free of non-hazardous, naturally occurring, unavoidable defects.
However, not to worry. As Eric Berger notes, “It is incorrect to assume that because the FDA has an established defect action levels of a food commodity, the food manufacturer need only stay just below that level. The defect levels do not represent an average of the defects that occur in any of the products—the averages are actually much lower.” (4)
References
Jack Dini is author of Challenging Environmental Mythology. He has also written for American Council on Science and Health, Environment & Climate News, and Hawaii Reporter.
