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How to feed people dioxin and get away with it

Earlier this month German authorities closed around 4,700 farms following the discovery that pigs and poultry had been given feed contaminated with dioxins, which are thought to be among the most carcinogenic environmental pollutants. Yesterday Russia banned the import of untested pork products produced in Germany after 1 November 2010. This follows earlier import bans on some German food products in Slovakia, China, Belarus and South Korea.

Evidently the North German firm Harles und Jentzsch added a contaminated oil, possibly intended for industrial paper production, to an ingredient for animal feed that was then sold to 25 different feed manufacturers. Tests showed that the oil contained dioxin at 77 times the permitted level. Around 150,000 tons of feed incorporating this oil was reportedly fed to poultry and pigs across Germany, and affected eggs were sold in Germany, The Netherlands and the UK.

Internal tests at the Harles und Jentzsch plant revealed elevated dioxin levels in feed ingredients as early as March last year, suggesting the possibility that the human food supply may have been contaminated for months. And of course, this is nothing new. There were similar dioxin scandals in Ireland and Italy in 2008, Belgium in 1999 and 2006, and Germany in 2003.

How can such practices go unnoticed so often and for so long?

Two features of food safety regulation may be particularly relevant.

(1) The most rigorous controls occur at the end of the food production chain, on the final products to be sold for human consumption

(2) These controls are based on sharp thresholds, maximum toxin levels deemed safe for human consumption.

On the face of it, both of these features seem quite sensible. Since the entire rational for food safety regulation is to keep down human exposures, it makes sense to focus regulation on products intended for humans. And doing so has the added advantage that food produced for sale to humans can be relatively easily accessed and sampled by authorities, whereas animal feed may be quite easy to hide. The use of safe thresholds also looks reasonable; it gives the food industry clear and easy-to-follow guidelines.

However, taken together (1) and (2) have the implication that gross misconduct in food production may be fairly easy to get away with if it occurs far enough back in the food production chain.

Suppose you have a tonne of dioxin-laced oil that you would like to sell. If you sell this directly for human consumption, you’ll almost certainly be caught quickly. On the other hand, if you sell it for use as one component in an animal feed ingredient, which will then be used by dozens of feed manufacturers to produce food for thousands of farmers, who will use the feed as merely one component in their feed regime, there’s a good chance you’ll get away with it. Dilution of the toxin by spreading it across a huge range of foods may prevent the safe thresholds on any individual final products from being exceeded.

The overall effect on human health may, however, be similar. There is no safe level of dioxin consumption for humans; the greater the exposure, the greater the risks of adverse effects. If we assume that the relationship between dose of dioxin and risk of harm is roughly linear, then the effect of introducing dioxins earlier rather than later into the food production chain may simply be to spread virtually the same total amount of total risk across more people. The reduction in risk faced by any individual person may be offset by the increase in the number of people affected. (I assume here that all of the dioxin ends up in human food eventually. In fact, some will be excreted by farm animals, or stored in parts of those animals that are not eaten.)

The moral importance of the effects may also be similar. True, a small risk borne by many may be less bad (say, because less unfair) than a large risk borne by a few. But arguably, the moral difference is not huge. If this is right then there is a clear need for new strategies to prevent misconduct early in the food production chain. We should ensure that it is no easier, or not much easier, to get away with food contamination earlier in the chain than it is later.

One strategy would be to introduce stricter and more rigorously enforced controls on animal feed and ingredients used to produce it. This has been the main response of German and European Union authorities in the wake of the recent scandal. It’s surely a good idea, but it’s unclear whether it will be sufficient. The food production process now has so many stages and elements that regulators will have a hard time keeping on top of all of them.

Another strategy would be to replace or supplement safe consumption thresholds on human food with some form of dioxin tax that penalises human food manufacturers, wholesalers or retailers in proportion to the dioxin content of their food, even if levels are below current thresholds. Random and representative food samples could be collected over the course of a year, say, with the ‘dioxin tax’ for the following year determined by the average dioxin content identified during the previous year. This would give human food producers and sellers an additional incentive to join with authorities in putting pressure on those operating earlier in the chain. It would also give them an incentive to simplify the entire food production process to make oversight easier.

Thresholds would probably need to be retained, otherwise food manufacturers or sellers could allow high dioxin levels in some products, while offsetting this by tighter control on other products. This would be undesirable since those who consume those products in large quantities might end up facing a particularly high risk. However, a tax on dioxins, and other toxins with no safe exposure level, might be a useful supplement to these thresholds.

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1 Comment on this post

  1. I agree entirely. This approach should be extended to all toxins that are found at subthreshold amounts. I'm sure people try it on and introduce these toxins knowingly, but in a way that will result in trivial penalty.

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