UNITED STATES DEPARTMENT OF
AGRICULTURE
FOOD ADVISORY COMMITTEE
CONTAMINANTS AND NATURAL TOXICANTS SUBCOMMITTEE
Thursday, December 5, 2002
8:34 a.m.
The Inn and Conference Center
Founders Ballroom
University of Maryland University
College
3501 University Boulevard East
Adelphi, Maryland 20783
P R
O C E E D I N G S
DR.
BUSTA: Good morning, everyone. Happy holidays.
DR.
FULLER: We may be here awhile.
DR.
BUSTA: It's beginning to look like a
holiday. This was very fortuitous, that
we had the meeting in the same place that we were staying. We appreciate Dr. Downer getting here from
her home. She got a little excitement
this morning, so her blood is rushing.
Some of the rest of us are just waking up.
This
morning, you see on our agenda, the first presentation will be by Dr. Terry
Troxell, who is going to summarize the Plan and Charge, tell us what we're
supposed to do from here on.
DR.
TROXELL: Thank you. Well, the northerners on the committee, we
have come through for you with snow.
The university is closed, so maybe we should just shut down and go build
a snowman and have snow fights. They
closed everything last night even before the snow happened, but that's
Washington for you.
Okay, get
down to serious business: the Action Plan.
So I have 15 minutes to summarize everything everybody did
yesterday. But just briefly, let's just
reup a few things.
We talked
about the analytical method yesterday, that we need to further validate the
definitive methods.
We have
the need for proficiency samples so that we can assure that everyone around the
world is--in this country and so on are getting the same kinds of results.
It would
really be desirable to have alternative methods. We're looking at LCUV as a quicker, cheaper method that can be
done with instrumentation that is, we believe, very prevalent. This would be prevalent not only in
companies so they can do QC or, you know, can follow the research on new
products and so on, but also for developing countries where they don't have
LC/MS/MS equipment and so on.
It would
have been desirable, of course, to have something simpler, like an amino
assay. But as we looked at the size of
the molecule, people that advise me--leave that, it really wouldn't--we
wouldn't likely get very definitive antibodies. But if that's something the committee thinks we should explore, I
suppose that would be another approach to getting something cheaper for doing
some screening.
Then the
next component really gets down to incidence and levels, all the way through
the exposure assessment. We've done an
exploratory survey; we need to--obviously, as we talked--expand that more
comprehensively to assure that we get similar results around the country. We need to get enough information to make it
so that we can have a degree of robustness in exposure assessment.
We are
starting to analyze this as part of our Total Diet Survey, which is a survey of
foods as consumed. Therefore, the foods
are baked and so on, so there's a certain degree of consumer preparation in
that study. The consumers that are
preparing that, which happens to be a church group, prepare the foods according
to recipe. So there is a certain amount
of the consumer-preparation angle in there.
But the
other--you know, in addition to serving to help provide data for the exposure
assessment, this is going to be kind of weather-vane, as it is for the other
chemicals we analyze--it's a weather vane on trends, so we'll be able to
measure progress in reduction of acrylamide by using--this is one of our
tools. No one tool general is the
end-all, so we look at--one always looks for a series of measures.
Then the
next component, of course, is the formation.
We have very good information at this time on a major mechanism. Obviously, some more work needs to be done
to check out other potential mechanisms in various foods.
And when
one thinks about reduction, there's probably three general strategies. One, of course, is to remove the
reactants. So remove those precursors,
asparagine and reducing sugars. So are
there ways to minimize the presence of those.
And then the second would be to stop the reaction from going, or slow
the reaction--so the ways to prevent the reaction from occurring, whether one
puts inhibitors in there or temperature changes or whatever. And then finally, of course, is once it
forms, is there some way that it can be destroyed after it is formed. So that kind of maybe divides that territory.
Then the
next thing, of course, was the toxicology.
Obviously, we need to understand the toxicokinetics, particularly the
comparative metabolism between animals and man. Biomarkers are going to be very useful. Some people look at biomarkers on the exposure side, but
biomarkers are, of course, critical on the tox side, too, so we can relate the
dose to the hemoglobin adducts, to the DNA adducts in the tissues, and then do
comparisons between those adducts in animals and man and so on, so we can do a
good risk assessment.
And then,
of course, there's the three major end points under consideration. There's the cancer end point, there's the
neurotox end point, and the germ cell mutagen end point. The two latter, the neurotoxin and the germ
cell, of course, are at much higher levels in exposures. Of course, the animal carcinogen end point
is also occurring at a much higher level than food exposures, but there
is--part of the neurotox is to try to define if there's additional--well, to
define that point more precisely and to look at effects, whether there might be
some neuro-developmental end points or whether there's an effect from long-term
exposure compared to the exposures under which the current studies were
done. And these things, then, will be
fed into risk assessments, which will then feed into risk management and looking
at different risk management options.
The next
component of our Action Plan is to foster those partnerships. You know, this is a large amount of work to
do when you look at the different components.
But then, on the other hand, there is also an intense interest out
there, and one of our considerations is how to harness that interest so that
there's a concerted, coordinated program, and we're fostering that through the
JIFSAN work and through JIFSAN's running the Infonet. And in addition, we're independently working inter-agency to
coordinate our efforts, and we'll do everything we can to support or facilitate
coordination not only to help the JIFSAN effort but also independently in the
international and so on.
One
illustration of the need for that coordination is that the mechanism was
announced independently by about five different--at least five labs, I mean,
five we know of. I think there were
other people out there who discovered the mechanism at the same time. And while it would have been nice for, say,
two laboratories to do that, the other three labs could have been making
progress on something else.
There are
many difficulties in the coordination in this, including the basic nature of
scientists. Their lives and their
creativity depend on kind of holding things tight, not being scooped, writing
papers that they can publish and not announcing them ahead of time because they
won't allow them to publish. But all
that, of course, will minimize the progress and increase the level of duplication. So we'll do everything we can to encourage
people to provide the information at the earliest point. Certainly FDA scientists, as government
officials, will be releasing information as soon as it's ready.
Then the
last component was to inform and educate consumers and processors about the
potential risk, provide options on how to reduce the risk as long as there's
gain. We have provided an initial
consumer message. We've also publicized
our scientific agenda and what we understand about the risk in order to assure
the public that we are taking the necessary steps and appropriate action to
protect them.
So
that's, in a nutshell, the Action Plan.
Then turn to the Charge again.
We're asking the committee to evaluate whether the research steps
outlined in the Action Plan are scientifically adequate to describe and address
the public health significance of acrylamide in foods. And based on what you heard, we would like
you to provide questions, we would like to have your views and expert advice on
whether the research steps are appropriate to describe and address that public
health significance. And then, are
there gaps in areas that there should be increased emphasis. And then, finally, the question of the
priority of research needs--what is more important to get done early. And also, I would suggest you think about
what can practically be done early. I
mean, obviously, you can't get a bioassay done in six months.
Anyway,
so some of the presenters are here, not all of them, but I think we'll be able
to answer any questions you may have during the session. And I turn it back to you, Chair. Thank you.
DR.
BUSTA: Don't run away. I've got a couple of questions. Number one, is there--you mentioned risk
assessment, risk management, and then the third step is all this risk
communications. I see the educational
component as risk communications, right?
DR.
TROXELL: And risk management. Risk communication has many components--it
communicates to consumers, industry; it also communicates back to the researchers
and risk assessors. So I mean
it's--basically, risk communication covers everybody's involvement throughout
the process.
DR.
BUSTA: And I see a lot of risk
assessment. I'm trying to understand
the risk management component of this.
DR.
TROXELL: We have not laid out potential
risk management options at this time, but one of them--I mean, actually, our
first risk management we have done is to put out a consumer message. We'd like people to eat that balanced diet
according to the pyramid and so on, and we think if they moved in that
direction--and most of us don't--you know, there would be some reduction in
acrylamide by that move. So that is a
risk management approach right there.
And then,
you know, there's--one can envision a series of risk management options, but
we're not--I mean, that's not what we're--
Would you
like more?
DR.
BUSTA: I just wanted to make sure it
didn't go by me.
Second
question I have is, is there an indication of the amount of effort that is
going to be put in on each one of these five steps, and is there an indication
of budget amounts? Or is that what
you're looking for from us? How much
effort will be put in on the assay versus the other concurrent activities?
DR.
TROXELL: I think you should address it
scientifically and tell us what you think are the important things to do,
whether they're critical things to do, and if you want to say, you know, this
is the A list versus the B list and the C list, then we'll try to figure out
how to get that money and the funding.
There is, as I said, tremendous interest out there. I mean, Europeans are spending a lot of
money on this; industry is already spending a lot of money. There are a lot of ways to ultimately fund
this work over and above federal funding.
And then, we just have to kind of check to see, you know, here's the
list, are people doing it, is it credible work, and where should we fill in the
gaps. But I would not right now
think--put a lot of weight on, you know, the particular cost. You might want to comment that that's very
expensive, possibly, for what we might get back, but--
DR.
BUSTA: Okay.
DR.
TROXELL: Other questions?
DR.
BUSTA: As I see us proceeding--you can
help if you see me going down the wrong track--but as I see us proceeding this
morning, is to go through the five areas that we have on our agenda and discuss
those with your questions, if we need clarification, what we see as evidence or
need of evidence, discuss them as thoroughly as we feel we need to. And if it appears to any of you that those
are not--that we should not separate and try and stay in that order, we could
rearrange it. I don't have any problem
with starting with the bottom one of the list or whatever. And after we've exhausted ourselves, we will
then go on to the three main questions.
And we do
not have to take the entire morning for discussion. If we feel we've gotten the information that we need, we can move
forward into discussing each of the three questions that have been posed to us
and we will go around and each make comments on the questions, individual
responses on each of the three questions.
We have plenty of time to discuss the various aspects.
DR.
HOTCHKISS: I just wanted to ask Dr.
Troxell kind of an umbrella kind of question, in part because he mentioned it
as part of the committee's Charge.
Throughout the presentations and in your summation, the agency has gone
through the same order of steps in the Action Plan. But you haven't added the would "priority" to this or a
sequence. Have you decided or thought
about a priority, or are you asking us to advise you on that?
DR.
TROXELL: Well, I think in the Charge we
do outline the various components done concurrently. Certainly, if you see some sequence, we'd like to hear about it. I think, you know, we have always thought
that, for example, it doesn't do much good to analyze a lot of samples without
a solid method, so we built that method first to our satisfaction. And now we have probably the round-off thing
of, you know, doing the inter-lab peer verification and so on. But we're--you know, so we have that
done. Yet clearly, I think, one wants
to construct a plan with the right sequence of events, and I think that's where
the priority also comes in. So I think
you can help us to identify what needs to be done first and second. I think there are also independent things,
like one really needs to not wait to work on formation and find out if there's
a way to reduce the amount of acrylamide in the food supply for the final word
coming in from the risk assessment. So
that's why we have these things going on concurrently.
DR.
HOTCHKISS: Thank you.
DR.
BUSTA: Before you go, in your question,
I'm interpreting in that Question 1, the sequence of--you have the first
sequence, and then it says "concurrent with formation studies and toxicity
studies"--and the "and" meaning a third concurrent activity,
right? If I interpret that way that's
blocked, there are three concurrent activities going on? I just want to make sure I--
DR.
TROXELL: Right, the--yeah, there's
three. Yes.
DR.
BUSTA: Three concurrent, okay. That's what that "and" means. Okay.
I just don't want to get off here.
The
alternative approach to discussing, whether we go--whether in toxicology and
analytical methods, formation, et cetera, would be to go through the Action
Plan that started with Testing of Foods.
Which is more comfortable? Do we
want to start off with questions and discussion about toxicology, or--Dr.
Hotchkiss?
DR.
HOTCHKISS: Because FDA has set a
sequence, for my own thinking, I would think we would want to go through the
sequence they have set up before discussing--it also seems like a logical
sequence to me.
DR.
BUSTA: "Sequence" being the
Action Plan?
DR.
HOTCHKISS: The Action Plan.
DR.
BUSTA: Okay. Is that all right with everyone who are poised to talk about
toxicology right away?
DR.
HOTCHKISS: I assume we'll get to
toxicology. I have a number of
questions about that as well.
DR.
BUSTA: And why doesn't that surprise
me? No.
All
right, well, let's look at testing. We
had a presentation on testing.
Questions, discussion on the testing of foods, which includes the
methods development and approach to occurrence?
DR.
FISCHER: You're not looking at the
draft Action Plan, right, you're looking at the slides?
DR.
BUSTA: Yes.
DR.
FISCHER: Is that the way you're going
to go through the Action Plan?
DR.
BUSTA: Well, we can go with the draft
Action Plan. Tab 5. Would you prefer that one?
DR.
FISCHER: It would seem like that's the
best thing to do.
DR.
BUSTA: All right. So that when we get to number 2--or do you
want to look at the major goals or just start into the discussion? Any comments, questions on the
background? Any clarification needed on
the Major Goals?
DR.
TROXELL: I would like to make a
suggestion. While the draft Action Plan
is, you know, in more of a summary format, the presentations were intended to
provide more depth, so I would use them in conjunction, at least.
DR.
BUSTA: One comment when I look at the
Major Goals is that "risk" shows up in at least three places and is
inferred in others, and I think that it's obvious that the risk-assessment
component is going to be the focus and I think that's been identified as we've
gone through, that eventually we have to get to risk assessment. So as we're looking at that, we can think of
all the concerns that there are to try and get risk assessment.
Number 2
on the Action Plan is Testing of Food.
DR.
FULLER: Before we move off that, just a
comment. And perhaps I've just missed
it in all the discussion, but I think the--at least as I'm trying to get to the
basics of things here--the issue of looking at occurrence of acrylamide in
foods, and variability, et cetera, et cetera, et cetera, I think what I haven't
seen yet is on--and perhaps someone from--maybe Dr. Troxell could help on
this--is at what point--has there been any consideration at what point that
part's going to start and risk assessment to begin, based on information that
is currently available on the tox data?
Am I making any sense? Are you
following my question? When do you have
enough of the exposure information? And
I just want--because we could do that forever.
DR.
CANADY: We're already in risk
assessment, in the sense that we're doing a--we've done a safety risk assessment,
we've done evaluations like that. We
recognized early on that we needed a lot of information regarding exposure,
regarding occurrence in order to do a full risk assessment. I think you're right. We're at the stage where we can start
framing the models, start putting the models together, figuring out what
questions we need to ask of the risk assessment. And so we are doing that.
Of course, it's an iterative process, so we have to have enough
information about where it occurs, obviously, before we can start understanding
exposure enough. I think we're to that
point almost. There are still a few
more, you know, basic shapes to fill out, but, yeah, I think we're to that
point.
And
again, we need to understand variability to some degree, but then risk
assessment is going to help us understand, through sensitivity analysis, for
example, which are the important exposure elements, which are the important
toxicity elements, and so on. Again,
though, we need to think what are the questions we're asking a risk assessment
to help us with.
DR.
FISCHER: Well, I'm confused about the
exposure, after you said that you've started with risk already. Because I thought you were doing the
exposure analysis in two steps. One is
that you were going to do this--not monitoring, but this broad-picture thing,
not taking time to get enough measurements or data to do a risk
assessment. Now at first, you were
looking at where it is, as opposed to how much it really is in a given food
group.
DR.
CANADY: Right.
DR.
FISCHER: And you're in this first stage
now. You're just looking things up and
seeing whether it's there. And you have
some numbers, but those aren't enough data to do the exposure part of a final
risk assessment with. Am I correct?
DR.
CANADY: I think you're both
correct. I mean, the point is we're
trying to understand when a full risk assessment, when is a complete risk
assessment going to be done. And my
answer is, you know, it's an iterative process, again. I hate to keep saying that, but we're at a
stage where we can use the current data to start framing the risk models that
can then help us understand what further data we need. I don't think we're to a stage where we can
do a full-blown risk assessment that answers all the questions we need to
answer.
DR.
TROXELL: Let me also add that, as Dr.
DiNovi said yesterday, that they're already in the process of doing an initial
exposure assessment. As you all know,
exposure assessments are going to have more certainty or less, depending on the
amount of data you have in there. If we
have 1 point per food, we're going to have a tremendous amount of
uncertainty. So, you know, that's part
of getting the kind of critical mass of information to have a reasonable level
of exposure assessment. Also, on the
tox side, you have a tremendous number of uncertainties, so if we get some of
the--you know, what would be the critical quick data that would help us zero
that in so we can do that next iterative step and, you know, do a risk
assessment that has less uncertainty so we'd be more comfortable it would be
predictive, rather than the risk assessment just saying, well, you know, these
are the other research steps we should do.
I mean,
risk assessments can be used for--you know, to assist risk management, but they
also can be used for determining where the gaps are so we can reduce
uncertainties.
DR.
BUSTA: Questions?
DR.
FISCHER: Well, it seems to me the other
way to do it would be to, at this point in time or at some time soon, decide
where it's likely that the largest risk is going to come from--what food group,
for example, or what group of foods represent the largest exposure; and then
get the necessary data on those groups and do a risk assessment. So what you're doing is looking at a
worst-case situation first to get a good idea about what the risk might be, as
opposed to doing an awful lot of work directed at the whole sphere of
foods. I'm suggesting to focus that on
what you can determine might be the most serious problem. There may be two or three food or food
groups that you would look at. If you
want to do it quickly, it seems to me that would be a better way of doing it,
more convincing, than this iterative thing--just keep going, getting more and
more data, and trying to decide, okay, when should we stop and do something
about risk.
DR.
HOTCHKISS: Those groups have probably
already been identified.
DR.
FISCHER: Yeah, that's what I have in
mind.
DR.
BUSTA: Dr. Gray now, and then we'll get
Dr. Canady.
DR.
GRAY: Well, I was going to say I agree
with Larry. That would be--that's sort
of the way to take an approach. In some
ways that has been done. We have some
estimate of exposure, and you can do a -- calculation that tells you this is
potentially a bigger risk than almost anything we've got out there in the food
supply. That's why we have to know a
whole lot better on the exposure and on the tox side how much confidence we can
have in those, sort of, worst-case things that have already been done. But those have been done, and those are the
kinds of things that make people sit up and say all around the world we've got
to spend some time on this.
So I
would agree with you, though, that this exposure--there are ways to think about
doing out exposure, to work with, sort of, the risk-assessment approach that
says where are the big sources of exposure, how can we nail those down--what
are the sources of variability in exposure, how can we nail those down to
understand this better. Because part of
what you're also hoping to do is to get to a place where you can learn, if it
has to be managed, how to manage that risk.
But the
worst-case things have been done, and they've scared the hell out of people.
DR.
BUSTA: Are you saying that you think
there's enough data on these what you've identified are the worst-case to start
doing a risk analysis with that information?
DR.
GRAY: Yeah, I think they suggest that
much more detailed work has to be done at this point. Because using the worst-case approaches, which have been
done--the WHO looked at that with exposure, we've got 20 years of regulatory
experience with acrylamide in other settings--using t kind of information, it's
sufficient there to say this needs more attention. The big question is where do you put more attention to really try
to do a good job of understanding those risks.
DR.
BUSTA: Dr. Canady?
DR.
CANADY: I think maybe part of the issue
we're discussing here is sort of a formalized definition of risk assessment as
the be-all and end-all and "the" document; and the process of assessment,
which, as Dr. Gray has just said, is already going on, the process of risk
assessment. And what I was trying to
say is that using this assessment modeling would help us understand where to
look first and where to look the hardest and where we need to focus on reducing
uncertainty the most, for example.
I don't
think we're disagreeing. I think we're
having a little problem with the definition of risk assessment and, you know,
is there a formalized meaning. That's
all.
DR.
BUSTA: I'm assuming that you have good
statisticians that can determine when you're at a point, an asymptote of having
enough data in a given sampling system to say we don't have to iterate it any
longer or we change the sampling, not just keep taking more and more samples.
DR.
CANADY: Well, the direct answer is yes,
of course we do. The indirect answer is
that's something that is influenced by the framing questions and what are the
countervailing risks, what decisions do you need to make. So you know you have enough if you can make
a decision that doesn't have a high cost in terms of health or in terms of
other things.
DR.
BUSTA: A very judicious answer.
Other
comments on this specific topic? How
much more sampling do you think is needed?
I mean, this has been--we've got this 700 samples. George?
DR.
GRAY: My thought here is, I hope that
there is good communication between the folks doing the exposure assessment and
the folks doing the sampling. Because I
really think that by doing this preliminary exposure assessment, where you're
working with the data that are available on the kinds of foods that people
consume and whatever level of aggregation you have there, you can understand
from trying to do that estimation what kind of data you need that helps you
understand what level of detail and aggregation you need at the sampling
level. And it may be for some foods
you've already got enough sampling to adequately describe the variability in
those and we don't need to go to finer levels of detail--by brand, by potato, by
season or something like that; or it may be that those things are big enough
that we need to do those better for certain of the categories of foods.
So it's
just sort of--it's very much in fitting with what Rick said, that you want to
use the way that you're going to approach the problem, the model way you're
going to try to estimate exposure from how much is in which foods that people
eat how much of, to understand where you need to get more information. So there, sort of, aren't numerical cut-offs
for sampling; it's much more--I think should be related to the way in which
you're going to use that information.
And I just hope that communication is going out. I'm pretty confident it probably is.
DR.
BUSTA: For example, my gut reaction is
that the information on infant formula so far has been essentially
negative. So to continue to sample
infant formula might be a waste of effort.
Is that--
DR.
GRAY: That would probably
be--sure. And that's part of the
statistical analysis that you talked about, of how many zeroes to I have to get
to believe that everyone's going to be close enough to zero that I'm not going
to do any more? That has to do with
what you expect for variability, though, which we've seen is kind of high. This isn't an easy sample question.
DR.
BUSTA: Dr. Hotchkiss?
DR.
HOTCHKISS: That really gets to the
heart of the question that I asked yesterday about comparing analytical data or
inserting analytical data in the databases which calculate consumption figures,
and when you do that, you begin to--you get what percentile you're covering for
a given food product and so forth, and then once you have that information you
can decide whether you have made a sufficient number of samples or not a
sufficient number of samples relatively easily. And that's the reason I raise that. Dr. DiNovi assured us that--and Dr. DiNovi is an expert in this,
spent his career in this, and knows what he's talking about in this, he knows
the databases--assured us that that would happen, and I'm confident it
will. The agency has great expertise in
that area.
I would,
though, really, to ensure--or to be more comfortable with an answer to this
question, suggest in the draft document of Action Plan in 2 that the first
major goal is to assess dietary exposure, and I think that is the first
priority. Under that it has a number of
consequences, analysis in analytical chemistry, for example, but there are two
major parts in order to assess dietary exposure, one of which is measuring
levels in foods, and that's listed as how to do that, but that is in itself not
sufficient.
The other
part is using the best available food consumption databases, and I would
recommend that that phrase or something akin to that be added to that major
goal. When you do that, when you plug
in your analytical data into a good consumption database, all of a sudden you
begin to answer the question of how much confidence you have or don't have that
you have covered the waterfront for that particular food.
DR.
BUSTA: You're suggesting that goes in
on goal number 1?
DR.
HOTCHKISS: Yes, under Major Goal 1, the
first bullet point under that is assess dietary exposure, and I think that's
absolutely correct. But there are two
parts to that, the first of which is mentioned under that--along with that
bullet, that is, measurement. But the
second part is to use that measurement in what I would call the best available
consumption database. This changes all
the time, but FDA has access to these databases, as Dr. DiNovi discussed
yesterday.
DR. BUSTA: Other comments on this specific topic? Ken?
DR.
LEE: I'm very interested in ways that
we can solve this problem in that--you know, best-case scenario would be to
reduce the level of acrylamide in foods to zero. And I think those Industries that are most affected by this, by
having the highest levels, are going to do work that will likely lead to a
reduction in that level, if not ultimately reach that goal of zero.
However,
I'm also concerned by how that occurs in cooperation with the Food and Drug
Administration. We saw, for example,
the posting of brand names and acrylamide contents on the World Wide Web, with,
of course, the footnote that these are incomplete data sets and you shouldn't
put any credence in these data. But if
I was a very litigious person, I would just be drooling at that list. And that doesn't really serve the scientific
interests or the best interests of consumers.
Because if this situation gets tied up in the courts, and if industries
are afraid to come forward with forthright data or data on how their process
variables affect acrylamide content of food, we're going to be set back quite
significantly.
So I
would encourage any system that allows free and unencumbered exchange of
acrylamide information in a way that it's blinded to brand identify.
DR.
BUSTA: Dr. Kuzminski.
DR.
KUZMINSKI: Thank you, Ken, for making
that point. I believe--gut feel,
without any personal knowledge--I said it yesterday, and at the risk of
nauseating the rest of the subcommittee, I'll say it one more time, that
there's probably data out there in industry that is good, reliable, solid data
in terms of occurrence in finished product, and probably data out there in
terms of occurrence throughout a process to make that product. And I think the agency, should they be able
to create an environment and situation and procedures where that data is
accessible, might save themselves a lot of time, a lot of effort, and probably
a lot of money in terms of getting that information. How they use that in terms of in combination with consumption
data to come up with the true exposure and risk information, then can follow.
But
again, just going from experience, the way this issue suddenly bloomed last
spring, there's been several months passed since that time, and the reputable
companies have been all over this, just all over this issue. It does a responsible company no good in the
long run--and this is a long-run issue--to generate data that is not good,
analytically not good from a sampling methodology, because their own
credibility goes down the tube.
So I
would just echo your comments, Ken, that I would strongly encourage the agency
to do this.
DR.
BUSTA: Dr. Hotchkiss.
DR.
HOTCHKISS: In a switch from several
hats, and as a former FDAer and having been intimately involved in a problem or
an issue very similar to this before, one has to recall that FDA is an agency
based on statutory law and must ultimately answer to that statutory law. As well, the agency has an obligation to
maintain its appearance of credibility--not just its credibility, its
appearance of credibility. While the
agency should take into account industry-generated data and so forth, it also
must realize that it does not have control over that data, the way that data is
collected, the quality of that data.
And therefore, when push comes to shove in a legal sense, the agency
probably does not want to rely on that.
In the
past, particularly with the nitrosamines in beer issue, this was settled quite
nicely, actually, by going to a--the industry went to a third party, a quite
credible third party. That third party
did analyses for the industry, essentially sanitized that data by company name,
gave that data to the agency. The
agency felt that that was a good measure of what was going on out there. That data eventually was all published in
the peer-reviewed literature and saw the light of that venue and so forth. But in the end, when the agency set action
levels, which they did--that is, they took legal regulatory steps around the
issue--the data generated by industry was not used for that because it was
illegal; but on the other hand, the agency took that data by going through a
third party which sanitized the data.
So there
is room for compromise here, but in the end the agency has to remember that it
has the force of law.
DR.
BUSTA: Terry.
DR.
TROXELL: Thank you. I just wanted to point out that this data
will probably be available through JIFSAN.
I mean, they're setting up this Infonet. As Dave Lineback said yesterday, industry will be able to submit
in a blinded way before it comes to JIFSAN.
We have heard at the JIFSAN workshop that there's probably 2,500 samples
been analyzed out there around the U.S., and then we've heard since then that
there's some 4,000 analyses in Europe that are being compiled by the U.K. in a
database. This is going to shed a lot
of light on just how many zeroes do we need in some things to say, well, we
don't have to worry about that.
The other
thing, of course, it's going to--I think, while there's some data on particular
products, a lot of effort has gone in with many of these analyses to try to
figure out what in the chain of production is contributing. So that kind of linkage is very important. And that doesn't necessarily fit into the
database, but that also would be very valuable, again, to link into this
information network in a blinded way so everybody can benefit from it.
DR.
BUSTA: Other comments on this
area? We'll be getting back to exposure
more later, right? I have a question on
exposure, but I'll wait for that one.
Some people trust NHANES more than I do.
The next
item in the Plan is the toxicology. We
had presentations as well as the development of new data on toxicology. Comments and discussion in this area? We had Dr. Canady up there on and on and on,
and he's here smiling and ready to go again.
Dr. Hotchkiss.
DR.
HOTCHKISS: In my view, clearly, most of
the items outlined in the draft Action Plan are certainly needed and should be
undertaken, particularly those that correlate some of the biomarkers with
exposure--although my own view is that a fair amount of that work has been
done, particularly by Tannenbaum and Farmer, through cigarette smoking. There's actually a very good database that
correlates number of cigarettes consumed per day and hemoglobin adducts and so
forth, which is obviously not foods, but by a different route of exposure. But you would assume, I think probably
correctly assume, that inhalation would be the worst-case scenario compared to
ingestion, and so that database seems to me to be very strong and worthy of
careful attention, and may in fact be sufficient to make some conclusions. But still, I think, biomarkers are
important--biomarkers on target tumors, very important correlation between
exposure and genetic adducts and genetic materials, clearly important.
The one
area of the Plan that's a little hazy to me--and maybe it could be further
clarified for me--is the chronic tumorigenicity study. Apparently FDA four years ago or so found
the data of sufficient quality to actually--and formally concluded, through the
Cancer Risk Assessment Committee, that the data was robust enough to actually
set what amounts to an ADI kind of number and so forth. I just wonder, by spending all that time and
money in a chronic rodent assay what would be expected to be learned that's not
already known? And what would the--I
mean, I think I'd bet the mortgage that--it's not much of a mortgage, but I'd
bet the mortgage anyway that you're going to find out in fact it is a carcinogen
in the rat, and you may get a little bit different answer than the previous
studies, but it's probably going to be well within an order of magnitude of the
answer you already have.
The rest
of the toxicology I think is great, the one about spending millions of dollars
to do that kind of study.
DR.
BUSTA: Dr. Canady.
DR.
CANADY: Thank you for that
comment. I think your two comments, or
the two areas you commented on, are actually related, though, in the sense that
one of the reasons we're very interested in doing an NTP bioassay is that we
can fold in biomarker data, DNA adduct data and those sorts of things with the
end points that would be considered under a chronic assay. So that's one point. The second point is that early information
from the bioassay will also be very useful to us, dose-ranging studies,
corollary studies, and so on.
So, while
I understand that going into a multi-year process to get to an answer that may
not be substantially different from what we already have in hand is something
you might question. I would make the
point that the information we could get by bringing more advanced
technologies--or rather, bringing a fuller suite of technologies to bear on the
problem may give us a better understanding of the extrapolation from the rat to
the human than we currently have.
Having it all in one package with the same animals is going to help us
make that low-dose extrapolation a lot more confidently.
And
that's that argument I would make for having the bioassay. The other thing is that we talked about zero
as a goal. We're not going to get to
zero for quite a long time. This is not
going to be an issue that's going to go away.
DR.
HOTCHKISS: If I could just follow that
up. I'm sorry, I don't want to sound
too lawyerly--I'd rather sound human than lawyerly. As I read what actually was available to the agency and
considered in depth by the agency in '97, and I believe before that, was--I
don't want to give you the quote, but it's something like the agency considers
the data robust or sufficient to make this kind of--in other words, none of the
issues that you raised were raised apparently three or four years ago when
acrylamide toxicity, as it relates to potential migration from food contact
materials, was an issue at the agency.
But now you feel that at that time the agency felt that it was
sufficient, but now it doesn't. Is that
the deal?
DR.
CANADY: Decision context is always
something that I think you need to consider in these situations. And at that time the decision was that food
contact exposure--which was, if I remember correctly, three orders of magnitude
below what we're considering now, perhaps more--in that context the
dose-response information was clearly adequate. It was clearly sufficient for us to make a decision that that use
was one that did not present an unacceptable risk.
When you
consider in contrast the broad exposure that we're currently considering, you
have to ask the question, I feel, do we have sufficient information, again, for
this new decision context. And that's
the question that we'd like to have the committee address, really.
DR.
BUSTA: Could I just ask the
question--yesterday, someone said it was a flat extrapolation.
DR.
HOTCHKISS: It comes from FDA's
document.
DR.
BUSTA: Yeah. Flat--could you explain "flat," to make sure that I'm
not misinterpreting? Does this mean
that at low concentrations it's potentially more hazardous or less hazardous?
DR.
GRAY: Can I just--I mean, from my read
of this document, when FDA reviewed this, it simply says that the dose-response
information in the range at which it was tested, which is still very, very
high, was relatively flat, meaning that between controls and dose groups the
tumor rate didn't go up like this; it went up--it was a very flat dose response
curve.
DR.
HOTCHKISS: Yeah.
DR.
GRAY: That's all I was saying. And that's in the range of doses that are
thousands of--well, hundreds of times higher than what we're talking about
today.
DR.
CANADY: Actually thousands is right.
DR.
GRAY: Yeah.
DR.
FISCHER: I still don't understand
that. Meaning--
DR.
HOTCHKISS: What it says is the response
is not tightly correlated to dose. In
other words, if I go up in dose, I would expect a number of tumors, number of
animals and so forth to in some way proportionally go up. But those curves were relatively flat. That doesn't mean that the chemical is not a
carcinogen; it just raises a flag, I think, for many toxicologists that there
is more to the story that's not understood, that it--in most cases,
"more" produces more response; in this case, for some reason, maybe
it's saturating some kind of system that--a system that converts it into the
penultimate or the actual carcinogen.
Maybe it's saturating that system, so when you double the dose you don't
get double the response. Something like
that. There's more to the thing. It raises a flag that we don't know
everything there is to know about it.
DR.
BUSTA: But in reverse, does this mean
that when it's flat it means you could get--you know where I'm going. If it's flat enough, then you could go very
down, very low doses and still get a response.
DR.
HOTCHKISS: Your operative would of
"could" is right--a lot of things could happen.
DR.
GRAY: But if you look at these data,
what most of them say is that things--the low-dose groups have very little
going on. They're flat with the
controls, too. So I mean it's--this all
depends on ultimately what sort of choices of models and such are used to
extend those data. So that's--you know,
that dose-response data is moderately interesting in that high-dose range.
In fact,
if I could make a comment, I mean, I think one of the problems we have here is
that this particular issue is a challenge to the traditional ways that these
risks have been assessed. Either the
reliance on high-dose rodent cancer bioassays--do we believe that a rodent
carcinogen is always a human carcinogen?
Or the models that are used, the linear no-threshold model that's used
to extend the dose response from animal data to human--is that correct or is it
not correct? And also, what levels we
think are important levels to manage risk.
Are hazard quotients of 1 something we get worried about when we compare
it to the ADI?
So this
is a tough one. And one of the things
that I'd actually like to perhaps see a little bit more of in the Action Plan
is, I agree that these research data-gathering goals that are set out here are
very good and very appropriate. But
what I'd like to see is--think a little bit more about is how those data are
going to be used. And I think one of
the most important things that we could recommend very early on is to use
things like the toxicokinetic data and things like that that are going to come. Put them into some kind of physiologically
based pharmacokinetic models, things that are going to let us look at the
assumptions that are based--that are in the traditional approach.
And with
those kinds of things, we can look at the difference between routes or food
matrices and we could say pretty quickly--and I think Dr. Hotchkiss is probably
right, by the time we get to the right doses and another rodent bioassay, we're
going to get about the same response.
We can look at the different routes of exposure, the inhalation data
from Epi, which is probably equivalent to a considerably higher oral dose. If we had good pharmacokinetic data, we
could relate that--and we might be getting closer to doses that people are
getting--and have maybe more confidence in what the Epi is telling us compared
to the animal bioassays.
So I
guess I'd like to see a little more discussion about how these data are then
going to feed back into the process and be used. And some of them will be much more useful in the shorter term
than the time that it will take to get a new rodent bioassay done, which, under
any circumstances, won't be sooner than three years from today and will
probably be longer than that.
I'd also,
sort of along the same lines--and this is echoing remarks we've had from
others--is urge the FDA to use some of those data that are coming from
industry, especially some of that really impressive stuff we saw that's being
done by the chemical industry around acrylamide. Those human studies will be extremely helpful in trying to do a
good job with PB PK. I was at the
Chicago meeting, and the head of the company was there offering to allow all of
the medical monitoring data and all of their plants to be used for Epi
studies. That seems like something that
should at least be investigated and potentially used. It's another opportunity, again, if we're going to question this
use of the high-dose rodent bioassay as the basis, let's get in there and get
some more and some better Epi data to help us have some comfort with what we're
going to do.
So I
guess the thing I'd like to see is, in addition to the science that's laid
out--and I think it is the right science that answers a lot of the questions
that need to be answered--is think about how that's going to be used, both in
the short term, when it can help us answer questions today, and in the longer
term, when it comes to ultimately making decisions.
DR.
BUSTA: Dr. Fischer.
DR.
FISHER: I would like to know whether--I
can't recall whether there was going to be a mouse component. Are mice going to be used as well as--okay. Because they're supposed to be somewhat more
sensitive. So I suggest that the
mouse--it's a good idea.
I think
it's worth--I never am sure whether it's worth to do the rodent bioassay the
way it's usually done, with high doses, to do risk assessment with. Clearly, I think what we know already from
the bioassay is that it's a carcinogen.
I mean, there's a lot of evidence to back that up. But what we don't know is whether it causes
an increased risk of cancer at very low doses.
And the only way we're going to know that is, I guess, repeating the
assay with lower doses, trying to see a better dose-response relationship than
we've got now. We know at high doses we
can see this, but how about at lower doses in between the NOAEL and the doses
that produce tumors?
But in
repeating the bioassay, I certainly think it ought to be a mechanistically
oriented exercise. And I think Dr. Gray
has already talked about that, I think.
We need to--certainly in its plan to measure biomarkers and so on,
that's definitely something that should be done. But I think they ought to think carefully about other information
that they might be able to get, toxicokinetic information, from these animals
that are used in the assay. This is
being done for other compounds by the EPA to do a very mechanistically based
bioassay. And I think here we have a
good chance to get a lot of information from these animals, who are going to be
dosed for a long period of time, in terms of toxicokinetics and mechanisms if
we make the right measurements.
So having
said that, I think it wouldn't be a bad idea to get the National Cancer
Institute and NIEHS interested in acrylamide research based upon the
mechanistic aspects of the outcomes that are expected, or not expected. Couldn't NCI put some money into mechanistic
research, maybe even tying it in to the cancer bioassay; and couldn't NIEHS
look for mechanisms, or examine mechanisms which may be active in these animals
that are getting dosed for two years, and so on?
So--and
perhaps they could do this by putting out RFAs for research on
acrylamide-induced toxicity, cancer and other things--reproduction and so
on. Neurotoxicity. I think it's worth a try to get these
funding agencies interested in helping with the mechanistic data that we need
to understand a toxicity, cancer and others.
I don't know what the FDA thinks about that, whether that's
possible. But I certainly suggest that
that be done.
DR.
HOTCHKISS: Let me point out that the
IARC Monograph, Vol. 60 of the IARC Monograph, which details a great deal of
toxicology--as you're all aware IARC monographs do--points out that acrylamide
has been tested in both mouse and rat.
Its probable route of metabolism to the ultimate carcinogen has been
studied in some detail, but -- never proved these things. But given the history of epoxides, beginning
with aflatoxin metabolism and going through cyclopropenes and a whole variety
of epoxides, I think that most cancer toxicologists would feel--would, again,
bet mortgages larger than mine that that is the proper route. In other words, much of what we're
discussing is, I think, reported in the IARC Monograph, which is in fact a very
detailed and--I haven't counted the references, but probably a hundred or more
references on the toxicology of this compound.
This compound has been known to be a carcinogen for more than two
decades, its metabolism widely studied, its epidemiology studied in
occupational environments and so forth.
This is a little bit of an unusual thing from the standpoint of food
contaminants in that we have all this history to it, and I don't think the
agency should spend a lot of time reinventing the wheel, but rather trying to
decide what to do about the wheel.
DR.
BUSTA: Dr. Lee.
DR.
LEE: Yeah, there's a lot of talk about
animal studies. I'm not a toxicologist,
so I'm really speaking out of a quest for more information. It appears to me that the relevance to the
human is the most important thing when it comes to food exposure, particularly
from the Food and Drug Administration's point of view. So I would just underscore what Dr. Gray
alluded to.
We heard
briefly yesterday from, I think, Dr. Friedman about a Covane study in Madison,
Wisconsin, where 24 sterile males were being fed three-dose levels of
acrylamide, and--I mean, I think this was a casual mention, but to what extent
is this going on with human studies?
And I don't have that information in front of me. So I need to know, is there a lot of feeding
going on of human beings with acrylamide, and what useful information could
come out of these studies?
DR.
BUSTA: Sterile males?
DR.
LEE: Yeah.
DR.
BUSTA: Dr. Whitaker. I presume it was voluntary.
DR.
WHITAKER: I would just like to amplify
on what Dr. Lee said. My thought my
process is as I sat here and listened--I'm not a toxicologist, so I feel like
I'm on the outside looking in. But I've
had many years of exposure to aflatoxin, through the Codex system, of trying to
set limits and understand what the consequences of aflatoxin was in
humans. And nobody could every agree on
the rat studies. And the definitive
studies that seemed to break the ice dam was the Chinese study. And so it--I don't know whether the analogy
still holds here with acrylamide, but maybe the emphasis should be headed more
towards the human effects if indeed that data is out there. I've heard you mention--Dr. Lee mention, Dr.
Gray mention--so maybe those studies are the ones that should be emphasized,
because we may head down the same road that we did for 25 years with aflatoxin
and its effects on humans.
DR.
BUSTA: And we don't want to do that.
DR.
LEE: I can add that they used sterile
males because the concern was -- reproductive effects.
DR.
BUSTA: Dr. Fuller.
DR.
FULLER: Thank you. I'm pretty comfortable as well with FDA's
action plan on all of this, and I'd like to reiterate, I guess, a couple of the
points that Dr. Gray. And also, just
to--back to FDA, to ensure that they are looking at and in consultation with
the chemical industry on the studies and aren't repeating any of the studies
that--and I didn't have a good sense of how familiar FDA was with the work that
Dr. Friedman was telling us about at the end of the day yesterday.
DR.
CANADY: I think the best way to share
that information is through the Acrylamide Infonet, to make people aware of
studies, what their protocols are, when the results are expected. And then the point was made earlier that
we're constrained by what we can use in regulatory purposes, so it needs to be
peer-reviewed and published, obviously, as well, before we can ultimately use
it to make regulatory action. That
would be my understanding.
DR.
FULLER: Is there no mechanism under
which you can review at this stage, if it's made available to you, the conduct
of the studies, et cetera, to provide some reassurance? And I'm just thinking of let's don't
duplicate if it's not necessary. And I
appreciate that the constraints being a regulatory body and needing to maintain
integrity, et cetera, et cetera, et cetera.
At the same time, I hate to see a lot of resources spent if there are
some--if there are good data that are being generated that would either prevent
the necessity of doing a particular study or, more importantly, change the
emphasis or what you're looking at in a particular study.
DR.
CANADY: Yeah, I think this underscores
the fifth component of the Action Plan, and that is collaborations are an
essential part of collecting information, making sure there isn't replication
and those sorts of things--or actually, making sure the replication is
knowingly done, to the degree that you can.
So, yeah,
I think, again, this is part of the Plan that we've laid out, that we would
look to all sources and collect information where it's available and avoid
unnecessary duplication where we can.
DR.
FULLER: Has--and I'm sorry, I
just--maybe you are answering the question, I'm just not hearing it. Is that happening now, in the planning
stages, based on--and have you had that collaboration, or is there something
about to happen with that? I just didn't
hear that in the presentation.
DR.
CANADY: Yeah, I think the first time
that I heard about the studies that were mentioned yesterday was at the June
consultation at Geneva. And at that
time, we asked for the protocols. We've
again asked for the protocols, I think it was at the Chicago meeting. And we heard the same offer; it was made by
SNF. So we're willing to look at them,
receive them and so on.
DR.
FULLER: Thank you.
DR.
TROXELL: So again, we're fully aware
what they're doing; and secondly, you know, as with food additives, we review
any studies that are submitted, and we'll use them to the fullest extent. We obviously want to minimize
duplication. We're very interested in
seeing what the results are of their human exposures so we can learn what we
can about the adducts.
DR.
FULLER: Thank you.
DR.
ACHOLONU: The material given us here
says there are uncertainties about the impact of acrylamide on public
health. There are uncertainties. Yes, tests have been done on rats, on
mice. We have tested food to find out
the content of acrylamide in food.
Until we find a way to connect it to human beings, it will be causing
unnecessary alarm to the public. If we
no get out information saying that acrylamide is carcinogenic, yes, it is
carcinogenic to rats. The genetic
makeup of rats and human beings are quite different. Of course, we have got mammals.
But we have to be aware of that and be apprised of it. But to connect this with human nature, we
cannot say that we have gone far in making people aware of the dangers of
acrylamide.
And this
is the point I want to make. Whatever
we do, whatever study we conduct, should lead us to connecting it to human
beings. That is the comment I wanted to
make.
DR.
BUSTA: I don't want to change the topic
here, but there's a fair amount of mention about glycidamide, and yet we just
talk about acrylamide. If that is the
mode of action, or apparent mode of action, why aren't we doing more testing on
glycidamide?
DR.
CANADY: I'm not sure I heard your question
right. Did you mean in the last case to
say "acrylamide"? Could you
restate the question? I'm sorry. I didn't quite understand it.
DR.
BUSTA: Well, you know, it's my
understanding that glycidamide is the step of the toxicity. Is that right?
DR.
CANADY: It's one of the proposed
mechanisms. There's some debate for
neurotoxicity and for the reproductive effects, for that matter, as to what the
active moiety is. And that's one reason
to do the mechanistic work that has been underscored several times and that we
have a lot of interest in doing. And
that is to understand what happens between the higher doses we have information
for animals and humans in and the lower doses that we see in foods--understand that
relationship. One of the steps in there
is figuring out which chemical actually causes the damage in the body, which
converted chemical or which parent chemical causes the damage, so that we can
make that extrapolation and understand how rats or mice differ from humans and
what we would expect to happen in humans compared to what we see in rats and
mice.
DR.
BUSTA: And the glycidamide, is that the
adduct?
DR.
CANADY: It is one of the two adducts
that forms with hemoglobin. Acrylamide
and glycidamide both form adducts. The
argument has been made that direct interaction with DNA only occurs for
glycidamide. The argument has been made
both ways with regard to neurotoxicity whether acrylamide or glycidamide is the
active agent. I'm trying to state this
neutrally. I mean, this is the way the
arguments have been laid out.
DR.
BUSTA: But I hear very little--it's
mentioned, but I hear very little about research on glycidamide.
DR.
CANADY: I'm sorry. The nomination to the NTP was for both
glycidamide and acrylamide. And that
was, again, recognizing the need to understand the mechanism for low-dose
toxicity. And again, one of the main
reasons for doing the NTP studies is to understand this transition from
high-dose animal to low-dose human. I
mean, that's a very important part of why we nominated acrylamide and
glycidamide, so that we could do the mechanistic work, essentially.
DR.
BUSTA: Other questions around this
point?
As I look
at--we're working through here, toxicology moves on to methodologies.
DR.
GRAY: Could I just ask, what tab are
you on? I'd like to be following along.
DR.
BUSTA: Well, tab 5 is the general one,
and then I keep flipping back to the presentations. Formation would be the next item in the draft plan, and we have
presentations on formation by Lauren Jackson, who's here. She got here--that's impressive.
Questions
and comments on formation?
DR.
FISCHER: Well, I would like to
see--there's two ways to look at this.
I think I mentioned this the other day.
We need information for the person who's doing the cooking at home on
ways to prevent the formation of acrylamide.
And of course industry needs to know the same kind of information so
that can put out products that have less acrylamide, if it's needed.
So who
should do the research? Should the
government do the research for the homeowner who is producing acrylamide at
home, and industry do research to reduce acrylamide in their products, and not
have the two talk to one another? That
seems--I imagine that could actually happen, but it seems crazy to have it
happen.
So I
think the two groups, those doing research with federal money and those doing
research with their own money on their own products, ought to be talking to one
another and sharing information. And I
know the FDA says that they have good collaborations with industry, but I would
question whether they really have the way to get the information that they need
from industry. For example, we just
heard that they have not yet gotten the protocols from the studies being done
by the chemical industry on acrylamide, after having asked for them. So I wonder whether there really is this
good collaboration going on.
So who
should--I think there should be not only a communication, but there should be
some way that the information that industry knows about the formation of
acrylamide be passed along to others so that it can be widely distributed. And I'm not confident at this time, after
just listening this short amount of time, that this is going to happen as smoothly
as one would hope.
DR.
BUSTA: Well, I've heard on several
occasions now that JIFSAN will be the potential route of that. Dave's not here. Do we have any idea how much information is moving in that route
now? Has that been well adopted? Does anybody--
DR.
CANADY: It's just started.
DR.
BUSTA: It's just started. So it's hard to know what--not everyone has
raced to put their data in there immediately.
DR.
CANADY: It's hard to really respond to
that. It's just a few weeks old.
DR.
LEE: As I understood from Dave
Lineback, the Infonet is a worldwide linkage--it's a World Wide Web site that
will link to data that you have either posted on your own website, your
company's website, your scientific website or wherever. So in that way, it is already in the public
domain. But I did ask Dave yesterday
what is going to motivate me if I have a company and I have a product that has
acrylamide that's a thousandfold higher than everyone else's; am I going to put
that on the Web? Okay? I don't think I will. And I think Dave agreed that a company is
not motivated to do that.
DR.
BUSTA: But we heard NFPA, I think,
offered to sanitize data? Is that an
appropriate interpretation? It's blind
data--nice word. Blind data. Is NFPA involved in JIFSAN? Were they-- Okay. So that-- okay, Henry just said that I've got to get this on the
record. Can I interpret the shaking of
a head?
DR.
JARMAN: Yes. That's a yes.
DR.
BUSTA: Rick Jarman, NFPA, indicated
that NFPA would blind information through them and put it onto JIFSAN if there
was a concern about that. So that's at
least one mechanism. Will JIFSAN accept
blinded data? Terry?
DR.
TROXELL: Yes. They're willing. As Dave
Lineback said yesterday with respect to the sampling data, that they expect
companies to blind the data either through associations or lawyers and so on to
put it in. And I think the same kind of
mechanism would work for research on formation. I think more of the hindrances are that scientists or even
companies may not want to give up initially what they have learned until they
can, you know, see further that it's going to work or that they can publish a
paper. I think that's where the FDA is
going to keep working to encourage and jaw-bone everybody to, you know, do the
right thing so we can get to the answers as quickly and efficiently as
possible.
Let me
mention also that in addition to the JIFSAN mechanism, I mean, we do have our
consortium, the National Center for Food Safety and Technology, that is a very
mature organization. And that's
where--really, that's where our food processing research is conducted. We have a full division out there. And they have a very strong relationship
with the industry and IIT, and they have a very strong program of food
processing work. And this is clearly
one of the priorities now for the NCFST, and I think that, you know, through
Lauren and the staff out there, Dr. Sadler and IIT, there's going to be
a--there'll be a strength of focus to really get to that formation
research. And we'll keep checking in
with various--whether it be industry and Europe and so on--various people that
are doing research. We'll--I mean,
you're right. We have to keep pushing
to make sure we're gathering the information that people are developing.
DR.
ACHOLONU: I have a question. Yesterday, when we were discussing this
formation of acrylamide, I made some statements with respect to each
connection, the chemical process. And I
read some materials where they talk about migration of acrylamide into food
from plastic. And then, when you talk
about formation of a chemical material, you have to come up with a simple
equation that says from this--if you add this to this, you get this. I think we should pay more attention to
finding out how acrylamide is formed chemically, and go from there. Maybe the chemists or the biochemists should
go into this. We have given it a name.
I have
read the material given. There are lots
of--some equations here, and they talk about acrylamide from Maillard reaction
products. Still, that doesn't give what
we are looking for when we talk about the chemistry of the material, the
substance. Could we go more into this
aspect? Because it said formation
chemical mechanisms governing the production of acrylamide is unclear. I think FDA should spend some time trying to
make this clear.
This is
the comment I want to make. When you
say you're forming something, the public, the scientific world has to know how
this material is formed chemically.
Thank you.
DR.
BUSTA: Dr. Downer?
DR.
DOWNER: I wanted to just respond to Dr.
Fischer's comment about the groups who should disseminate this
information. And I think it should go
beyond just the FDA and the industry, but look at some of the professional
organizations like the American Dietetic Association, like the American College
of Nutrition, and other home economics groups that would be a good conduit for
this information to get to John Public, who's actually cooking at home.
DR.
BUSTA: Dr. Gray.
DR.
GRAY: Well, the first thing I want to
say is that I do--I think the formation research is very important. And I think even there, there are these
opportunities perhaps to do some kind of mechanistic or empirical work, and
would suggest, as I think others have, that, for example, trying to correlate
levels of free asparagine in foods to levels of acrylamide is the kind of thing
that can help build a link to understanding both formation and perhaps control.
But I'm
using this as an opportunity because it's mentioned in this particular bullet
point. It's the first place communication
comes up. I want to follow on Dr.
Downer's points. And I think this is a
place where we really do need to be making some effort.
I think
one of the themes--I participated in the Chicago meeting on acrylamide and risk
communication. One of the themes there
was an important fact that even follows from this Action Plan is we're going to
be having information coming out continually over the next probably five years,
and much of it is going to be led by exposure information. We're going to learn what foods it's
in. It's already now on the World Wide
Web. You can look and see if it's in
your favorite breakfast cereal. And
we're just going to have more and more of that. We're going to have the NHANES data finding the material in
blood, of you, me, our kids. These are
going to be communication challenges that, if we think about them now, we'll do
a better job of dealing with them.
And for
that, I want to suggest that FDA take advantage of its own strength in consumer
research, that it work with these industries--these food industries do an awful
lot of consumer research as well; there's a lot of knowledge there. How can we the message that is
appropriate? And I would suggest that
FDA's message so far has been very, very good, including--I want to recognize
their recognition of the potential for tradeoffs here, that there are no simple
solutions to this. How can we get that
message to people, whether it's leveraging the professional organizations,
physicians, people who interact with people and have some moral--not moral,
authoritative--an authoritative voice with them. Don't attribute too much.
Or if these are things that have to be done directly. If we're working with the news media, how do
we make sure that these messages are well done?
And I think
one of the things we have to think about is there's a big world out there that
studies risk communication. When we've
got a strong consumer component, including the fact that you and I are making
acrylamide at home when we make toast and we make bread, we have to think very
carefully about how we're going to communicate those things.
And then
finally, I guess, but along those same lines, one thing that I've found, I
didn't--well, it didn't sit quite right with me in the Action Plan--is a
fundamental assertion right off the bat that what we want to do is reduce
acrylamide levels. I think there is
still--we're recognizing that there is scientific uncertainty; we're not sure
the levels at which this is a problem.
And I think even if the Action Plan recognizes it, there's some
uncertainty. We've got to learn
something before we even think it's good to do that--that helps with
communication. If we have an Action
Plan that says get as much of it out as we can today, and then say don't worry,
eat your regular balanced diet, those mixed messages make it a lot harder to
communicate.
DR.
BUSTA: Dr. Lee.
DR.
LEE: I'm glad that Dr. Gray and Dr.
Downer introduced the idea of communication.
And I think it might be appropriate, certainly not today, but perhaps FDA
or some other body would like to make a determination whether or not acrylamide
is a natural substance or it is a manmade substance, or perhaps it's both. Because that, of course, has a lot of
implications when it comes to communication and it also has a lot of
implications when it comes to litigation.
DR.
DOWNER: That was going to be my point.
DR.
ACHOLONU: What is this idea of its
migration? Why are some documents, some
publications making reference to acrylamide migrating into food? Could somebody please explain that to
me? Because in the biological sense,
things that migrate are under their own locomotion. Is the migration by active transport or by passive transport? How is it occurring? How does it migrate from plastic into the
food? Would somebody please explain
that to me?
DR.
BUSTA: Dr. Canady, do you want to--
DR.
CANADY: I think the reference is being
made to prior FDA decisions about food contact materials--the wrappings, the
packagings for foods. The situation
we're talking about today refers to incurred acrylamide through cooking. In other words, you cook the food--it
doesn't migrate to the food during the cooking process, rather it's created
during the normal cooking process. So
the issue of migration affects our current situation in the sense that it talks
about how acrylamide might move out of the food that's been caused to have the
acrylamide in it through the normal cooking process.
DR.
ACHOLONU: But you know it's in the
literature, right? Apart from what you
gave us, check in on acrylamide. I see
it used constantly, "migrating into food."
DR.
BUSTA: I have a question on
formation. Some of that data are really
straight--I mean they're just so obvious, they really hit you in the face with
the presence of glucose and asparagine, I mean, produce all kinds of
acrylamide. When I look at that, I sort
of say all we have to do is apply that.
Is there still--am I simplifying that too much? I look at some of the materials that Dr.
Jackson presented, and it's sort of, well, if you've got a free reducing sugar
and asparagine and you heat it up, you're going to get acrylamide. I mean, it seems just right there, and I
don't--what are the big questions on formation?
DR.
FULLER: You're asking him how much more
work is needed.
DR.
BUSTA: Yeah, it seems I--or is it--are
we going to look into food systems or whatever, but, I mean, it seems like it's
answered; it's there.
DR.
DOWNER: But is it just glucose and
asparagine in the absence of the temperature and the exposure?
DR. BUSTA: My understanding is it's a reducing sugar
and asparagine, maybe cystine, and heat.
And we get acrylamide. Is that--
DR.
FISCHER: I don't think that's true, is
it? I don't think this is true, because
they say--they've told us that if you microwave the products, you don't get
it. So that's heat and temperature--
DR.
BUSTA: It's not hot.
DR.
FISCHER: Sure it's hot.
DR.
BUSTA: Not hot enough.
DR.
FISHER: It's hot. Put your finger in a piece of bread--
DR.
DOWNER: It's exposure time.
DR.
BUSTA: It's only 100 C.
DR.
HOTCHKISS: Never above 100 C.
DR.
FISCHER: Never above 100 C?
DR.
HOTCHKISS: Only at the surface. You can't raise the temperature until you
get rid of the water.
DR.
LEE: Well, you can pop popcorn at a lot
higher temperature.
DR.
FISCHER: It seems to me there was
something with the browning reaction.
DR.
LEE: Those data are incomplete. I don't know if microwave popcorn has
acrylamide or not.
DR.
FISCHER: It think it's in the list.
DR.
LEE: All right, let me look at the
list.
DR.
BUSTA: Dr. Troxell?
DR.
TROXELL: Thank you. Well, if it--maybe you should, if it's
obvious, and professor emeritus, I would go back and figure out how we can do
it. We're all stumped.
You know,
this is you got components of living food materials, potatoes and so on, how do
you--you know, you could eliminate this if you could eliminate the sugar and
the free asparagine. Well, I'm not sure
we have food by eliminating those things, or I'm not sure we have tasty food by
eliminating sugar. So the question is,
is how to maybe reduce the levels in key things so we're--and then--or how to
target inhibition of a reaction.
Because there's an extremely complex series of reactions.
So it's
one thing to say we understand the mechanism, and it's another thing to--a
totally different world to try to capitalize on that which everybody is
feverishly working on now. They're
feverishly working on capitalizing this, to prevent the formation or reduce the
formation in foods. And as far as the
temperature, it doesn't form below about 120 C, so you need to get at least the
surface temperature of the food above 120 and probably substantially above that
to really start pushing the reaction along.
DR.
BUSTA: In regard to microwaves, that's
one of the problems that's one of the problems. It doesn't brown. And so
you--
But what
I'm trying to get to is we're fairly knowledgeable about the formation
mechanisms, and it's the control of the formation and modification of formation
that is the research interest. Is
that--I mean, Stadler published this one graph that seems so dramatic that it
seems like we have a pretty good idea about mechanisms.
DR.
FISCHER: I saw there's some question
marks in the scheme. I don't
understand, and apparently no one else does either, why there's such
variability in the formation of acrylamide, that we've seen the data that
nobody understands. That tells me,
anyway, that there is some factor, or factors, involved that we don't know
about that's causing this variability. Sometimes
in the same batch of products you've got pieces that are much higher than
others. So there's something unknown.
DR.
BUSTA: Dr. Jackson, then Dr. Lee.
DR.
JACKSON: I think when you look at the
data, you're seeing the variability.
There are two sources of variation there, one with the processing, the
other with the raw material. If you
look at a batch of potatoes--and I haven't tested this myself, but from when
I've talked to the people in the potato industry, you grab one potato out of a
bag, they're going to be very different even though they're stored the
same. They're a living plant. And you're going to have variation in the
free asparagine and the sugar levels.
And I
don't know how you're going to eliminate this problem--I mean, Ken Lee talked
about this--I don't think you're going to be able to eliminate the acrylamide
levels to zero, because you can't eliminate asparagine from foods. I mean, that's an amino acid required for
the structure and the plant.
So I
think what's going on, at least from when I've talked to the people that are
doing the potato--you know, the fries--what they're trying to do is look into
storage of potatoes and trying to reduce levels by storing the potatoes and
testing, you know, different conditions where they can store and lower the
levels of free asparagine and sugars that way.
Another way that they're looking into this also is looking into
different variety of potatoes that might have lower free asparagine as well or
free reducing sugars.
But
processing, I think, is the only controllable way, I think, that we can look at
this problem as an agency. I don't know
how we can do it any other way.
DR.
BUSTA: And that's--we have a fairly
good idea of the formation; it's the control and the variability and the other
things influencing that formation that are the real questions.
DR.
JACKSON: I think one of the areas that
we're going to research is to separate and determine where the variability is,
if it's in the process and in the raw material, because--I didn't include the
data in the presentation yesterday, but when we did fry three different batches
of potatoes, same temperature--they were all stored the same--the three
batches, no matter how well I tried to control the temperature in that oil, we
got very different levels. Especially
when you got to the higher temperatures, where you got probably more browning
and things going on, it was very difficult to control the acrylamide. You'd get tight--you know, the replicates
were very different.
So
there's something going on. And that's
why I--it points to using model systems, because you can control the raw
material going in and then you can see if there's variability in the
process. And that's what we intend to
do as well.
DR.
BUSTA: Dr. Lee.
DR.
LEE: Thanks, Lauren, for the
comment. You know I have very high
confidence in you as a scientist as well as your colleagues in Argo-Summit.
And
formation and control, I think, are the same argument, because if you know how
it forms, you know how to control it.
But I would venture a guess, just speculate, that the industry is going
to be the first people on the block to understand how to control this. Because they have far greater vested
interest in controlling it, and they also have a much more controllable process. The consistency of manufacture is such that
you're in control of almost everything you can possibly measure.
So again,
I would just put in a plug here that we make it easy and in industry's best
interest to share both their data on occurrence and process variables that
control. Now, when you're sharing
process variables, you're sharing brand identify, so this has to be done in a
double-blind fashion, if at all possible.
And then
a quick segue--two people have mentioned microwave. You know, if we have data on our website now, 157-181 micrograms
per milligram to microwave popcorn. So,
you know, it's not supported that microwaving is going to give you an
acrylamide-free product.
DR.
BUSTA: Dr. Kuzminski.
DR.
KUZMINSKI: Just an observation just to
follow up on some of the discussion.
I think
that this problem creates a number of opportunities and challenges, challenges
for the trade associations, if you will.
When a company--just from experience, when a company is asked to share
processing information, my experience is--in terms of process variables, my
experience is that that's proprietary information. It's part of the formulation to produce that finished product.
So the
challenge, as I see it, to--and yet we have a situation here where we know that
it exists in finished products, we know that there's variability in the raw
materials going into that finished product, yet we know that that process to
produce that finished product creates conditions that produces acrylamide. So the challenge, I think, to industry is
to--and to the trade associations that represent them, is to figure out a way
whereby valid information can come forward that would help with the levels in
finished product. And I suspect it will
be a very gut-wrenching exercise for that body of society to come up with a way
to come forward with process variables.
The
conundrum for a company, as I look at it, is that they have a product that's
out there with an established market share, whatever that share is. And that product is achieving that share
through a number of means and also because it has a certain product image to
the consumer. And that image to the
consumer is responsible for some of its success. Changing the process to change that image is the big challenge to
a company, to the industry.
So it's
not an easy problem for them to solve.
I'd like the committee to fully realize that, in terms of coming to
grips with sharing that kind of process information. Not an easy problem at all.
But it's a challenge to the trade associations and to industry to come
to grips with it.
DR.
BUSTA: Dr. Whitaker.
DR.
WHITAKER: Lauren, I would just like to
comment that there is another source of uncertainty, and that's in the
acrylamide test procedure. And this is
what I was trying to get to yesterday with Steve Musser.
I suspect
the greatest variability would be from potato to potato, but your sample
preparation and your analytical components of your test procedure also
contribute to the uncertainty. But my
guess is those lower two components, the sample preparation and the analytical,
are small compared to potato-to-potato.
But I think it has to be acknowledged or understood that that's also
there and characterized.
DR.
BUSTA: Are there any other points?
DR.
JACKSON: Actually, I wanted to add
something. We talked about potatoes and
grain products where the asparagine-sugar mechanism's probably the main
mechanism. Coffee we didn't talk about
very much. Coffee--there might be some
other mechanisms going on, mainly because you go to very high temperatures, you
know, over 500 Fahrenheit, 250 degrees C.
So there might be some other mechanisms going on there, and that needs
to be fleshed out as well.
DR.
BUSTA: Dr. Lee.
DR.
LEE: Lauren, it was you that showed
data that at very high temperatures acrylamide contents were lower.
DR.
JACKSON: That's right.
DR.
LEE: So you're speculating that there's
another mechanism there? Or do you have
any clues as to what's going on?
DR.
JACKSON: We don't really know. I know from what the Nestle people--we had
this meeting out in Chicago. Stadler
from Nestle was talking about coffee.
And what they do, is they measure the different roasts of coffee from the
light roasts all the way to the dark roasts.
So they measured the acrylamide levels from light roasts to dark roasts,
and they didn't find any differences.
Which suggests, maybe, there's some type of degradation going on as well
as formation. You know, you--we don't
really know.
So that
needs to be understood, too. The
formation as well as degradation. I
showed there was a dip in the graph there.
That really needs to be understood as well.
DR.
ACHOLONU: This glucose and asparagine
reaction, are you using it as an example of a way acrylamide can be formed, or
is it the general way it is formed every time, every time?
DR.
JACKSON: According to the research
we've seen so far, that is the main mechanism.
I mean, if you look at the yields of acrylamide--if you look at the
yield of acrylamide in a model system, Moltram and his colleagues, when he did
his reactions, .3 percent of the asparagine actually became converted to
acrylamide. If you look in a food
that's fried, you get roughly the same percent conversion. So they kind of match up there. But if you look at other amino acids--methionine,
the other ones, cystine--the amounts, the yields you get from those amino acids
just don't compare. They just
don't--couldn't account for all the acrylamide that you do form in food.
DR.
ACHOLONU: So if you fry french fries,
you are assuming that you have asparagine there and you have glucose--of course
we know that french fries has glucose--and that any kind of combination that
comes up, and we say acrylamide is in this food after it was fried or baked,
that this is the very process that took place chemically? Is this what you're saying.
DR.
JACKSON: I understood your
question. If the french fry, the raw
material, has asparagine and glucose, you can pretty much bet, if you get the
temperature to the right temperature, you're going to have acrylamide in that
food. You saw that one piece in one of
the slides, the Procter & Gamble people depleted all of the asparagine, or
most of the asparagine in the potato, fried it, and then didn't form acrylamide. So that--I think that's pretty good evidence
there that asparagine is the key amino acid in acrylamide formation, at least
in the potato, and in grain probably as well.
DR.
ACHOLONU: Would you assume that there
are other ways that we don't know at this present time?
DR.
JACKSON: There could--yeah, there very
well could be. There very well could
be.
DR.
BUSTA: If you notice, there's an
asterisk that says the Chairman has the "perogative" of calling a
break.
DR.
LEE: PRE-rogative.
DR.
BUSTA: Whatever. I would just like to make one
comment--again, taking my opportunity--and reiterate what Dr. Gray said
earlier. We've just been discussing
about getting rid of the acrylamide, controlling acrylamide, it being there, et
cetera, and we're really not sure that it's a problem yet. I mean, we really don't know if it's a
problem in food. And I think--I have to
keep reminding myself of that. We're so
enthusiastic to reduce it, measure it, check it, get rid of it, and even talk
zero levels and we have no idea if it's a problem.
Now, if
none of you wish to attack me on that statement, we will take a 15-minute
break.
DR.
FISCHER: I do want to ask you whether
you're saying that we shouldn't do any research on formation until we know
there's a problem.
DR.
BUSTA: No, no. I just--I think we should not declare it a
problem--
DR.
LEE: Not a human health hazard, right.
DR.
BUSTA: --a human health hazard until
we've got a little better information.
DR.
LEE: It is a problem, it's just not--
DR.
FISCHER: It is a hazard, I think. The definition of a hazard is it's something
that causes a--that has a potential for harm.
DR.
LEE: Right.
DR.
FISCHER: And this is a hazard. It may not be a--
DR.
BUSTA: May not be a risk?
DR.
FISCHER: Yeah, may not be a risk, but
it's a potential.
DR. LEE: Okay.
DR.
BUSTA: With that, we need a break.
[Recess.]
DR.
BUSTA: If there's no more comment about
formation--
DR.
FULLER: One.
DR.
BUSTA: Okay, we've got a comment on
formation here.
DR.
FULLER: Thank you. I just want to sort of go back to a point we
were talking as we ended just a minute ago, about message and the point that
Dr. Gray brought up about issues concerning--perhaps the group looking at the
message that we want to say or comment back to FDA on, and that was getting to
the point on reducing the amount of acrylamide prior to clear knowledge of a
risk or a significant hazard, significant risk.
And I
think, personally, I did not--I don't think you were, Dr. Gray--and correct
me--I don't think you were saying to ignore this as a potential risk, but just
to, in that message, clarify; or at least I would suggest that the committee
just clarify that the significance of a risk is unknown at this point, not--and
there is some concern about stressing too greatly reducing a risk with an assumption
that--or reducing, excuse me, reducing exposure based on an assumption that
there is significant risk when, indeed, we A) don't know that there is a
significant risk. There is certainly
calculable or theoretical--there's potential for it. I'm not saying this very well.
But I
think we want to--does the committee want to address that issue and more
clearly--or clarify that issue?
I'm
getting a bunch of blanks.
DR.
FISCHER: Well, I think you're talking
about the last bullet here, Information--develop/foster public-private
partnership, gather scientific information for assessing a human-- No, you're not. Excuse me. Educate Consumers.
DR.
BUSTA: The second-to-last one.
DR.
FISCHER: Yeah, second-to-last one.
DR.
FULLER: Yeah, it came up at the end of
our discussion just a moment ago. And I
don't think--I think we need to be careful, and maybe we should just hold this
off till that bullet, but I just think we need to be careful about the message
that we send to the consumer. And we
can address it at that point, if that would be more appropriate. I'll leave it to our Chair to--
DR.
BUSTA: Well, we'll be there shortly.
DR.
FULLER: Okay. We'll do it then.
DR.
BUSTA: It's my thought that some of you
may get antsy before 3 o'clock. So if we
can sort of look at moving reasonably fast and maybe even having a relatively
short lunch and come back, if that's all right with you. If it's all right with you, we'll get back
to the education component, as I see it, on the next page. If there's no other urgency on formation, or
discussion--and we're all going to be talking about this one more time, when we
make our statements.
Methodologies
is basically the next item. Is there
any comment about methods, current methods, evaluating the screening? Any discussion or need for clarification?
DR.
FISCHER: Well, I can say we discussed a
little bit, maybe it was at dinner, about how difficult it might be--and I
think it was mentioned here this morning--how difficult it might be to develop
an immunoassay-based screening effort.
DR.
BUSTA: Yeah, that was mentioned this
morning.
DR.
FISCHER: It would be great to be able
to do that because it would be so fast and so on. But I'm wondering whether we really know we have the information
to eliminate that possibility altogether.
For example, you can use an assay based on antibodies or you can use an
assay based on a receptor for acrylamide in cells. I don't know whether we know whether there is a receptor that's
involved for causing neurotoxicity or whatever else, but if you had the
receptor, then you could base an assay on that receptor.
We don't
know whether acrylamide is actively transported across membranes, or at least I
haven't read of that. I may have missed
it. But if it's actively transported, there's
another receptor and possibility for a specific binding for an assay.
So I
guess what I'm saying is that I wouldn't throw away the possibility of going
the routes of that type of an assay.
It's worth investigating to see whether it's possible.
DR.
BUSTA: It's my understanding that FDA
will be evaluating screening methodologies, not necessarily developing
them. Is that correct? Are you developing rapid, quick, and fast,
easy methods?
DR.
TROXELL: One of our groups is at this
point looking into an LCUV method. And
if the committee thinks that we should looking into other quick assays such
as--see if there's a possibility for immunoassay or something, then we would
carry that advice back and see, you know, if we should look into that further.
DR.
BUSTA: Dr. Hotchkiss?
DR.
HOTCHKISS: In the past history of these
kinds of contaminants, the agency and others have, I think, very logically
developed two levels, if you will, of analysis. One is a screening or presumptive analysis; the other is a confirmatory
analysis typically used more in a regulatory sense. The agency, I think, has to date developed a first-rate
confirmatory analysis for which I think there will be no argument with other
than the cost.
My
reading of the literature, however, is that there already is a what appears to
be a relatively quick and nice screening method based on bromination and
electron capture or gas chromatography.
And I suppose I've, given what I read, urged the agency to round-robin,
maybe through AOAC, that procedure because EC detection, because of the
pesticide issues in food, is very widely available, routinely done by hundreds
and hundreds of labs around the world and thousands of samples per day. It seems to me that this method would give a
very quick screening method that could be in place in probably a matter of
weeks if people really wanted to do it.
DR.
BUSTA: Any other comments on
methods? Let's move forward, then, to
Meetings and Collaborative Projects in the draft Action Plan. There are a number of bullets on here. Are there any comments on that area? That's on page 4 and 5 of the draft Action
Plan, under tab 5.
DR.
DOWNER: I'd just like to see we include
the nutrition professional and academic groups included in this, and home
economics groups, particularly for the consumer's interest.
DR.
BUSTA: Okay. I would think when you include academics, you'd include, for
example, the extension service that, hopefully, still has a connection with the
consumer.
Any other
comments on the meetings, public meetings, subcommittee meetings of this
committee?
DR.
HOTCHKISS: Just to congratulate FDA,
who, as these issues have unfolded in the past, has not always been so
cognizant of the importance of bringing a variety of stake-holders into the
picture. This seems to be a very good
trend, very good move.
DR.
BUSTA: Well, let's move on to Consumer
Messages. And we had a presentation by
Dr. Acheson. And we have these consumer
messages that we're--Dr. Downer and then Dr. Fuller.
DR.
DOWNER: My major concern with the
consumer message as it's outlined, and particularly in our presentation
yesterday, was it gave the impression that eating a balanced diet may have a
protective factor against acrylamide.
And we don't know this. Because
he kept saying eat a balanced diet, one with fruits and vegetables. And so what I quickly got from it was if I'm
eating a balanced--whatever "balanced" is--I'd really put it as the
term "healthful," healthful diet.
We need to make that clear, because it's quite confounding.
As I said
before, it appears to me that if we're eating a balanced or healthful diet that
it gives a person--that's a protective factor against acrylamide or what may
come with it. If we're going to put
this and couch this in a message for the consumer, I hope that it will be
clear, with something--for example, saying "In addition to eating a
healthful diet and handling food safely," make sure that you do
so-and-so. I don't want to see one
message replacing the other or causing additional confusion.
DR. BUSTA: Dr. Fuller.
DR.
FULLER: Let me come back to that. I want to compose my thoughts a little bit
more coherently, particularly in light of that comment. So let me come back to that in just a
minute. I think Dr. Gray is interested
in a comment.
DR.
GRAY: Well, actually my comment is
slightly different, but it's sort of a communication idea that goes to Dr.
Downer's comment as well. I wonder if
we could, or whether FDA could, using its exposure-assessment models and such,
compare sort of a total-diet survey, what-do-people-really-eat diet to a
food-pyramid healthful diet, in terms of acrylamide content, just as another
way to show people that if you follow this advice that says eat a balanced,
healthful diet with a variety of foods, in addition to all the other good
things it does, your acrylamide exposure will be lower as well.
DR.
DOWNER: May I respond? The problem with that is we recommend that
you eat six to 11 servings from the breads and cereal group. That's the big group. And that's the group where acrylamide is
most contained in meal preparation. So
again, you see how the message has--
DR.
GRAY: Well, it may well be that I'm
wrong that doing that would make a difference.
But it also--part of it is which choices are made even within those
groups. And I'm sure that the American
Dietetic Association or someone like that has particular recommendations within
those groups that may be different than what people are actually doing.
DR.
DOWNER: Well, the government
actually--the FDA and USDA, they're the ones who put out the food guide
pyramid. And I think my--it's not the
food so much alone, but how it's prepared, is what we're hearing now. And so that--the message will be meal
preparation rather than the food guide pyramid. I think if we put the food guide pyramid and put it in place with
the acrylamide message, we may end up having a hornet's nest. So that's--we have to be careful as well.
DR.
BUSTA: Dr. Lee?
DR.
LEE: This is kind of a segue from the
prior discussion of meetings. You know,
every time you call a meeting or have some kind of action, the media
watches. So each one of these meetings
represents some opportunity to communicate to the consumer. The release of the information on the
website triggered something on the CBS News this morning about acrylamide,
which--unfortunately "eat a balanced diet" is not news. We know that. If it bleeds, it leads, okay.
Usually news is negative, it's bad.
So the news, of course, is, "Oh, my God, did you know this stuff
was in baby food" or whatever. So
I don't know if there's a conscious effort on anybody's part to work with media
or to control the net impression that people get from all this news on
acrylamide.
But I'm
kind of uncomfortable going forward to the consumer with a message when we sit
here and say, look, we really don't even know if this stuff is a human risk, we
don't know how to control it, there's a lot of unknowns. So, yes, one should always be cognizant of
the consumer message, but I just don't know what that message needs to be at
this point.
DR.
BUSTA: Dr. Fuller.
DR.
FULLER: Well, that does help. And I guess I--my personal feeling is that
the message does need to be couched carefully.
We have information this is a rodent carcinogen, we don't know perhaps
the significance of the rodent data to human exposure and human risk. But we also can't say that there is
not--that we can go la-di-da along our merry way and forget it.
I do have
more confidence, perhaps, than some in a carefully crafted message to the public
that says very clearly here's what we do know, here's what we don't know, here
are the areas of uncertainty. And yes,
I realize that this is a complicated message, but I disagree that your message
always has to be a sound bite. And I
think you can carefully craft that message and give information to the
consumer, or at least information that will point the consumer to where they
can get good, reliable information in a form they can understand, and point to,
okay, yeah, there's something here; no, I don't need to give up potatoes from
my diet, but perhaps I should consider not having as--maybe I should not go
with the french fries every day for lunch, but perhaps I should go with
something different--potato salad rather than french fries.
So I
think we can carefully craft that message, and I actually think FDA is doing a
pretty good job in that thus far. I
don't think they have given the message that says stop, halt, you've got
something in the diet that is of immense risk.
They are saying that we are looking at ways to reduce this
exposure. The only part that I haven't
heard is--perhaps that I might emphasize a little bit stronger--is the
uncertainty of the information to date.
But I don't find tremendous fault with the message thus far.
DR. BUSTA: Dr. Hotchkiss.
DR.
HOTCHKISS: Yes, I have a question for
Dr. Acheson or whoever may know about this.
Has the agency put together any communications, for example with the
consumer safety officers in the regional offices, or is there anything to be
done in the FDA Consumer or other agency-controlled public vehicles for
providing information on this topic?
DR.
ACHESON: What we're currently doing is
developing a talk paper to try to address some of those issues to get that
message out.
DR.
HOTCHKISS: Let me tell you the reason I
ask that question. I presume all of you
have seen this morning's USDA--Freudian slip--USA Today. You haven't seen it? There's a relatively significant article
that names brands and products and so forth based on yesterday's discussion in
this meeting--quotes agency officials by name and so forth in this morning's
paper. What that does, as you all well
know, is leaves the agency in a position of responding, of reacting to the
media and others. And if you read that
article, as we did this morning, I think you'll find it not to be a very good
representation of what went on in this room yesterday--at least in my view it
wasn't.
We in New
York State have a very efficient system of getting consumer responses back
through our county agents. And I know
what's going to happen when I get back--assuming I do sometime in the
future. When I do get back, we are
going to have--we have a system for every consumer inquiry to a county
cooperative extension agent gets back to the university, and very
specific. I know, based on what's in
that article, we will have a series of them, questions, for which we'll quickly
put something together and put it back.
The problem with that is that this puts us, and more importantly the
agency, on the defense, rather than being proactive to say this is what we
know, this is what we don't know, the kinds of things you're going to do in
putting it out.
I think
the major consumer concern as we get these back through the county agencies is
not specifically Frito Lay potato chips versus other things--it is when they
read it in the paper--but what they really want to know is, is anybody at home
on the issue, what are they doing about it, what is the game plan, are they
looking at this, what do we know, what do we don't know? They're interested just in knowing that
somebody's there taking care of us and trying to straighten it out. And that means that then the press response
to FDA or other authorities rather than FDA responding reactively.
DR.
BUSTA: Dr. Troxell.
DR.
TROXELL: Thank you, Terry. The talk points have gone to a public
affairs officers, so when they see the questions they'll be able to address
them. And secondly, there is an article
in draft for the FDA Consumer, so there'll be something in that venue also.
DR.
BUSTA: You said what kind of paper is
being prepared?
DR.
TROXELL: There's a talk paper to give
the public affairs specialists a basis to field questions on this issue and the
survey. That has gone out. And there's also an article that is, you
know, close to final that is going to be published our FDA Consumer in the next
month or two on acrylamide and the actions we're taking, that we're addressing
the research needs, and also will have the consumer message in.
DR.
HOTCHKISS: Will that talk paper go out
to the regional consumer affairs officers?
DR.
TROXELL: Yes--our public affairs
officers is what they're called now.
DR.
BUSTA: Dr. Acholonu.
DR.
ACHOLONU: I just want to amplify what
Dr. Fuller said. I remember the last
person I spoke to yesterday, Mr. Stier.
He took time to emphasize the fact that we must be careful about what we
put out to the public, that there has been no correlation so far between
acrylamide and human beings. I do know
that an ounce of prevention is better than a pound of cure. The FDA is doing the right thing to make the
public know about its concern about acrylamide. So every effort should be made to publicize this as widely as
possible, possibly by radio and TV and any other means.
But the
message must contain the fact very clearly that so far there is no connection
known between the effect of acrylamide on mice and rats and the effect of
acrylamide on human beings, that study is still going on, and maybe in the due
course of time we will find out if it is carcinogenic to man.
So that's
the point I wanted to make. As you put
out the information, the message to people, make it clear that it is still in
the realm of probability, of possibility, that it is not a foregone conclusion
that acrylamide is carcinogenic to man.
DR.
BUSTA: Dr. Lee.
DR.
LEE: I'd like to agree very much with
Dr. Hotchkiss in that the message that somebody's at home, somebody's watching
the issue, we're taking care of it, we're on top of it can very well be the
message here with acrylamide. Because I
think the agency's doing a great job of being very proactive in looking at this
from every possible angle.
And
therein also lies an opportunity. Joe
mentioned the county and the extension apparatus. Every state in the nation has extension capability, and I would
think that there's an opportunity here as a generic template to extend the
FDA's reach by interfacing effectively with land grant university campuses that
have extension.
DR.
BUSTA: Even if those are USDA. Dr. Kuzminski.
DR.
LEE: Agency rivalries aside.
DR.
KUZMINSKI: The tab 5 that we're looking
at, it's a draft Action Plan. And I
think personally that the agency has done a very good job of trying to manage
the scientific information from around the world and trying to funnel it
through vehicles that exist to make that information available. And because it's a draft action plan, it's a
plan in process, I guess. I think
number 7, as it reads--Consumer Messages as it now reads in our binders, to me
sounds a little weak, a little wishy-washy.
And it could be embellished by some of the comments that have been made
today in terms of more specifics of we're doing this talk paper, whatever they
want to call it, articles will be published in the FDA Consumer and other
documents.
Because
sometimes in reading this kind of material and listening to the amount of work
that's going on, maybe this was your point, Marion--I know we talked about it
yesterday--how much knowledge is enough knowledge before you come out with some
sort of proclamation or a position or a preliminary risk assessment? I know this is a difficult area for the
agency to deal with, a preliminary kind of basis, but in order to continue the
fine managerial leadership they shown on the scientific and technical basis, I
think that same kind of leadership should be exercised on the
consumer-communication basis.
DR.
FULLER: I'll add just one more comment,
and that is perhaps part of the message needs to be that the
message--acknowledge up front that the message is going to change as more
information comes in. And I think we
sometimes fail to say that up front.
It's always an underlying assumption, but having been through some shorter-term,
high-profile incidents in which the message was having to change on a fairly
short-term basis, my personal experience has just been if you are very up-front
with what you know, what you don't know, you can say "this is what we
think at this point in time, there are problems with what we think, here are
the problem areas, and this will change as these studies come in." And it may go "our concern may increase
or in fact may decrease, depending on the data that are generated." And you said it very well. Thank you.
DR.
BUSTA: All right. The only other item on the draft document
that we haven't discussed is Regulatory Options. Does somebody have some burning feeling on that? To me, that's policy and--
Oh, Kenny
pointed out, thank you, we went running quickly past Exposure. And we discussed that and it's not highly
identified as a heading. Are there any
points or discussion on exposure that you wish to talk about before we go into
the questions? We've been alluding to
exposure a lot, as I see many of these comments on education, et cetera. And earlier, I think, Dr. Gray--well, a
number of the individuals have commented on real-diet intakes and things of
that type on exposure. Are there any
other discussions on exposure, or questions about exposure?
DR.
LEE: Where is Exposure in this outline?
DR.
BUSTA: It's in--some in Toxicology and
in Testing, Total Diet Study, and--
DR.
FISCHER: There's a section called
Testing of Food.
DR.
BUSTA: In Testing. Under Testing of Food, under Actions,
there's Total Diet Study in that.
DR.
HOTCHKISS: Dr. Busta?
DR.
BUSTA: Yes.
DR.
HOTCHKISS: Yesterday, during
the--before I got here, then yesterday during the presentations, I thought,
well, gee, maybe Exposure should be taken out as a major goal, as a section
unto itself. But I think that's really
in some ways redundant, they're not going to do all these other things unless
they do exposure; really is a matter of choice of how you want to emphasize
it. Obviously--at least, I think, to
virtually everybody in this room--it's obvious that exposure is a key element
here. If you want to make it obvious to
those who it might not otherwise be obvious, then you could put it out. But it is under Major Goals. It is the first bullet under Major Goals,
and so--and when the analytical discussion occurred yesterday, I think right at
the front it was said that the reason for doing this analytical work is so that
we can accurately assess exposure. So
certainly this has not escaped the notice of the agency that this is primary. On the other hand, if this is a public
document and someone were going to make it more obvious, you could put a bullet
or a number in here to bring out exposure.
The
technical issues, in my view, around exposure are not analytical. As I said yesterday, FDA is a first-rate
organization in that. The technical
issue is connecting the analytical data with best available consumption data,
which FDA is also first-rate on doing, and I'm sure they were doing--it's just
not very obvious in the document. And
that's why this morning I recommended using--some mention of using the best
available database should be put into the document.
DR.
BUSTA: Dr. Lee?
DR.
LEE: I don't know where to put this, so
I mention it under Exposure. I still
don't know for sure whether or not you have de novo synthesis of acrylamide or
have some in vivo formation of it.
There's really no human population that I know that does not eat cooked
foods, so the only populations I can think of that don't eat cooked foods are
wild animals and--it was just mentioned casually that acrylamide's been detected
in those creatures. So there are some
things that I have yet to understand about exposure.
DR.
BUSTA: Other comments? Is the subcommittee ready to start
addressing questions?
DR.
HOTCHKISS: I am.
DR.
BUSTA: All right, I'll start off with
Question No. 1. You have that in your
Charge and Questions.
Given
what we know about acrylamide's toxicology, occurrence, formation, exposure,
and risk, are the following research steps appropriate to describe and address
the public health significance of acrylamide in food? There are three items below that. Number one, the following sequence of a current study --
variability, exposure evaluation, concurrent with formation studies and
concurrent with toxicity studies. Are
those appropriate to describe and address the public health significance of
acrylamide in food?
I thought
we would rotate around the room, unless someone has a burning desire to be
first. Is Dr. Downer ready to respond?
DR.
DOWNER: Are the research steps
appropriate? I think that they are. I think the preliminary steps are fine, but
that more research is needed on information regarding absorption, metabolism,
distribution, and excretion of acrylamide in humans so that we can estimate the
risk, relay the risk to humans that can be made.
DR.
BUSTA: Okay. Dr. Hotchkiss.
DR.
HOTCHKISS: In general, the research
steps and plan put forth by FDA, in my view, are quite appropriate, logical,
and will serve the public interest of public health. My only caveat or disagreement is that I don't see the benefit of
the long-term cancer bioassay surveys per southeast. I do see a considerable need for much of the pharmaco- and
toxicokinetic work, much of the biomarker work, the germ cell genotoxicity, all
of those kinds of things, but I don't believe that the long-term
carcinogenicity assay is required to gather information from those.
Other
than that one part of that, I think that FDA has, as I said before, put forth a
comprehensive and logical plan. I think
that, and I think it will be addressed in our Question 3, I think priority of
work is important in this, and I want to reserve comment for that.
DR.
ACHOLONU: It is my opinion that FDA has
done well so far. But we're expecting
more in the future. Thank you.
DR.
GRAY: Well, I'd like to echo the others
who say that this is a very well thought out action plan and I think that it
covers, at this point, all the bases for developing--most of the bases for
developing information to describe the risks.
The one thing I don't see here, and it may be implicit, is discussion of
the tools and the approaches and potential research that needs to be done for
methods of using this information to describe the risk. And here I'm thinking particularly about
evaluating particular risk assessment approaches that can be used in this
setting.
And the
one other thing I would suggest that isn't here that may be appropriate, and
this has to do with both resource and timing considerations that I'm not very
good at estimating, is a question of whether further epidemiologic work would
be helpful. It's not currently in the
plan, and given that a large part of our concern is the potential relevance of
the animal data to humans, more data on humans may help to resolve that.
DR.
BUSTA: Dr. Kuzminski is not a voting
member, but you can make a comment if you wish.
DR.
KUZMINSKI: Oh, thank you. I think the elements that are contained in
bullet one are--it's a good plan. We've
heard discussion. I think there are a
couple of things that could be in different order in the written material here,
like validation of method ahead of survey, but we've heard discussion that that
indeed was the priority. Somewhere in
there, the need for work on and use of risk assessment as knowledge is generated
needs to be included.
I guess
my other comments will be addressed by bullets two and three.
DR.
BUSTA: Dr. Whitaker.
DR.
WHITAKER: I do think that the steps as
outlined here are appropriate. I think
it shows FDA spent a lot of time thinking through the process, and the steps
seem to be logical.
I think
that there's not much said in Question 1 about priority, but I assume that,
from what we've said here yesterday and today, that those priorities are
probably understood, such as analytical validation should be done before
anything else.
And this
is a lot of research. And I don't know
that FDA necessarily will do it all itself, and it should try to make use of
industry and academics to attack these goals in terms of a research process.
DR.
BUSTA: Dr. Fischer.
DR.
FISCHER: I agree with everyone
regarding the completeness and applicability of the plan to what needs to be
done to understand acrylamide's potential role in causing harm from the food
supply. I think it's a well thought
out, good plan.
I agree
with Dr. Gray that what it lacks is specific statements of intended research,
or research needs in humans. I think in
the end we always like to see the human data.
We've already, I think, talked about the inadequacy of the present data
in that these were worker studies, in the main. And I would say, from what I can see in my experience, that
worker studies are never looked upon as being sufficient when you're looking at
a low-dose situation like we're looking at now, particularly with food being
the matrix in which exposure occurs.
So
there's a--any chance to increase the information in humans, I think, ought to
be taken. That includes toxicokinetic
studies as well as some way to get some epidemiological information. It seems to me we've kind of ruled out the
possibility of doing any epidemiology, either on exposure or exposure and
outcomes. And maybe there is a way to
do it. Maybe somebody's got a creative
way of getting a population that we could look at who is more highly exposed
than other populations.
So I
would agree that we need to consider more information in humans.
DR.
BUSTA: Dr. Fuller.
DR.
FULLER: Like everyone else, I applaud
the efforts and the plan, I think, is also very carefully thought out. I have some ambivalent feelings, like Dr.
Hotchkiss, on long-term studies. I do
think, though, that they're--I don't know that it would be--that I would agree
or suggest that they should not be done.
I think there is potential there for those to be further enlightening,
although how much more so and how much bang for that buck, I'm not as certain
there. But I don't know that my
uncertainty is such that I'd say don't do it.
Otherwise,
I think--the points that have been made I won't reiterate, and I just think
it's a pretty thorough plan.
DR.
BUSTA: Dr. Lee.
DR. LEE: Being near the end risks redundancy, but
I'll leave the ultimate redundancy to our chairman, Frank Busta.
Yes, the
steps are appropriate and are in the interests of the public good, and I agree
with prior comments. The occurrence
survey requires good cooperation now underway both with international
organizations and the food industry.
But more importantly, to understand the mechanism and means to minimize
the chemical, the cooperation of the total research community is needed.
In
particular, understanding process variables will require active participation
by industry in a way that does not disclose proprietary information or single
out a particular brand or product as a target.
The JIFSAN Infonet appears to be a good start, but there needs to be
some active management of that.
DR.
BUSTA: Ken always has described me very
well--the ultimate redundancy.
DR.
LEE: Put that on record, will you?
DR.
BUSTA: Put that on record.
I am
impressed by the unanimity of the entire committee, in that there is extensive
support, strong support for the research steps. I think the concurrent activities, of three activities going on
at the same time, are very appropriate and a very logical approach to the
research needs.
I believe
that the role of food in not only the formation of acrylamide but its
occurrence and the toxicity are all valid and important research
activities. So that I know we talk
about model systems, and I know we look at mechanistic approaches and we measure
the occurrence of acrylamide, but I think there's a need to factor in the
specific food matrix systems and the processing in those considerations and try
and link them across all three of the areas.
Because there may be a dramatic variation between what we've seen so far
in other products and maybe the food matrices will give us an answer to that.
I concur
with all the individuals who've commented about the cooperative research
activities, and would like to emphasize that the academic opportunities are
here as well. Unfortunately, frequently
academic research is terribly slow, especially with graduate students. It takes time. And the information is not terribly readily available until
they've concluded their effort. But I
think there are opportunities, at least in the long run, for academic
participation in some of the fundamental work here, as well as industry and the
government agency.
I also
concur with the need for the human consideration all the way through, including
exposure and the kind of eating patterns.
I think that a 13-year-old young man eating a variety of different foods
is a consideration that may not fit in a lot of the other databases and needs
to be thought through. I think that it
relates to the home cooking activity and it relates to the toxicity problems,
at least in concentration.
And when
I look at the toxicity studies, I see the order of priority just the way
they're listed on the Charge. I think
mechanistic studies to support low-dose concentration is probably the most
pertinent because of that low-dose extrapolation, and then going down through
the rest; because the long-term cancer studies may not serve us as well, at
least for our immediate research needs.
Finally--and
two people have mentioned it, and I would like to say it again, as long as I'm
being totally redundant--the epidemiology seems to have more promise than I've
heard put forth here. It just seems to
me that we could find a population somewhere in this world that doesn't like or
eat browned foods--maybe a North Alaskan Inuit population or some population
somewhere that does not consume highly browned foods; and in some way try and
get a matched population to do the epidemiology to see if that--and that may be
based on a lot of markers that are still not proven as well. But it seems to me that that would address
some of the questions that Ken has mentioned about endogenous generation of
acrylamide, et cetera.
A long
and windy answer, but I had to, you know-- It's nearly 12 o'clock, so we can
take a break and come back for Questions 2 and 3. And we'll try and have a reasonably quick lunch and be back
between 12:30 and quarter to 1:00.
DR.
FISCHER: You don't want to finish
up? I mean, we're so close to
finishing.
DR.
BUSTA: Okay. Is that what I'm hearing, let's keep it on a roll?
DR.
HOTCHKISS: I would like to finish
because--I agree we are quite close and I think we could finish this up and
lunch will be about the same temperature.
DR.
BUSTA: It really is--from my
experience, it takes somewhere between two and four hours before you're really
up at the hazard realm. Unless it's
been there since 10 o'clock.
DR.
LEE: So it's not just temperature, it's
time too.
DR.
BUSTA: All right. If that's the--
DR.
HOTCHKISS: Go for it.
DR.
BUSTA: Now I will do a reverse and
start with Dr. Lee on the second question.
Are there
gaps in the research plan or areas where emphasis should be increased?
DR.
LEE: You fooled me by doing that.
Are there
gaps in the research plan? I think
toxicity studies should take full advantage of any information developed by the
acrylamide and related manufacturing industries, because industry cooperation,
again, is needed to solve this problem if the problem truly is significant.
The best
interests of consumers is preempted, perhaps, by legal actions, and the means
to minimize this hazard will dissipate if data is sequestered by the courts and
made unavailable by industries who seek self-protection.
There is
questionable value in posting incomplete data sets and brand names on the World
Wide Web, as was recently done.
And to
the extent positions, a system for free and unencumbered exchange of data must
exist. Industry data on acrylamide
contents of foods and process variables that favor or inhibit its formation are
critical parts to this puzzle. A blind
system that protects brand or process identify is essential, and this
represents a potential gap in the plan.
DR.
BUSTA: Dr. Fuller.
DR.
FULLER: I didn't see any overt
gaps. And I would just stress the
issues that we talked about a little earlier on the use of data in risk
assessment and communication. I won't
go into long, lengthy comment on that, but--because I think we've addressed it
previously.
DR.
BUSTA: Dr. Fischer.
DR.
FISCHER: As far as gaps goes, I think
we addressed--in my last comment, we addressed a gap, and that is a human
angle. And I think that's there.
The other
thing I think I don't see is--another way to get a better idea of whether the
human might be susceptible to a particular toxicity if you don't have any human
data is to have good information on species differences. And I don't think I see that stressed much
in the plan. So if we could have--if we
could find a reasonable species that is much less sensitive, for example, or
much more sensitive, it would give us a good idea of whether we can extrapolate
to the human. If all the species we
study look about the same, then we have a good idea that the human might be
susceptible. So a little more attention
to species differences might be helpful in the end.
DR.
BUSTA: Dr. Whitaker.
DR.
WHITAKER: I know we all have our own
ideas as to what is important and what is not so important, but I only listed
two things that I thought were--that I felt strongly about, and one is the
human studies, which has already been mentioned.
The other
has to do with variability. And I'm
talking about variability now at the bottom of the pyramid. We've heard about variability from food to
food and variability from brand to brand.
But I know that eventually somebody in FDA is going to want to know how
accurately and how precisely are we measuring acrylamide in a lot. So I would like FDA to also take it one step
lower in their thought processes, and that is to understand the variability
that's associated with sampling, sample preparation, and analysis.
DR.
BUSTA: Dr. Gray.
DR.
GRAY: The only comment I would make
here is that I do think that area that could benefit from some increased
emphasis here is simply the notion of communication, that we think very hard
about how to communicate with people over the entire period of execution of
this plan and into the future after that.
DR.
BUSTA: Dr. Acholonu.
DR.
ACHOLONU: I'm impressed with what has
been done so far. But I want to
reiterate what I said about connecting whatever they do with human beings. I want to say that rats, mice are
rodents. They don't come close to human
beings. I'd like to recommend to FDA to
consider carrying out some experiments with monkeys or apes, then eventually to
man. So that's my recommendation.
DR.
BUSTA: Dr. Hotchkiss.
DR.
HOTCHKISS: Yes, the question are there
gaps in the research plan? At least
explicitly, perhaps. Let me give you,
or in my view, some specifics. The
first recommendation I would have relates to the issue of human
epidemiology. This acrylamide is an
unusual substance in that, as I've said before, there is substantial
occupational exposure, and a number of epidemiological studies have been
conducted on that. The question is
whether or not those epidemiological studies are applicable to a different
route of exposure, a different level of exposure, which is probably
considerably lower but also over a very longer period of time. It seems to me those are important
questions. I would recommend to the
agency that they, either in-house or externally, contract a group to address
those specific issues around epidemiology and to advise them whether or not
they feel that the current epidemiology is applicable or not applicable and to
what degree.
The
second area is, I guess, implicit in the plan but not specifically mentioned or
addressed in terms of methodology, and that is really risk assessment. I think that that is the absolute key thing
here. We're dancing around this issue
because there is no credible risk assessment conducted, at least for this exposure. There is a--risk assessment has been
conducted by the agency itself on acrylamide as a migrant, but not in the
context of a food contaminant. And I
think if we had that risk assessment--of course, I understand there are lots of
things implied in that in terms of analytical methodology and the quality of
sampling and so forth. But still, it
seems to me that's a key piece of information, is what's the risk and how do we
compare that risk to other risks.
In the
toxicology studies, perhaps again implicit, but I think there are two issues
that seem to me to be fairly straightforward to address in the right toxicology
study, and that's germ cell toxicity and neurotoxicity.
Neurotoxicity
is typically most sensitive during fetal development, and there are a number of
protocols for assessing neurotoxicity in animal models during fetal
development. If you don't see toxicity
in that, it's unlikely you, at those doses, will see toxicity elsewhere. Those are the most sensitive systems. Those are relatively well established and
straightforward.
The other
is germ cell threshold, and it's again a similar kind of thing. Probably, or it's possible that there is a
threshold for germ cell toxicity, and again those protocols for those kinds of
assays are fairly well developed, again, in young animals during
maturation. There are certain stages of
the maturation process that the germ cells are very susceptible to toxicants.
Those
kinds of studies probably would put this issue to rest, again assuming it has
not already been put to rest because of the occupational exposures. But in general, it is those kind of specific
things that I think perhaps could be included in the draft plan.
DR.
BUSTA: Dr. Downer.
DR.
DOWNER: Thank you. I concur with my colleagues that we need
some information on human subjects.
However, I also think that biomarkers to include both short-term and
long-term exposure should be investigated further. Bioavailability of acrylamide, or its metabolite glyceride [ph],
from food needs to be looked at also.
And I'd also like us to look at the food consumption data and
compartmentalize it into not just what general Americans eat, but look at the
different ethnic groups, look at the different age group categories, and also
look at some of the socioeconomic data to get a better picture of what's going
on. Because we know that these
different groups have different health issues that go along with it, and I
suspect we may find some correlation there.
DR.
BUSTA: Dr. Kuzminski.
DR.
KUZMINSKI: Thank you, Frank. I think there are two gaps that are areas
where emphasis should be increased. One
is the use of risk assessment at an appropriate point in time--and there's big quotes
around that would "appropriate."
And I don't know the answer that, and I don't think a lot of people in
this room know the answer to that, but some decision needs to be made in terms
of managing this entire process both from a technical information-gathering
viewpoint and from a communication to consumer viewpoint. So that's one.
The other
gap and area where emphasis should be increased is on the role of data that
could be obtained not just from government agencies but external data,
industrial data, if you will. I must be
frank; I didn't hear much passion on either side of the coin, by either
industry or by the agency, in terms of talking about that's a source of data
that we're working on through JIFSAN. I
think it's a huge area that could be exploited, exploited to benefit in terms
of helping to solve the problem and helping to define further the problem and
then solve it, if there indeed is one.
DR.
BUSTA: Joe?
DR.
HOTCHKISS: I just wanted to make a
comment about the epidemiology that perhaps not everyone is aware of. But the epidemiology around fried foods
would be extraordinarily difficult if not impossible to do for a variety of
reasons, one of which is that the general conditions, at least as we know it
now, in which acrylamide is formed in foods happens to be exactly the same
conditions that a whole variety of other, I think on an equal basis, more toxic
compounds--the heterocyclic amines and a whole variety of those kinds of
compounds--are formed. So if you
compare a population that is a fried-potato eater against a non-fried-potato
eater, you're going to face the question of acrylamide versus heterocyclic
amine versus a variety of other issues as well. So recommending to the agency to do something like a fried-food
epidemiology is rather a difficult if not impossible task.
DR.
BUSTA: I think that was aimed at me.
DR.
FULLER: Perhaps.
DR.
BUSTA: Just confirming the difficulty.
I won't
be as redundant this time as I was last time, or at least go on as long. I concur.
I haven't heard any of these comments that I disagree with. The gaps that were identified, I think, are
significant and important--by the other members of the committee. I feel that the emphasis that was stated
earlier in just running what I said, where I thought mechanistic studies could
be emphasized initially and that exposure information and the role of food, I
think, are indications of my opinion of where emphasis can be increase, or at
least placed.
Any other
gaps stirring anyone else? All right.
Number
3. Now, I started this way--I'm trying
to spread this around. Number 3, I'll
start: Priority research needs that
should be addressed first.
I'll just
be redundant on what I just said, and that is that I think we need to look at
the--on Consumption, I think we need to look at exposure levels with the
emphasis, in addition to analyzing some of the foods. And I have heard of the design of these food studies, and the
combination of information from around the world, as being significant in
achieving the first of the concurrent research activities that are stated here.
I think
that the role of food, again, is very important both in toxicity studies and in
formation and control studies. And
that's why I think the emphasis should be placed first.
Let's
start with Dr. Kuzminski. We'll come up
this way.
DR.
KUZMINSKI: Thank you, Frank. I must defer to the toxicologists in terms
of the time that it takes, just in the time that it takes to come up with the
research answers to some of these topics that are proposed. My sense is that it takes a longer time than
it takes to do some of the others, just based on some very limited experience
in some toxicity tests that I have been involved in.
So I
think the methodology, the occurrence, and the formation and the exposure
mechanisms, that mix of investigative pathways as outlined in their sequence
here is taking priority, has taken priority over the last several months and
should be maintained. But the others
should be clicking in pretty promptly.
DR.
BUSTA: Dr. Whitaker.
DR.
WHITAKER: I wasn't sure how to address
this question, because in my way of thinking FDA has already started the
process as they should have; and to be commended for that, not to wait on us.
If I laid
out the priorities, and I look at what FDA has done or has started to do
already, I would agree with it. I think
the first thing you have to do is make sure the analytical method is giving you
correct answers, and they've done that and they should continue. And I would have gone into occurrence,
exposure, and risk. And I think
that--at least what I've gotten out of this--is the way they have gone, along
with some other areas also.
So I
think, based upon the way they have started and what way I would look at it,
that they're on a turn.
DR.
BUSTA: Dr. Fischer.
DR.
FISCHER: Well, I find this a difficult
one as well. Certainly, exposure is an
important factor and should be among the first things done. It's already under way, so I don't have any
worry that we're not going to have exposure data probably first.
The
toxicity studies and mechanistic studies do take a longer time, and for that
reason I guess one way to look at it is why put them off? If in fact they're going to take a long
time, maybe you ought to get them started.
And I think that that's being done as well. So I agree to that.
I would
say, if I had--what I would start almost right away is thinking about risk
communication--not a research need, but maybe you could call it research. I'd start thinking about scenarios where
you're going to have to respond to the public's concern and crafting the kind
of response that you may need to make.
And maybe already some is needed.
So I wouldn't put off communicating with the public about this issue.
DR.
BUSTA: Dr. Fuller.
DR.
FULLER: I'll be honest; I don't think I
have anything meaningful to say, so I won't.
DR.
BUSTA: Dr. Lee?
DR.
LEE: I wish I had faculty like you.
DR.
BUSTA: You wish you had faculty.
DR.
LEE: Yeah, right.
Are there
priority research needs? I believe
there is no shortcut to determining if acrylamide is a significant health
hazard or a food compound that has negligible toxicological effects. Nonetheless, the FDA will be doing its job
by first placing its finite and often meager resources where consumer interests
are best served. This could include
rapid, inexpensive tests for the compound, means to reduce the total dietary
exposure, and an informed public that has science-based information on which to
make dietary choices.
It may be
useful to determine if acrylamide is a natural product, a man-made product, or
both. It would be helpful if research
could provide a basis for the answer to this question.
And in
the context of total food risk--that includes issues such as security, food
counterfeiting, diversion, food-borne pathogens or prions in chronic wasting
disease--acrylamide appears to be a lesser immediate threat to the human
condition and thus a lesser priority.
DR.
BUSTA: Dr. Gray.
DR.
GRAY: Thanks. Recognizing the timing difficulties involved with much of the
toxicological research, the main suggestion I would make in the way of
priorities is, to the greatest extent possible, moving along the toxicologic
data and the tox analysis and risk analysis in order to provide context for the
exposure information that we know is going to be coming soon, both in the forms
of specific foods with acrylamide contents and things like adduct levels in the
population.
So this
is just, as soon as we can, even as uncertain as it might be, to be able to
provide some context to these exposure levels that are going to be coming
first.
DR. BUSTA: Dr. Acholonu.
DR.
ACHOLONU: I think that FDA could spend
more time working on the kinds of food prepared. To what extent is the level of acrylamide found in fried food, in
broiled food, in baked food, and in roasted food? It may be good to do some work, and grade them. Find out where the level is found to be
highest.
The next
thing I feel we should go into is work on safe limits of acrylamide in
food. To what extent can you take in
acrylamide, to make sure that it is safe for health, that it will not be
carcinogenic?
Next, I
don't know if we addressed the issue of cumulative action. Can acrylamide, when it gets into you, be
metabolized and taken out or excreted; or does it accumulate? As you get exposed to it and as you eat,
does it keep on increasing to the level then causing cancer in a human
being? So we need to go into that
aspect.
And as
I've said before, priority. We are
making this study assuming that it can do something to man. So emphasis, anything we can do, any
research we carry out should bring us closer to confirming that it is
carcinogenic to man--not just say it is probable, it is assumed. Everything we have said so far, what has
been written so far has been speculative as far as human beings are
concerned. So any research, any work we
do should point towards confirming that acrylamide is carcinogenic to man. Thank you.
DR.
BUSTA: Dr. Hotchkiss.
DR.
HOTCHKISS: The question as framed is
are there priority research needs that should be addressed first? In my view, the answer to that is
emphatically yes. Is FDA doing
that? It seems by de facto, yes. As we see the FDA ongoing and planned work
in this area, it seems to be a logical sequence. Have FDA prioritized their work?
It seems certainly not. I've
seen nothing in here to really prioritize it.
They've done it in kind of a de facto way. My recommendation is that FDA say, yes, this is our priority,
this is the sequence of events we're going to unfold. There is a timing frame back in here that actually puts timing --
that implies priority but does not state so.
My own
priority would be a post haste risk assessment, and not necessarily waiting for
all data. You never get all data for
risk assessment. You'll refine your
risk assessment. And as a matter fact,
as I've painfully pointed out to the FDA, they've already conducted a risk
assessment for acrylamide and have published that risk assessment. With the available current data, they should
either conduct a subsequent risk assessment or say why that cannot be done,
because it really is the key element here, is risk.
If we
knew the risk assessment--and, of course, implied in "risk
assessment" is a lot of things.
Exposure, you can't do a risk assessment without exposure, and you can't
do exposure without all the analytical kinds of things and those things that
FDA is doing. But if we had our best
current guess on risk now, then that would certainly guide us better in the
future. So that would be my first
priority.
Along
with that, clearly the major risk is going to be carcinogenicity. It virtually always is. But along with that, the short-term,
oral-dose neurotoxicity and germ cell experiments, I think, should also be a
priority because that will either take those issues off of the table or bring
them to the forefront on the table, depending on how those specific outcomes
are seen. My guess is what's going to
happen is the tumorigenicity risk assessment--tumorigenicities at low dose is
going to be the primary thing--but until that works, then you don't know that--and
then a risk assessment.
Other
than that, I think, in a practical sense, FDA is prioritizing these things in a
de facto sense very well.
DR.
BUSTA: Dr. Downer.
DR.
DOWNER: I think the FDA has already
started on the priorities, and my recommendation that I'm going to make is
simply adjunctive rather than a priority.
I think one of the things to look for would be whether or not
acrylamide, at the levels found in food, is of any toxicological significance. I would also want to look to see, if we make
changes or recommendations with regard to food preparation, what are some of
the tradeoffs to ensure microbial safety and definitely to maintain
organoleptic properties.
DR.
BUSTA: There's time for a last
statement if any of you feel that you have anything further to add to the
record. Dr. Downer.
DR.
DOWNER: I just want to thank you all
for the opportunity to be on this committee and for the white papers and the
presentations that were made. I
certainly came here, after reading the documents, with one perception, and was
able to be swayed and educated further to make some of the decisions I made
today. So thank you.
DR.
BUSTA: Dr. Lee.
DR.
LEE: Well, I don't want to roll
credits, but I want to thank Dr. Henry Kim for being very comprehensive in
preparing everyone for this meeting, and his e-mails were very helpful.
DR.
BUSTA: Dr. Kuzminski.
DR.
KUZMINSKI: I would just like to thank
our Chair for the job he's done.
DR.
DOWNER: Ditto.
DR.
KUZMINSKI: You've done a good job.
DR.
LEE: I appreciate the Chair for his
redundancy.
DR.
BUSTA: I think this has been a very
excellent experience. The committee is
so compatible, they took over my last statement. I'd like to, of course, thank FDA for all their efforts and Henry
for sitting here watching me closely to make sure that I really don't get
myself into trouble. And this entire
subcommittee, I think we've had a good day and a half. And I think we'll have another opportunity
to experience some of this again when we have the full committee.
Thank
you, and for those of you that can make it home tonight, good luck.
DR.
DOWNER: You'll have to come to my
house.
DR.
BUSTA: Those of you that can't, good
luck. Terry?
DR.
TROXELL: I'd like to have the last
word.
DR.
BUSTA: You're on.
DR.
TROXELL: I want to thank the committee,
for the FDA, for CFSAN, for myself, for the tremendous amount of work you have
done and the advice you have given us; for braving the weather, braving the
trip home. We wish you a safe and
speedy trip home, and hope the folks heading to Florida can get to the
sunshine.
Thank you
again, everyone.
[Whereupon,
at 12:23 p.m., the meeting was concluded.]
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