February 2, 2012
Department of Health and Human Services
Public Health Service
Food and Drug Administration
College Park, MD 20740
Nancy Chapman, RD, MPH
Apple Processors Association
1050 17th St. NW
Washington, DC 20036
Juice Products Association
750 National Press Building
529 14th St. NW
Washington, DC 20045
Dear Ms. Chapman and Ms. Freysinger:
I am writing to ask for assistance from the Apple Processors Association (APA) and the Juice Products Association (JPA) in obtaining data on arsenic in fruit juices from the juice industry. As you know, the Food and Drug Administration (FDA) is in the process of reconsidering its regulatory strategy on arsenic in fruit juices. There are several areas in which more data would be very useful to FDA. If your members have data on these matters we would be very grateful if they would provide FDA with their data, either individually or through the APA and JPA, as their data may have an impact on our regulatory strategy. The areas that concern us are:
- What levels of arsenic are manufacturers finding in apple, grape, and pear juice? We are interested in data on both total arsenic and on the arsenic species monomethylarsonic acid (MMA), dimethylarsinic acid (DMA), and inorganic arsenic.
- From our own sampling, we see a small percentage of apple juice samples with very significant amounts of MMA and DMA. Do you have any information on the sources of MMA and DMA in apple juice samples? In particular, is this related to current or prior use of arsenical pesticides, or have other potential causes been identified?
- What is the prevalence of total arsenic contamination in apples and apple juice by growing region? Globally, where is the apple juice with relatively high amounts of arsenic coming from?
- What steps, if any, do manufacturers take to control arsenic levels in water used to dilute juice concentrate? Do manufacturers measure arsenic levels in their water supply? Do they use any water treatment processes to remove arsenic from the water supply and, if so, at what level of arsenic would treatment be considered?
- What steps, if any, do manufacturers take to lower arsenic levels in juice or juice concentrate? Are there any treatment technologies available or in use to remove arsenic from juice?
- How much apple, pear, and grape juice is produced in the United States annually? How much is imported? How much apple, pear, and grape juice is sold for U.S. consumption? We are interested in separate production and consumption data for each of these juices.
- Do manufacturers have data on the age of consumers of apple, grape, and pear juice in the U.S.?
Thank you very much for your help in gathering these data from the juice industry. Please let me know if you have any questions about our request or if you have other suggestions for important issues to research. We believe that data from industry will be very helpful in identifying the most appropriate regulatory strategy for arsenic in fruit juices.
Nega Beru, Ph.D.
Office of Food Safety
Center for Food Safety and Applied Nutrition