not based on health impacts and is contrary to FDA’s Closer to Zero program since it
effectively removes the incentive for industry to do any better than the worst 5% of the
international marketplace.
In anticipation of the June meeting to consider the draft, the U.S. Delegation, led by
USDA and FDA, requested comments on the draft proposal from those who signed up
for notice. Unleaded Kids submitted comments on the draft proposal.
We repeated calls asking for the U.S. Delegation to push harder for tighter standards
and recommended MLs of 1,000 ppb. This would be the same level that New York
State has set for most spices. FDA has yet to set an action level but has recalled
cinnamon over 2,000 ppb.
Why it Matters
We explained in our comment that a woman who was a big fan of both cinnamon and
culinary herbs and relied on a brand with lead contamination at the draft MLs would
have blood lead levels of 28 µg/dL by age 30 based on EPA’s All Ages Lead
Model.1 This could happen without her knowledge since only baby food
companies are required to test their products for heavy metals and make the results
publicly available.
A blood lead level of 28 µg/dL is extraordinarily high according to CDC! The
Occupational Safety and Health Administration (OSHA) considers a blood lead level of