What are the applicable maximum levels in foodstuffs?

Residues in food and feed are legally regulated in Regulation (EC) 396/2005 of the European Parliament and of the Council of 23 February 2005. The maximum levels, i.e. the maximum residue levels, are set by the EU Commission.

In the European Union maximum levels were only set for primary products, which undergo further processing to produce various foodstuffs. The maximum HCB residue level for milk is 0.01 mg/kg, based on a fat content of 4 percent, while for meat it is 0.2 mg/kg and for eggs 0.02 mg/kg, for fruit and vegetables 0.01 mg/kg, cereal 0.01 mg/kg and for pumpkin seeds 0.05 mg/kg.

So there is only a maximum level set for milk, but no maximum levels set specifically for milk products like butter, curd etc. Thus the maximum level for milk of 0.01 mg/kg cannot be transferred 1:1 to butter, even if the level measured in butter is higher. So for butter, its fat content is used to calculate the level in the milk that was used to make the butter.

The various maximum limits for HCB result from HCB’s especially high solubility in fat: the higher the fat content, the higher the maximum limit value. When setting maximum levels, account is taken of the food quantities that a person on average eats, i.e. of those categories of food that are traditionally eaten in greater quantities. Particular consideration was given here to children as an especially sensitive population group. However, safety factors are always included - this means that the maximum content for a substance is set well below the level at which initial effects were observed in animal tests.

Regulation (EC) No 396/2005

Specific queries regarding maximum residue limits of hexachlorobenzene in food and feed can be made at the following database (keywords pesticides, hexachlorobenzene): ec.europa.eu/sanco_pesticides/public/

AGES has made a new assessment of the risk presented to the population of the Görtschitz Tal by HCB-contaminated foodstuffs. The first assessment was carried out in December 2014. The result of the initial evaluation was confirmed: there is no health risk to people who have eaten HCB-contaminated products for up to 14 days. For people who have eaten HCB-contaminated foodstuffs for a longer period, a risk is not to be expected, but cannot be ruled out. The Austrian Federal State of Carinthia has therefore commissioned experts in environmental medicine from the Medical University of Vienna to investigate the actual HCB contamination and possible health effects for the inhabitants of Görtschitz Tal. 

The current AGES risk assessment

For the current assessment the results were used from residue testing on 824 foodstuffs from the period 27 March 2014 to 20 March 2015. These primarily involved milk and milk products, meat and meat products, but also fruit, fruit juices, honey, vegetables and cereal produced in the Görtschitz Tal. Compared to the risk assessment of December 2014, there were twice as many test results available. It was therefore possible to make more precise calculations as to the quantities of HCB consumed by children, women and men in the Görtschitz Tal.

A worst case scenario was assumed: these calculations assume that people have had a diet consisting of products originating solely from the Görtschitz Valley region. Contaminated products have not been for sale since December 2014. Thus the calculated consumed quantities are higher than those that people in the Görtschitz Valley were actually exposed to.

The risk was calculated for persons who eat contaminated foodstuffs in average quantities (average consumers) as well as for persons who eat especially large quantities of food that due to their high fat content are most contaminated with HCB, such as milk, milk products and meat (high consumers).

Results

The average intake levels of HCB for children, women and men were compared to the currently most up-to-date health-related reference levels from 2013 (US Agency for Toxic Substances and Disease Registry, ATSDR). These tolerable or acceptable intake levels refer to the quantity of a substance that a person can consume every day with no expected adverse health effects.
For people who have eaten contaminated foodstuffs for up to 14 days there is no risk. The tolerable or acceptable intake level of 8 µg/kg body weight per day will not be exceeded either for high or for average consumption levels.

If contaminated foodstuffs are consumed for between 15 and 365 days, the tolerable intake level of 0.1 µg/kg body weight per day will be exceeded in children, women and men. These excessive levels equate to three times the tolerable daily intake in the case of average consumption levels and six times as much in the case of high consumption levels of milk and meat. Adverse health effects are not to be expected, but cannot be entirely ruled out.

If contaminated foodstuffs are consumed for longer than a year, the average intake of HCB is four times the tolerable intake of 0.07 µg/kg body weight per day and in the case of high consumption levels of milk and meat products eight times that amount. Adverse health effects are not to be expected, but cannot be entirely ruled out.

AGES’ role in the testing and monitoring of foodstuffs

The performance and organisation of monitoring in the field of foodstuffs is the remit of indirect federal administration. The supervisory authorities in each of the federal states (food supervisory authority (LMA), veterinary authority) operate under the responsibility of the State Governors.

If contraventions of statutory requirements relating to foodstuffs become evident due to farm inspections or expert assessments by AGES or by the monitoring agencies of the federal states of Vienna, Carinthia and Vorarlberg, the responsible state authorities must take appropriate measures to rectify these failings. Such measures could include restriction or prohibition of the marketing of goods, banning the use of premises or even the closure of a farm/business.

If products are deemed or found to be harmful to health, the responsible farm/business is to be informed immediately by the relevant supervisory authority. The farm must immediately prevent any further circulation of the product and take steps to remove it from the market (recall or withdrawal), inform its customers and warn the public, if the goods have already reached the end consumers. If the business operator does not fulfil his or her obligation, the appropriate authority has to seize the goods. (Source: Food Safety Report -Lebensmittelsicherheitsbericht)

AGES will inform the public on behalf of the Federal Ministry of Health about harmful goods, if a public health risk exists (Section 43, Para. 1 Austrian Food Safety and Consumer Protection Law - § 43 Abs. 1 LMSVG): “If, due to the findings and expert assessment of the agency or a federal state inspectorate or a risk assessment conducted by the agency on the basis of notification via the rapid warning system in accordance with Article 5 of Regulation (EC) No 178/2002 or from the RAPEX rapid warning system in accordance with Article 12 of Directive 2001/95/EC, reasonable suspicion exists that goods are harmful to health in accordance with Section 5 Para. 5 Line 1 and that a substantial group of the population is thereby at risk (public health risk), the Federal Minister for Health has to issue a public information notice. Any applicable measures already taken by the business operator are to be taken into account.”
Testing for HCB in foodstuffs in Austria
Foodstuffs are tested according to a sampling plan specified every year by the Federal Ministry of Health, which stipulates the scope of activity for the supervisory authorities in each federal state. These routine samples are taken all year round across the entire spectrum of products. The results of this sampling enable representative conclusions regarding food safety.

AGES routinely tests food and feedstuffs for the banned substance HCB. HCB levels relevant to food legislation were detected solely in pumpkin seeds and pumpkin seed oils in previous years.

If suspicion arises during monitoring that food legislation requirements have not been met, the authorities then take samples “on suspicion”. The aim here is to clarify how a foodstuff became contaminated in order to ultimately eliminate the cause.

Stockholm Convention: The "Dirty Dozen"
EU Pesticide Monitoring Report
Environment Agency Austria: Hexachlorobenzene
Environment Agency Austria: Contaminated Site Atlas
Information Page for HCB Görtschitz Valley
Assessment of Hazards and Risks along the Food Chain
Risk Management for Minimising HCB Contamination in Medicinal Pumpkin (only in German available)