32-5

S. SAUNDERS, Frito-Lay, Inc., 7701 Legacy Drive, Plano, TX 75024-4099

Mycotoxins have become more visible as a concern for public health with consequent implications for global trade. Complicating the issue, often the toxicological databases for mycotoxins are relatively incomplete compared to other potential food toxicants such as pesticides. When faced with uncertainty the natural tendency of regulators is to drive allowable limits as low as possible. A current vogue among regulators, especially in the European Union, is to invoke the "Precautionary Principle" when gaps in the knowledge base or disputes of interpretation exist for potential toxicants. This metaphysical approach to regulation is difficult to deal with scientifically since it is rare that toxicologists universally agree on all aspects of any particular toxicant. In this situation, under reasoning supplied by the "Precautionary Principle", regulators can justify any limit (including outright prohibition) on the basis of unresolved questions regarding the potential hazard of a food-borne toxicant. This approach produces significant difficulty for world trade since mycotoxin residues vary widely from country to country. Further there are relatively few chemical treatments available to control mycotoxins in raw agricultural commodities, and in any case production of mycotoxins can be greatly influenced by weather. An example of the difficulties that can arise is found in the story of aflatoxin in the Codex Committee on Food Additives and Contaminants (CCFAC). The European Union has repeatedly pushed to lower the allowable limit of aflatoxin to 5 ppb, in spite of clear evidence from JECFA and others that lowering the limit from 20 ppb to 5 ppb would not provide a meaningful public health benefit. A lower limit would however have significant impact on world trade. Thus political considerations can often be as important as scientific facts in determining a national position on allowable limits of mycotoxins.