When the Department of Health started discussing the acceptable daily intake (ADI) of the feed additive ractopamine being 1 microgram for each person, it was clear that it was heading in the wrong direction.
In 1996, the US Congress passed the Food Quality Protection Act (FQPA), signed by then-US president Bill Clinton. The act demanded that the US Food and Drug Administration and the Environmental Protection Agency (EPA) add an additional safety factor of 10 when assessing the acceptable residue levels of pesticide in foods to enhance protection of pregnant and post-natal women, as well as infants and children.
In other words, when considering potential ingestion of toxic chemicals that have highly uncertain toxicological data, like ractopamine, by more sensitive, weaker groups of people, setting a safety factor of 10 to 30 times the normal recommended amount must be made a priority.
This means that viewed in the light of the FQPA, setting the ADI of ractopamine at 1 microgram is not sufficient to protect infants and certain groups of women, or people with cardiovascular diseases — which is extremely worrying.
A few years ago, the WHO Joint Food and Agriculture Organization/WHO Expert Committee on Food Additives also considered setting the ADI of ractopamine at 0 to 1 microgram, but this was rejected straight away by the EU’s Panel on Additives and Products or Substances used in Animal Feed (FEEDAP) because it was deemed insufficient and did not take into account the responsibilities of such agencies toward protecting weaker and more susceptible groups.
Therefore, if we look at the matter based on the spirit of the FQPA, which states that the ADI for weaker groups should be set 10 to 30 times higher than the average, then the Department of Health should set the ADI at a level lower than 0.1 microgram before it starts thinking about relaxing the restrictions on US beef imports.
If things are done according to FEEDAP’s recommendations, the department should only start to consider easing the restrictions if the ADI is set at zero — basically then only allowing US beef that has not tested positive for the controversial residue.
I worked at the EPA in the US for many years and often had to examine and evaluate pesticide residue levels and ADI. These things often had to be done using the most conservative measures, and additional safety factors of 10 to 30 times the average were used to protect women and children. With this conservative and secure risk assessment in place, products had to pass rigorous pesticide tests before they were allowed onto the market.
Taiwan has already spent a lot of social resources on the issue of US beef containing ractopamine residues and has been accused by the US government and Congress of resorting to unscientific measures in handling the matter. The data and information the US government is using now makes one wonder if it has considered, or may even have breached, the tenets of the FQPA it passed in 1996.
There are two steps to solving this problem: The first step is to emulate the EU and only allow the import of organic US beef that does not contain any leanness-enhancing additives or hormones.
The second step is to copy the FQPA model by adding a clause to Article 11 of the Act Governing Food Sanitation (食品衛生管理法) specifying the protection of women and children and making an additional safety factor of 10 to 30 times the normal standard a legal requirement.