els due to its ubiquitous presence in the
environment rather than to any avoidable contamination of food.
“FDA undertook additional efforts to ban or
restrict uses of lead in association with food…”
Isolated Exposures
While efforts to reduce dietary lead
exposure for the general population have
been largely successful, some individual
consumers or groups of consumers—
often recent immigrants and their families who use poor-quality products from
abroad—may occasionally encounter
foods containing significantly elevated
lead levels. Most such incidents are isolated in that they involve products personally brought into the U.S. or
products imported in limited quantities.
In 1994, FDA began to encounter
candy products from Mexico packaged
in wrappers containing lead-based printing inks. Most of these wrappers were
designed so the ink was either on the
outer surface of the wrapper or between
layers of laminated plastic and thus,
could not leach into the actual candy.
Unfortunately, a few of the wrappers
were poorly designed or had defects in
their materials that allowed significant
amounts of lead to migrate into the
candy.
At the same time FDA was scrutinizing the wrappers, it began testing significant numbers of Mexican-style candy
products for the first time. Mexican-style
candy is unique compared to traditional
candy sold in the U.S. in that it frequently contains minimally processed
ingredients such as chili (the pod of any
species of capsicum) and tamarind, and
can contain salt as a primary ingredient.
FDA tests revealed that these Mexican-style candy products contained higher
levels of lead than did traditional sugar-based candy, regardless of whether or
not the wrapper contained lead-based
printing inks.
Although the exact source of the lead
had not been established, FDA officials
surmised that the elevated lead levels in
the candies might be due to their containing minimally processed ingredients.
Whereas the manufacturing process for a
highly refined ingredient like sugar essentially purifies the product, ingredients
that undergo only minimal processing
are more likely to retain low levels of
contaminants, such as soilborne or dust-bound lead, from their growing environments.
In 1995, FDA published a guidance
document in the form of a letter to manufacturers, importers, and distributors of
imported candy and candy wrappers.1
The letter discussed FDA’s findings related to lead-based printing inks on
candy wrappers and the issue of lead in
candy itself. In the letter, FDA urged
members of industry to refrain from the
use of lead-based printing inks in their
packaging materials and informed them
that FDA regarded candy wrappers that
