More on Melamine: The FDA Position vs. Philosophy

The FDA’s revised position on melamine, dated November 28,2008, deserves even more special attention. Melamine is toxic to the body, and has no business being ingested in any quantity. No food containing melamine should be ingested, and this is particularly true for infants. The facts regarding melamine toxicity are being distorted to make it sound like, to the general public, that melamine is safe. In my previous discussion on melamine, I addressed the toxicity of melamine and the associated cover-up. This time I shall discuss melamine, and any toxin for that matter, from a philosophical viewpoint. This discussion is adapted from the book Why Am I Sick? And What To Do About It , available on Amazon.

Ingestion of any toxin has absolutely no role in health. While the body can effectively eliminate certain toxins found in the environment, other toxins either cannot be readily eliminated from the body or are eliminated from the body very slowly. When this happens, damage to the body results. Since this damage often occurs at the cellular and sub-cellular level, it often goes undetected until considerable damage has accumulated. By the time damage is detected at the system level, the disease process initiated by the toxin has been in progress for quite some time. Obviously, removing ourselves from the exposure to the toxin is the appropriate countermeasure. In addition, methods can be used to hasten the elimination of certain toxins from the body. Fortunately, in most cases, the body is able to repair the damage cause by these toxins.

Toxins are a unique form of stress encountered by the body in the sense that they not only invoke the body’s natural stress response as chemical stressors, but also have a mechanism of toxicity that subsequently causes tissue damage. This tissue damage further invokes the body’s stress response. In essence, the natural stress response of the body is invoked by both by the toxic chemical stressor and the tissue damage caused by the toxin. This factor is often overlooked by those publishing “safe exposure limits” of their favorite toxin.

For every controversy regarding any toxin presented in the discussion, two opposing positions can be found. One position is that the substance is known to be toxic and therefore can cause harm to the body. This position is substantiated by biochemists, professors, and other independent researchers. The other position maintains that the toxin is safe. This is the position that will calm the public, and is often financed by those having a vested financial interest involving that toxin in one way or another. One cannot legislate away the detrimental effects of a toxic compound. In addition, propaganda cannot be used to reduce the toxicity of a toxin.

Governments have issued documents defining safe exposure levels to various toxins, such as Mercury and other heavy metals, pesticides, and various organic and inorganic compounds, and now, melamine. The safe exposure level is determined through extensive research, and the safe exposure limit is typically set at a level where symptoms are not evident. This research is performed by men and women who have PhDs and specialize in biochemistry and human disease. Various factors are taken into consideration and, based upon the findings, a number is generated representing the upper limit of safe exposure. The fundamental problem with this methodology is that we talking about a toxin. The safe exposure level of the toxin is therefore zero. If the PhD performing the research arrived at a safe exposure level of zero, they would be fired from their job, plain and simple. The truth is that, since these toxins are present and eliminating them is impossible, something must be done to make the public feel safe. Exposure limits, therefore, are set, published, and adhered to, giving the illusion of safety. This amounts to nothing more than a game of “how much can we get away with and not get caught.” In other words, a game is being played in setting limits to how much damage that can be done to the body, and, at the same time, keeping the damage undetected as far as physical or mental symptoms are concerned. The stated intent of setting these limits is always related to, in one way or another, the protection of the health of the public. The real reason, however, is to avert any legal liability as a result to exposure to these toxins. Obviously, not being a participant in such a game would be in the best interest of health.

The same nonsense of setting safe limits is also applied to human laboratory tests designed to measure exposure to toxins. In this case, however, the nonsense is carried quite a bit further. Limits of the presence of heavy metals, various organic and inorganic compounds, or other toxic compounds are set for the urine, blood, or hair by various organizations. Several quantitative methods are available for determining whether a toxic level exists. Different organizations publish different limits of these toxins, and no agreement can be found as to what constitutes a safe level. To complicate matters further, occupational limits in exposed workers are also defined, and safe exposure levels to the toxins used in industry are different from the limits for the general population. For example, for the general population, the upper limit of Lead found in the blood should not exceed 19 ug/dl. For industrial exposure, the limit defined by the Occupational Safety and Health Administration (OSHA) is 40 ug/dl. If the level exceeds 60 ug/dl, according to OSHA, the employer must remove the employee from exposure to the hazard. While it appears that these limits are as a result of careful and extensive research, they represent nothing but pure nonsense. The question arises as to why 39 ug/dl is safe and 41 ug/dl is not safe. Another question arises as to why employment in industry warrants a higher safe exposure level as opposed to someone who does not work. The cynical observer would question why all these figures published by the government all mysteriously ends in a zero. Why is 40 ug/dl the accepted limit, and not 37.5 ug/dl? For any test designed to measure the level of a known toxin in the body, regardless of whether the toxin is being measured in the blood, urine, hair, or other tissue, the only safe level of that toxin is zero. Furthermore, determining safe levels of exposure based upon the factor of employment is, at best, absurd.

Biochemistry is a very well defined and well understood scientific field. Biochemistry does not lie. If the biochemist can clearly demonstrate the disruption to the biochemical processes of the body caused by a particular toxin, and can clearly show exactly how the toxin is toxic, no further discussion or argument is necessary. If a particular compound is shown to disrupt a particular chemical reaction through a specific mechanism of action, no guidelines or legislation issued by any governmental organization is going to affect the biochemical reaction. When something is defined as a toxin, in most cases the mechanism of actions is clearly understood and demonstrable. In other cases, the mechanism of action of the toxin is unknown, which, in a way, is indicative of a potentially more dangerous toxin. If the mechanism of action is not known or not fully understood, no one really knows exactly how that toxin is poisoning the body. A toxin in which the mechanism of action is unknown is analogous to Pandora’s Box.

Melamine is a toxin for which safe exposure limits have now been set for the sole purpose of calming the public. The limit of melamine exposure has been set at 1 part per million (ppm). This limit, as expected, is the proberbial “round number,” and represents pure nonsense as arrived at through junk science. This limit will ultimately be refined, and defined for specific age groups. Just like with Lead, there is no safe exposure limit to a toxin that can, and will, cause harm to the body. Since we are talking about a toxin, the safe exposure limit is therefore zero. Avoiding any food imported from China would be the only prudent measure regarding melamine.

The FDA’s official statement, revised on November 28, 2008, can be found here: http://www.fda.gov/oc/opacom/hottopics/melamine.html

How the FDA determined what level of melamine is safe can be found here: http://www.cfsan.fda.gov/~dms/melamra4.html

A list of products tested by the FDA can be found here: http://www.fda.gov/oc/opacom/hottopics/melamine/testresults.html