By: Molly Rauch, Public Health Policy Director, Moms Clean Air Force
Date: November 18, 2021
About: FDA's Closer to Zero Plan
To: Food and Drug Administration
Thank you for the opportunity to comment today. I’m Molly Rauch, Public Health Policy Director for Moms Clean Air Force, an organization of over one millions moms and dads fighting to protect our children from toxic chemicals, air pollution, and climate change.
Earlier this year, a congressional investigation showed that there are significant levels of toxic heavy metals in baby food. Across the country, our members were startled and deeply concerned to learn that high levels of arsenic, lead, cadmium, and mercury are in our babies’ food, and even worse, that these contaminants are basically not regulated. Despite the fact that our food is contaminated by metals known to cause permanent harm to the developing brain, there is basically zero oversight of this problem.
This is unacceptable. Toxic metals harm babies’ developing brains. They are reaching our babies’ brains in combination with other toxic exposures from the air, water, and soil, and the effects are cumulative. The reality is that this harm is irreversible and permanent. It may be subclinical, but it’s real harm to real children, and it is eminently preventable. It is a top priority of Moms Clean Air Force that this exposure is prevented, and it’s time for FDA to make that happen.
Allowing baby food companies to regulate themselves and voluntarily set their own standards has failed to protect our babies. It’s like asking my teenager to voluntarily limit his time on TikTok, as he sees fit. It’s simply not a helpful strategy. This cannot be left up to the companies. Moreover, FDA’s Closer to Zero plan is too slow to protect our babies and toddlers. Way too slow, given what we already know. We need immediate, aggressive interim standards and ambitious deadlines for FDA action. If the FDA waits until 2024 or later to set final standards for toxic heavy metals, millions of babies will be exposed to substances known to compromise their development.
Parents have a right to know what we are feeding our babies. That means that baby food must be tested to ensure that government standards are being met, and those test results should be made public. Products that do not meet the standards should be recalled as a health threat.
Standards must consider the effects of toxic heavy metals in combination, not one by one, to protect our babies’ brains. Finally, standards should not be driven by what’s “achievable” based on current manufacturing and farming practices. We already know that those current practices allow toxic metals to readily enter into our babies’ food. Instead, standards must be based on what’s needed to protect our babies from permanent harm to their developing brains and other organs. As parents, we cannot settle for anything less.