QUESTIONS AND ANSWERS - OYSTER AND SOYA SAUCES

3-MCPD is one of the chloropropanol group of chemical contaminants and is a potential carcinogen. It has been found in acid hydrolysed vegetable proteins and several other food ingredients as a result of processing, storage, or migration from certain food contact materials.

Health Canada (HC) has determined that there is no immediate health risk from eating existing stocks of the soya and oyster sauces. However, HC advises that elevated levels of 3-MCPD are unacceptable in the longer term and must be lowered.

Yes. On November 25, 1999, Health Canada established a provisional guideline of 1.0 part per million (ppm) for 3-MCPD in oriental-style sauces. The provisional guideline has been phased in to allow time to communicate the information, adjust manufacturing processes and allow for depletion and replacement of existing stocks. Importers and manufacturers have been advised that as of April 1, 2000, product is expected to comply with the provisional guideline.

Industry is expected to work towards further reduction of 3-MCPD levels (below the provisional guideline) after that date.

No. Health Canada has determined that there is no immediate health risk from eating existing stocks of oriental-style soya and oyster sauces marketed in Canada. Many of the oriental-style sauce products on the market were not implicated in the CFIA study or were below the 1.0 ppm provisional guideline.

Although 3-MCPD research work is ongoing, most concerns centre around long term exposure to the contaminant. To represent a health concern, affected product would probably have to contain consistently elevated levels of 3-MCPD and be consumed in large daily amounts over an extended period of time.

As a protective measure, Canada is insisting that 3-MCPD must be reduced to provisional guideline levels or below by April 1, 2000.

Most existing stocks are being used up and none of the product remaining in distribution will likely be removed from the marketplace unless there are problems. The provisional guideline however, goes into effect April 1, 2000 on imported product and compliance action will be taken after that date when 3-MCPD guideline levels are exceeded.

On December 10, 1999, CFIA announced measures to reduce the levels of 3-MCPD in oriental-style soya and oyster sauces sold in Canada.

The CFIA has advised importers and manufacturers that levels of the contaminant must fall below 1.0 ppm by April 1, 2000 or product will be subject to compliance action. Industry has been advised to take immediate steps to comply with the provisional guideline.

Manufacturers of product identified in the survey with 3-MCPD levels above the provisional guideline have been contacted by CFIA.

The CFIA, together with Health Canada representatives, have held meetings with industry groups to discuss progress in reducing the levels of 3-MCPD in affected sauces.

CFIA has advised the import industry that entries after April 1, 2000 are to comply with the provisional guideline of 1.0 ppm and have asked Canada Customs to place soya sauce on a National Border Lookout. Oyster sauces are covered under the current Fish Import Monitoring strategy. Importers demonstrating product compliance will be placed on an exempt investigation list and covered through a random audit test program. Non-exempt entries will require investigation and possible testing. Non-compliant entries will either be re-exported or voluntarily disposed.

Both CFIA and HC will continue to monitor health and safety aspects of the 3-MCPD issue.

The 1.0 ppm provisional guideline will be reassessed as new information becomes available. Based on discussions with Health Canada and international developments, the Health Canada provisional guideline will be further lowered in future. Health Canada believes that levels of this contaminant should be "as low as reasonably achievable" (the "ALARA" concept) and, while the guideline of 1.0 ppm is protective, much lower levels of this contaminant are technologically possible and should be sought, with the objective of ultimately eliminating this contaminant from these foods entirely.

In order to undertake a risk assessment of a contaminant in food, Health Canada would consider the toxicity of the contaminant in question, together with its human exposure via food. Human exposure via food is determined by a knowledge of the particular foods in which the contaminant is found, the consumption levels of those foods, and the levels of the contaminant found in each of those foods.

The information is available on the U.K. government website at: http://archive.food.gov.uk/maff/archive/food/infsheet/1999/no187/187soy.htm

The information we have to date indicates that the U.K. did not take recall action on these products. Instead, the U.K. authorities advised suppliers of the affected products to take appropriate steps to ensure they do not contain detectable levels of 3-MCPD in future. The U.K. authorities refer to a survey conducted by the Joint Food Safety and Standards Group (JFSSG) which found that some soy sauce products on sale in the U.K. can contain this chemical contaminant.

For more information, see the Food Surveillance Information Sheet describing this survey, which is posted on the U.K. Ministry of Agriculture, Fisheries, and Food website at: http://archive.food.gov.uk/maff/archive/food/infsheet/1999/no187/187soy.htm

Other information is available on the CFIA website located at www.inspection.gc.ca. The U.K. website listed above also provides background information.