First, on October 3, 2008, the FDA said no level of melamine in infant formula was safe:
"There is too much uncertainty to set a level in infant formula and rule out any public health concern."That's how the FDA interpreted the science at the time.
- FDA Issues Interim Safety And Risk Assessment Of Melamine And Melamine-related Compounds In Food
Then, on November 28, 2008, after small amounts of melamine and cyanuric acid (which, when they occur together, accelerate creation of kidney crystals) were detected in popular, brand name formula, the FDA said that anything below 1.0 ppm was safe:
"Amounts of the industrial chemical melamine or the melamine-like compound called cyanuric acid that are below 1.0 ppm [1,000 parts per billion] do not raise public health concerns," said Stephen Sundlof, the FDA's director of the Center for Food Safety and Applied Nutrition."Where did that number come from? Were there long-term, comprehensive, studies conducted between Oct 3 and Nov 28 that arrived at that number? Why 1.0? Why not 0.9, or 2.1, or 0.4 ... or 0.0? Can that number be defended? Is that saying that 1.0 ppm should raise no concern, but 1.1 ppm should? What's the margin of error here?
- FDA Sets 'Safe' Levels For Melamine In Baby Formula
I have respect for the scientific prowess of FDA researchers. I've waded through the tedium of FDA documents. They're not unlike engineering documents ... in their nit-picky, number-oriented focus. But I don't have the same respect for the people in the FDA who take that work, and make some maniacal decision from it. As if they licked their finger, stuck it into the breeze, and made a decision based on the direction of the wind that day. The political wind.
Come to think of it, there's a lot of similarity between the laborers in engineering and their bosses ... and the laborers in the FDA and their bosses.
We need to hear from the serfs more often.