This book is about creating a food supply in your home that is safe and free of toxic substances. These toxic substances include heavy metals (such as mercury) and pesticides. Using scientific research and my own experiences, I illustrate how such substances (as well as our diets in general) are contributing to Western diseases like diabetes, heart disease, Alzheimer’s disease, autism, and more. Most of the public has no idea that the food they eat may contain these substances because of loopholes in the laws, misleading food product labels, and faulty risk assessment processes. I know this because of the research I conducted—and then was ordered to stop conducting—during my time as an employee of the Food and Drug Administration (FDA).

I transferred to the FDA in 1999 as a Public Health Service (PHS) officer from the United States Environmental Protection Agency (EPA). My job at both the EPA and FDA involved the identification, assessment, mitigation, and cleanup of toxic elements left behind on laboratory surfaces, in laboratory hood and ventilation systems, biosafety cabinets, and plumbing systems in research laboratories undergoing closure. At that time, my training and background was in environmental health and industrial hygiene. This means I was qualified to identify, assess, and control physical, chemical, biological, or other environmental hazards in the workplace or community that could cause injury or disease. While doing my job at the FDA, my collaborators and I kept finding mercury in the plumbing systems of laboratories undergoing closure. We wondered where it came from.

Fortunately, my supervisor at the FDA gave me permission to determine the source of the mercury contamination in the plumbing systems. During my investigation, I uncovered the unsettling fact that many laboratory chemicals contain mercury residue. When mercury is part of a molecular compound or in its elemental form, it is heavier than water and tends to settle at low points in plumbing systems.1 Before environmental regulations were developed by the EPA for the disposal of hazardous waste, researchers just poured waste chemicals down the laboratory drains and the mercury settled in the sink traps and sumps. This is the reason why we kept finding mercury in the plumbing systems of the laboratories undergoing closure at FDA. You may wonder how the mercury residue got into the laboratory chemicals in the first place. I did, too.

THE SEARCH FOR MISSING MERCURY
I consulted with my peers working in the environmental field and asked if they knew how the mercury residue ended up in the laboratory chemicals. I interviewed a colleague at the EPA and found out the chlor-alkali chemical companies reported missing several tons of mercury from their manufacturing process every year to the EPA.2 (Chlor-alkali is a chemical process used to manufacture many industrial substances.)

In 2000, the twelve mercury cell chlor-alkali plants in operation at the time reported to EPA that there were approximately 65 tons of missing mercury altogether.2 This amount was the difference between how much mercury the plants used and how much mercury the plants released into the environment or disposed of. The chemicals manufactured by the chlor-alkali plants were often the same ones used by FDA research laboratories.

My EPA colleague informed me that there was only one mercury cell chlor-alkali chemical company that had provided the EPA with information on where their missing mercury went. Out of the nine mercury cell chlor-alkali chemical companies operating in 2004, Vulcan Chemical was the only one in the United States to achieve its goal of finding its missing mercury. Vulcan Chemical knew exactly how much mercury went into their manufacturing processes to make chlorine, hydrochloric acid, sodium hydroxide, and potassium hydroxide chemical products, and where the mercury ended up. I suspected much of it ended up in the chemical products that the FDA and other researchers used in their laboratories, but needed to investigate further to see if my hunch was correct. I figured it would be best to go to the source, and so I telephoned Vulcan Chemical. No one was available to talk with me. I left a message for management staff, but they did not return my call.

The Vulcan Chemical mercury cell chlor-alkali manufacturing plant was located in Wisconsin, and I knew the company would have been required to comply with state environmental laws pertaining to toxic substance releases in wastewater and air. I submitted a request to the Wisconsin Department of Natural Resources (DNR) for information regarding the missing mercury from the Vulcan Chemical plant. The exact amounts were provided to me in an email from a wastewater specialist in the Wastewater Permits and Pretreatment Section.3 Vulcan Chemical had provided this information to the DNR as part of their wastewater discharge permit application. The information is provided below:

Missing Mercury (Hg) Found in Vulcan Chemical Products in 1999

• Chlorine (Cl). 1 lb Hg/year.
• Sodium Hydroxide/caustic soda (NaOH). 6 lb Hg/year.
• Hydrochloric Acid/muriatic acid (HCl). 11 lb Hg/year.
• Potassium Hydroxide/potash (KOH). 11 lb Hg/year.

As you can see above, one pound of the missing mercury was found in the chlorine product, six pounds were found in the sodium hydroxide, and eleven pounds were found in both the hydrochloric acid and the potassium hydroxide. I realized at this point that mercury residue would probably be found in all chemical products produced by the mercury cell chlor-alkali industry. Since the mercury was missing from this industry, obviously no one had been keeping track of it. This fact alarmed me greatly because mercury is known to be extremely toxic among public health professionals. It is a neurotoxin, which by definition interferes with brain development. What if the missing mercury ended up in products consumed by children? I knew the American Academy of Pediatrics had published a paper recommending the elimination of all mercury exposure from our children’s environment.4 The question that came to my mind was: Who else uses these mercury cell chemical products, besides scientists working in research laboratories?

I didn’t have to look far for an answer to this question. It was lurking on the Vulcan Chemical website. Mercury-grade sodium hydroxide and hydrochloric acid were chemicals used primarily by the food color, citric acid, and high fructose corn syrup industries. Why would manufacturers use these mercury-containing chemicals to make food ingredients? Maybe the corn syrup manufacturers would talk with me. After all, I worked at the FDA.

MERCURY AND HIGH FRUCTOSE CORN SYRUP
The only corn refiner I could find who was willing to speak with me was the manager of an “organic” high fructose corn syrup (HFCS) manufacturing plant. The gentleman informed me that while the HFCS industry used both mercury cell sodium hydroxide and membrane grade sodium hydroxide in their manufacturing process to lengthen and enhance product shelf life, the mercury cell sodium hydroxide was preferred when it was available. I asked him if I could send out an FDA field investigator to collect samples of HFCS for mercury analysis and he said yes, as long as I agreed to keep his identity confidential. He was alarmed at the possibility there could be mercury residue in his product as a result of using mercury cell sodium hydroxide in his manufacturing process and wanted to be cooperative.

I was alarmed that mercury cell sodium hydroxide was even allowed to be used in the HFCS manufacturing process in the first place. That year (2004), Americans were consuming 36 pounds of HFCS per person, which seemed like a lot of sweetener to me—especially when the substance could be contaminated with mercury.5 I contacted someone at the Chlorine Institute, the trade association that represented the chlor-alkali chemical manufacturers, to find out why food manufacturers could buy and use their mercury cell chemical products.

The president of the Chlorine Institute at the time, Art Dungan, was most cooperative and provided me with information on the allowable levels of mercury in “food grade” chlor-alkali chemicals.6 He explained the amount of mercury residue in mercury cell chlor-alkali products varies, depending on the manufacturing process at each plant.6 Manufacturers of mercury cell chlor-alkali chemicals are required to provide information regarding the amount of mercury found in their products on their product specification sheets.6 Mr. Dungan explained the allowable levels of mercury and lead in food grade chemicals are established by the Food Chemicals Codex, the internationally recognized food ingredient safety standards, now owned and published by U.S. Pharmacopeial Convention, otherwise known as the USP.7

After doing some digging, I learned the USP was founded in 1820, long before the FDA, and is essentially the trade association for the pharmaceutical industry.8 According to the Vulcan Chemical web page, the two largest purchasers of its mercury cell chlor-alkali chemicals were the pharmaceutical and high fructose corn syrup manufacturers! It appeared to me that mercury residue was purposely being added to both medicines and food ingredients. Why? What do food and medicine have in common?

Further research revealed mercury has historically been used as a biocide in medicines designed to kill germs or other pathogenic organisms, and as a pesticide in chemical products designed for killing mold on seeds and grains.9 In medicine, it was incorporated in de-worming agents, teething powders, and diaper rash creams.9 Prior to being taken off the market, Mercurochrome (an antiseptic containing mercury) was used routinely to treat sore throats and prevent infection in wounds.9 In fungicides, mercury was an element used in agents designed to kill mold in and on grains.10 Mercury compounds were used extensively in agriculture and in food production.10 

The purpose of using mercury cell chlor-alkali chemicals to manufacture food ingredients is clear to me now. It makes sense that mercury residue in any food ingredient would kill mold and bacteria and lengthen product shelf life. The longer a product stays fresh on the grocery shelf without spoiling, the better for food manufacturers because product losses are minimized and profits are maximized, increasing net earnings. I became increasingly aware of how many food products contained high fructose corn syrup. I still could not believe mercury-containing chlor-alkali chemicals were intentionally being added to HFCS during the manufacturing process to enhance product shelf life. I wondered if HFCS manufacturers were touting their food ingredient’s ability to prevent food product spoilage by killing bacteria or mold.

A quick visit to the Corn Refiner Association’s web page revealed high fructose corn syrup was indeed being marketed as an ingredient capable of enhancing product shelf life by “creating freshness,” or allowing manufactures to produce foods that stay fresh.11 After viewing manufacturer’s and distributor’s websites, I read about how HFCS could be added to bread to “prevent mold.” Some websites even touted the ingredient’s use as a preservative. It was not approved by FDA for use as a preservative. How much mercury was in this ingredient, anyway?

To find out, I asked an FDA field investigator to visit a number of high fructose corn syrup manufacturers and collect samples for analysis. These samples were sent to a researcher’s laboratory at a different agency that had analytical equipment that could detect the lowest levels of mercury; they were then placed in cold storage for safekeeping. I obtained another set of samples directly from the manufacturers and sent them to an analytical chemistry lab at the National Institute of Standards and Technology (NIST) and a University of California laboratory for analyses.

The researchers at NIST analyzed the HFCS samples and found trace amounts of mercury in all of them, as did the researchers who analyzed the samples at the University of California laboratory. It was time to report my findings to the FDA Center for Food Safety and Applied Nutrition (CFSAN). The University of California researcher sat in at the meeting with CFSAN staff and together, we reported the findings. To my amazement, after the meeting, I was ordered by senior FDA management to stop my investigation. Later, when I tried to publish the findings provided to me in an official report by the researchers at NIST,12 I was informed by FDA management staff that I could not use the results in the official NIST report because they were not meant for “public distribution.”

It became increasingly clear to me that in order to finish the investigation and report the findings, I would have to retire early from the Public Health Service. As a commander in the Public Health Service, if I disobeyed the direct order to “stop investigating,” I could be prosecuted under the Uniform Code of Military Justice. Since I would not be allowed to continue the investigation, I asked my supervisor if I could tell the researcher who was safekeeping those HFCS samples sent to him by the FDA field investigator to do whatever he wanted with them. To my relief, my supervisor said yes. I immediately made plans to retire early to continue the investigation and find out the truth about the use of mercury as a preservative in our food supply.

MY MISSION
Since my retirement, I have continued the investigation with collaborators at research institutions and universities throughout the United States. We publish our findings in peer-reviewed medical journals. Now, I serve as the founding director and principal investigator at the Food Ingredient and Health Research Institute (FIHRI), the only federally-recognized 501(c)(3) nonprofit organization in the United States devoted entirely to food ingredient safety, consumer education, and research.13,14 There is no other organization in the U.S. devoted to conducting research on food ingredients, such as HFCS, that are generally recognized as safe by the FDA. There are numerous food additives and ingredients recognized as safe by the FDA in our food supply that recent research indicates are factors in the development of autism, attention deficit-hyperactivity disorder (ADHD), and chronic diseases such as obesity and diabetes. 

This book is a compilation of the research findings conducted by FIHRI, U.S. government scientists, and other researchers at universities across the world, written in consumer-friendly terms. This is combined with my knowledge and experience of working at a federal food regulation agency, the FDA. The research on food ingredients to date is science-based and the findings described for you here will guide you in creating a safe food supply for your family.

In Chapter 1, you will be introduced to the most common toxic substances that end up in our food supply. The guidelines that are used to assess the risk of such substances is problematic, and this chapter will explain why. In Chapter 2, you will learn how your genes function, their important roles in maintaining your health, and how they respond to what you eat. Chapter 3 discusses pesticide exposures in food and how they create conditions for adult-onset diseases. In Chapter 4, I will discuss food ingredients that can contain heavy metals, such as vegetable oils and corn sweeteners, and how they affect your current and future health status. Chapter 5 defines the Standard American Diet (SAD), which is sorely lacking in certain nutrients that help prevent disease. Chapter 6 sheds light on the autism and ADHD epidemics and provides guidance to parents on what they can change in their family diet to alleviate the behaviors associated with these disorders. In Chapter 7, I will briefly outline the history of food safety regulation in the U.S. and describe the relationship between food manufacturers and the federal government. You will also learn how to read food ingredient labels so you can choose the safest products and foods to buy at the grocery store without falling for misleading claims. Finally, in Chapter 8, I will provide tips for creating and maintaining a safe food environment at home. It may seem impossible to avoid toxic substances in your food, but if you are armed with the information you need, you will find it is not so hard—and you and your family will feel healthier as a result.

By the time you are finished reading the conclusion at the end of this book, I hope you will be able to apply what you learn to your family’s daily life and improve the quality of food you serve at your dinner table. In creating a nutritionally adequate and safe food supply for your family members, you will not only enhance their quality of life, but also improve their chances of remaining healthy during their life span.