Comparative Testing: Soy Sauce for 3-MCPD. Malaysian Association of Standards Users

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Comparative Testing: Soy for 3-MCPD 1. Background and Introduction 3-MCPD (3-monochloropropane-1, 2-diol) is a chemical which may be formed in foods by the reaction of chloride with lipids. It is the most commonly found member of a group of chemical contaminants known as chloropropanols. It can occur in foods and food ingredients at low levels as a result of processing, migration from packaging materials during storage, or in domestic cooking. It is primarily created in foods by protein hydrolysis by adding hydrochloric acid to speed up the reaction of the (soy) protein with lipids at high temperatures. The UK- based Institute of Food Science & Technology (IFST), through its Public Affairs and Technical & Legislative Committees, has authorized an Information Statement on 3-MCPD. According to that statement, 3- MCPD can also occur in foods which have been in contact with materials containing epichlorohydrin-based wet-strength resins - used in the production of some tea bags and sausage casings. 3-MCPD has been shown to be a carcinogen in laboratory animal studies and the European Commission s Scientific Committee on Food (SCF) originally classified 3-MCPD as a genotoxic carcinogen with the recommendation that its presence in foodstuffs should be reduced to an undetectable level. More recent evaluations by the SCF and other expert committees have concluded that there is a lack of evidence of in vivo genotoxicity and that a threshold-based approach for deriving a Tolerable Daily Intake (TDI) would be appropriate. The SCF have proposed a provisional TDI level of 2µg/kg body weight/day for the amount of 3-MCPD that can be consumed daily over a lifetime without appreciable harm to health. There is European food legislation which imposes maximum levels for 3-MCPD in hydrolyzed vegetable protein and soy sauce. 2. Potential Hazards Related to A survey of soy sauces and similar products available in the UK was carried out by the Joint Ministry of Agriculture, Fisheries and Food/Department of Health Food Safety and Standards Group (JFSSG) in 2000 and reported more than half of the samples collected from retail outlets contained various levels of 3-MCPD (Macarthur R et al., 2000). According to a press release in Jun 2001, United Kingdom Food Standards Agency found in tests of various oyster sauces and soy sauces that some 22% of samples contained a chemical called 3-MCPD (3-monochloropropane-1,2-diol) at levels considerably higher than those deemed safe by the European Union. About two-thirds of these samples also contained a second chloropropanol called 1, 3-DCP (1, 3-dichloropropane-2-ol) which experts advise should not be present at any levels in food. Both chemicals have the potential to cause cancer and the Agency recommended that the affected products be withdrawn from shelves and avoided (Source: Food Standards Agency Press Release). In 2006, Certain batches of Marca Pina Soy (1 litre) have been found to be contaminated with levels of (3-MCPD) above EU statutory limits. According to the label, the affected brand of Soy sauce was manufactured in the Philippines. 1

According VietnamNet Bridge, in 2007 at Vietnam, 3-MCPD was found in toxic levels (Testing since 2001, In 2004, the HCM City Institute of Hygiene and Public Health found 33 of 41 sample of soya sauce with high rates of 3-MCPD, including six samples with up to 11,000 to 18,000 times more 3-MPCD than permitted, an increase over 23 to 5,644 times in 2001) in soy sauces, along with formaldehyde in the national dish Pho, and banned pesticides in vegetables and fruits. A prominent newspaper Thanh Nien Daily commented, "Health agencies have known that Vietnamese soy sauce, the country's second most popular sauce after fish sauce, has been chock full of cancer agents since at least 2001,". In Nov 2008, Britain's Food Standards Agency reported a wide range of household name food products from sliced bread to crackers, beef burgers and cheese with 3-MCPD above safe limits. Relatively high levels of the chemical were found in popular brands such as Mother's Pride, Jacobs crackers, John West, Kraft Dairylea and McVitie's Krackawheat. The same study also found relatively high levels in a range of supermarket own-brands, including Tesco char-grilled beef burgers, Sainsbury's Hot 'n Spicy Chicken Drumsticks and digestive biscuits from Asda. The highest levels of 3-MCPD found in a non- soy sauce product, crackers, was 134 mcg per kg. The highest level of 3-MCPD found in soy sauce was 93,000 mcg per kg, 700 times higher (Source: Daily Mail Press Release on The cancer chemical lurking in our food). 2.1 Why is 3-MCPD found in Soy? According to Food Safety Agency, 3-MCPD is produced as a contaminant by-product of a flavor enhancer known as acid-hydrolyzed vegetable protein. Flavor enhancers are commonly added to commercially produced food products (for example frozen dinners, instant soups, and snack foods) and some soy sauces to make them taste more 'savory'. 3-MCPD was originally detected in acid-hydrolyzed vegetable protein (HVP) and was subsequently found in HVP-containing soy sauces. 2.2 Malaysian and other Countries' Legislations Related to 3 - MCPD European Commission Regulation (EC) No 466/2001, which was adopted on 8 March 2001 and which applies from 5 April 2002, prescribes maximum levels of 3-MCPD of 0.02mg/kg (20µg/kg) for hydrolyzed vegetable protein and soy sauce. In the case of the soy sauce, the limit is based on a product containing 40% dry matter (corresponding to a maximum level of 0.05mg/kg (50µg/kg) in the dry matter). The joint Australia New Zealand Food Authority (ANZFA) set a limit for 3-MCPD in soy sauce of 0.02 milligrams per kilogram, in line with European Commission standards which came into force in the EU in April 2002. 2

Comparative Testing: Soy for 3-MCPD The Malaysian Food Act 1983 set a limit for Maximum Permitted Proportion of 3-MCPD in food as follows: Table1: Maximum Permitted Proportion of 3-MCPD in food Food All foods containing acid hydrolyzed vegetable protein (liquid foods) All foods containing acid hydrolyzed vegetable protein (Solid foods) Maximum Permitted Proportion in food (mg/kg) 0.02 0.05 Acid Hydrolyzed vegetable protein 1.00 3. Testing Soy for 3-MCPD 3.1 Methodology The samples of soy sauce were identified and purchased based on the common brands available in most of hypermarkets and grocery shops. Once the brands were identified, 1 sample of light soy sauce and dark soy sauce from the same brand was purchased.the samples were purchased from locations in Klang Valley. 3.2 Limitations Accurate sampling methods were not applied to represent the entire samples in the market. Purchased was based on the rationale that the common brands could be found in most of the shopping complexes, hypermarkets and shops. Only few samples were included due to budget constraint. 3

3.3 Samples Purchased 4

Comparative Testing: Soy for 3-MCPD 5

6

Comparative Testing: Soy for 3-MCPD 7

8

Comparative Testing: Soy for 3-MCPD 9

Table 2: List of products purchased for testing and their descriptions No Brand Product Name Manufacturer Barcode & Expiry Date Place Purchase of Parameter to be tested 1 Pearl River Bridge Mashroom Flavoured Superior Dark Soy Guang Dong PRB Bio Tech Co.LTD No.2, Dong Hu Xi Rd Guangzhou 6921180820056 22/01/2014 Giant 2 Pearl River Bridge Superior Light Soy Guang Dong PRB Bio Tech Co.LTD No.2, Dong Hu Xi Rd Guangzhou 6921180820025 22/01/2014 Giant 3 Lee Kum Kee Mashroom Flavoured Dark Soy Lee Kum Kee (Xinhui) Food Co.Ltd No.1-2, North District, Ind & Trading City,Qi Bao, Xinhui District.Jiangmen City,Guangdong,China 07889512889 17/02/2013 Tesco 4 Lee Kum Kee Selected Light Soy Lee Kum Kee (Xinhui) Food Co.Ltd No.1-2, North District, Ind & Trading City,Qi Bao, Xinhui District.Jiangmen City,Guangdong,China 07889513146 16/02/2013 Tesco 10

Comparative Testing: Soy for 3-MCPD 5 Cap Tamin 6 Cap Tamin 7 Tesco Value 8 Tesco Value 9 Cap Tian Nu 10 Cap Tian Nu Kicap Cair Putri Syarikat Salmi HJ.Tamin Sdn Bha KM 40, Jalan Ipoh,33600 Enggor Perak Dark Soy Syarikat Zamani HJ.Tamin Sdn Bhd 223, Kampong Pasir Baru, Jalan Gopeng 31000 Batu Gajah Perak Light Soy Tesco Stores (M) Sdn Bhd Level 3, No.3, Jalan 7A/62A, Bandar Manjalara 52200, Kuala Lumpur Thick Caramel Tesco Stores (M) Sdn Bhd Level 3, No.3, Jalan 7A/62A, Bandar Manjalara 52200, Kuala Lumpur Thick Soy Bidor Kwong Heng Sdn Bhd Plot 1919, Kawasan Perusahaan Bidor,35500 Bidor Perak Light Soy Bidor Kwong Heng Sdn Bhd Plot 1919, Kawasan Perusahaan Bidor,35500 Bidor Perak 11 Giant Light Soy Giant Hypermarket 2, Jurong East Street #04-32A,IMM Building Singapore 609601 9556051130018 Giant 9556051140017 31/12/2013 9555216500079 September 2012 955521650086 December 2011 9556538000049 27/08/2013 9556538000025 27/07/2013 9556538001527 09/07/2012 Giant Tesco Tesco Tesco Tesco Giant Kelana Jaya 11

12 Adabi Kicap Manis Adabi Consumer Industries Sdn Bhd,Lot136,Rawang Industrial Park,48000 Rawang 9556252273453 11/01/2014 SSPS Super Market Jalan Ipoh 13 Adabi Kicap Masin Adabi Consumer Industries Sdn Bhd,Lot136,Rawang Industrial Park,48000 Rawang 9556252273606 05/01/2014 SSPS Super Market Jalan Ipoh 3.4 The samples were tested by ALS TECHNICHEM (M) SDN BHD according to the following methods: Table 3: Testing Parameter Parameter, Unit Test Methods % Dry Matter as total Solid, g/100g In House No. F20 (Based on AOAC 925.33) 3-MCPD (Fresh Weight), mg/kg Journal of AOAC International Vol. 84, No.2, 2001 3 MCPD (based on 40% dry matter), mg/kg Journal of AOAC International Vol. 84, No.2, 2001 12

Comparative Testing: Soy for 3-MCPD 4. Results Below are the test reports from ALS Technichem Sdn Bhd Table 4: Test Results No Brand Product Name Manufacturer Barcode & Expiry Date % Dry Matter as Total Solid, g/100g 3-MCPD (Fresh Weight), mg/kg 3-MCPD (Based on 40% dry matter), mg/kg 1 Pearl River Bridge Mashroom Flavoured Superior Dark Soy Guang Dong PRB Bio Tech Co.LTD No.2, Dong Hu Xi Rd Guangzhou 6921180820056 22/01/2014 48.5 2 Pearl River Bridge Superior Light Soy Guang Dong PRB Bio Tech Co.LTD No.2, Dong Hu Xi Rd Guangzhou 6921180820025 22/01/2014 30.3 3 Lee Kum Kee Mashroom Flavoured Dark Soy Lee Kum Kee (Xinhui) Food Co.Ltd No.1-2, North District, Ind & Trading City,Qi Bao, Xinhui District.Jiangmen City,Guangdong,China 07889512889 17/02/2013 51.8 4 Lee Kum Kee Selected Light Soy Lee Kum Kee (Xinhui) Food Co.Ltd No.1-2, North District, Ind & Trading City,Qi Bao, Xinhui District.Jiangmen City,Guangdong,China 07889513146 16/02/2013 40.9 5 Cap Tamin Kicap Cair Putri Syarikat Salmi HJ.Tamin Sdn Bha KM 40, Jalan Ipoh,33600 Enggor Perak 9556051130018 51.9 13

No Brand Product Name Manufacturer Barcode & Expiry Date % Dry Matter as Total Solid, g/100g 3-MCPD (Fresh Weight), mg/kg 3-MCPD (Based on 40% dry matter), mg/kg 6 Cap Tamin Dark Soy Syarikat Zamani HJ.Tamin Sdn Bhd 223, Kampong Pasir Baru, Jalan Gopeng 31000 Batu Gajah Perak 9556051140017 31/12/2013 38.1 7 Tesco Value Light Soy Tesco Stores (M) Sdn Bhd Level 3, No.3, Jalan 7A/62A, Bandar Manjalara 52200, Kuala Lumpur 9555216500079 September 2012 48.6 8 Tesco Value Thick Caramel Tesco Stores (M) Sdn Bhd Level 3, No.3, Jalan 7A/62A, Bandar Manjalara 52200, Kuala Lumpur 955521650086 December 2011 52.9 9 Cap Tian Nu Thick Soy Bidor Kwong Heng Sdn Bhd Plot 1919, Kawasan Perusahaan Bidor,35500 Bidor Perak 9556538000049 27/08/2013 76.3 10 Cap Tian Nu Light Soy Bidor Kwong Heng Sdn Bhd Plot 1919, Kawasan Perusahaan Bidor,35500 Bidor Perak 9556538000025 27/07/2013 46.6 11 Giant Light Soy Giant Hypermarket 2, Jurong East Street #04-32A,IMM Building Singapore 609601 9556538001527 09/07/2012 41.7 14

Comparative Testing: Soy for 3-MCPD No Brand Product Name Manufacturer Barcode & Expiry Date % Dry Matter as Total Solid, g/100g 3-MCPD (Fresh Weight), mg/kg 3-MCPD (Based on 40% dry matter), mg/kg 12 Adabi Kicap Manis Adabi Consumer Industries Sdn Bhd,Lot136,Rawang Industrial Park,48000 Rawang 9556252273453 11/01/2014 60.9 13 Adabi Kicap Masin Adabi Consumer Industries Sdn Bhd,Lot136,Rawang Industrial Park,48000 Rawang 9556252273606 05/01/2014 44.0 :Not Detected 5. Discussion and Recommendations All the soy sauce samples tested by ALS Technichem (M) Sdn Bhd could be considered to be generally free of 3-MCPD. Based on the background study that we have done, Standards Users have noted that there are also other consumer products that have been detected for 3-MCPD in other countries. Due to our limitation, we were not able to test these products. The products suspected to contain 3-MCPD are: 1. Vegetarian Meat which may use VHP and flavor enhancers 2. Cheeses 3. Burgers 4. Salamis As a precautionary measure, Standards Users would like to urge both Ministry of Health to carry out market surveillance and test other products (for example those listed above) which have tendencies to be contaminated with 3-MCPD. 15

6. References 1. IFST issues statement on 3-MCPD-http://www.foodnavigator.com/Science- Nutrition/IFST-issues-statement-on-3-MCPD 2. http://www.food.gov.uk/multimedia/webpage/soyproductsqa/ 3. Robjohns S, Marshall R, Fellows M, Kowalczyk G (September 2003). "In vivo genotoxicity studies with 3-monochloropropan-1,2-diol".Mutagenesis 18 (5): 401 4. doi:10.1093/mutage/geg017. PMID 12960406. http://mutage.oxfordjournals.org/content/18/5/401.long 4. Samojlik E, Chang MC (April 1970). "Antifertility activity of 3-chloro-1, 2-propanediol (U- 5897) on male rats". Biology of reproduction 2 (2): 299 304. doi:10.1095/biolreprod2.2.299. PMID 5520328. http://www.biolreprod.org/content/2/2/299.long 5. Ericsson RJ (July 1970). "Male antifertility compounds: U-5897 as a rat chemosterilant". Journal of reproduction and fertility 22 (2): 213 22.doi:10.1530/jrf.0.0220213. PMID 5428943. 6. Macarthur R, Crews C, Davies A, Brereton P, Hough P, Harvey D (November 2000). "3- monochloropropane-1,2-diol (3-MCPD) in soy sauces and similar products available from retail outlets in the UK". Food additives and contaminants 17 (11):9036. doi:10.1080/026520300750038072.pmid 11271703. 7. Food.gov.uk press release soysauce 8. Chart with five mentions of affected oyster sauces 9. Fu WS, Zhao Y, Zhang G, et al. (August 2007). "Occurrence of chloropropanols in soy sauce and other foods in China between 2002 and 2004". Food additives andcontaminants 24 (8):8129. doi:10.1080/02652030701246039. PMID 17613068. 10. http://www.food.gov.uk/multimedia/bigimages/soysauceproducts.gif 11. http://www.bar.gov.ph/barchronicle/2004/may04_1-31_soysauce.asp 12. http://english.vietnamnet.vn/reports/2007/05/699774 13. http://afp.google.com/article/aleqm5iimrrbvltlgx3p0uxmsqet1zjayw 14. Malaysian Food Act 1983 and Food Regulations 1985 16