Challenges and Future State for Mycotoxin Analysis: A Review From a Regulatory Perspective.

Mycotoxins are naturally occurring toxins produced by certain fungi. Exposure to mycotoxins may occur through the consumption of contaminated foods or from animals that are fed contaminated feed. To safeguard the nation's food supply, the U.S. Food and Drug Administration (FDA) utilizes a comprehensive mycotoxin program which samples and analyzes foods for surveillance and compliance purposes, including enforcing action levels. Mycotoxin analysis is at the center of the mycotoxin program, as concentration data are needed for data analysis, scientific assessments, and risk management. This review focuses on the Agency's continuous efforts to develop and incorporate fit-for-purpose analytical tools for mycotoxin analysis with particular focus on the relationship between analytical methodologies and scientific assessments. The discussion further highlights challenges and advancements in analytical methods and discusses future possibilities to develop analytical tools and preventative risk management approaches to meet the evolving regulatory needs.

Paired metagenomic and chemical evaluation of aflatoxin-contaminated dog kibble.

Introduction: Identification of chemical toxins from complex or highly processed foods can present 'needle in the haystack' challenges for chemists. Metagenomic data can be used to guide chemical toxicity evaluations by providing DNA-based description of the wholistic composition (eukaryotic, bacterial, protozoal, viral, and antimicrobial resistance) of foods suspected to harbor toxins, allergens, or pathogens. This type of information can focus chemistry-based diagnostics, improve hazard characterization and risk assessment, and address data gaps. Additionally, there is increasing recognition that simultaneously co-occurring mycotoxins, either from single or multiple species, can impact dietary toxicity exposure. Metagenomic data provides a way to address data gaps related to co-occurrence of multiple fungal species. Methods: Paired metagenomic and chemical data were used to evaluate aflatoxin-contaminated kibble with known levels of specific mycotoxins. Kibble was ground to a fine powder for both chemical and molecular analyses. Chemical analyses were performed with Liquid Chromatography Mass Spectrometry (LCMS) and according to the AOAC Official method 2005.08: Aflatoxins in Corn, Raw Peanuts, and Peanut Butter using Liquid Chromatography with Post-Column Photochemical Derivatization. Metagenomes were created from DNA extracted from ground kibble and sequenced on an Illumina NextSeq 2000 with an average sequence depth of 180 million reads per replicate. Results and discussion: Metagenomic data demonstrated that the abundance of DNA from putative aflatoxigenic Aspergillus spp. correlated with the levels of aflatoxin quantified by LCMS. Metagenomic data also identified an expansive range of co-occurring fungal taxa which may produce additional mycotoxins. DNA data paired with chemical data provides a novel modality to address current data gaps surrounding dietary mycotoxin exposure, toxigenic fungal taxonomy, and mycotoxins of emerging concern.

Retrospective analysis of dog study data from food and color additive petitions.

As part of the US FDA CFSAN's efforts to explore alternatives to animal testing, we retrospectively analyzed a sample of food additive (FAP) and color additive petitions (CAP) submitted to the FDA for the utility of dog study data in safety assessment. FAPs and CAPs containing dog studies (161 petitions) were classified as decisive (38%), supportive (27%), supplemental (29%) or undermined (6%) based on the impact the dog study data had on the final safety decision. Petitions classified as decisive were further categorized based on if the dog study data were used to a) address a safety concern (35/61); b) calculate an acceptable daily intake (ADI) (11/61); c) withdraw a petition (4/61); d) the effect was unique to the dog (2/61); or e) unclear (9/61). Of 11 petitions where the dog study was used to set an ADI, 7 contained studies where the points of departure (POD) from the dog studies were within an 8-fold range of the rodent with differences in study design likely contributing to the difference in PODs. Future research should include the development and use of qualified alternative studies to replace the use of animal testing for food and color additive safety assessment while ensuring human safety.

Reassessment of the cadmium toxicological reference value for use in human health assessments of foods.

The U.S. Food and Drug Administration (FDA) developed an oral toxicological reference value (TRV) for characterizing potential health concerns from dietary exposure to cadmium (Cd). The development of the TRV leveraged the FDA's previously published research including (1) a systematic review for adverse health effects associated with oral Cd exposure and (2) a human physiological based pharmacokinetic (PBPK) model adapted from Kjellstrom and Nordberg (1978) for use in reverse dosimetry applied to the U.S. population. Adverse effects of Cd on the bone and kidney are associated with similar points of departure (PODs) of approximately 0.50 µg Cd/g creatinine for females aged 50-60 based on available epidemiologic data. We also used the upper bound estimate of the renal cortical concentration (50 µg/g Cd) occurring in the U.S. population at 50 years of age as a POD. Based on the output from our reverse dosimetry PBPK Model, a range of 0.21-0.36 µg/kg bw/day was developed for the TRV. The animal data used for the animal TRV derivation (0.63-1.8 µg/kg bw/day) confirms biological plausibility for both the bone and kidney endpoints.

A systematic review of adverse health effects associated with oral cadmium exposure.

Scientific data characterizing the adverse health effects associated with dietary cadmium (Cd) exposure were identified in order to make informed decisions about the most appropriate toxicological reference value (TRV) for use in assessing dietary Cd exposure. Several TRVs are available for Cd and regulatory organizations have used epidemiologic studies to derive these reference values; however, risk of bias (RoB) evaluations were not included in the assessments. We performed a systematic review by conducting a thorough literature search (through January 4, 2020). There were 1714 references identified by the search strings and 328 studies identified in regulatory assessments. After applying the specific inclusion and exclusion criteria, 208 studies (Human: 105, Animal: 103) were considered eligible for further review and data extraction. For the epidemiologic and animal studies, the critical effects identified for oral Cd exposure from the eligible studies were a decrease in bone mineral density (BMD) and renal tubular degeneration. A RoB analysis was completed for 49 studies (30 epidemiological and 19 animal) investigating these endpoints. The studies identified through the SR that were considered high quality and low RoB (2 human and 5 animal) can be used to characterize dose-response relationships and inform the derivation of a Cd TRV.

Cadmium physiologically based pharmacokinetic (PBPK) models for forward and reverse dosimetry: Review, evaluation, and adaptation to the U.S. population.

The goal of this study was to assess a cadmium (Cd) physiologically based pharmacokinetic (PBPK) model to evaluate Cd toxicological reference values (e.g. reference dose, tolerable intake, minimum risk level) adapted to the U.S. population. We reviewed and evaluated previously published Cd PBPK models and developed further adaptations to the 1978 Kjellström and Nordberg (KN) model. Specifically, we propose adaptations with updated U.S.-specific bodyweight, kidney weight and creatinine excretion models by using NHANES data as well as a stochastic PBPK model that provides credible intervals of uncertainty around mean populational estimates. We provide our model review and adaptations as well as present estimates from the newly adapted models using observed U.S. urinary Cd values as a function of gender and age and given dietary exposure as evaluated from NHANES/WWEIA and U.S. Total Diet Study data. Results show all newly adapted models provide acceptable mean estimates of urinary Cd in the U.S. The stochastic model provides credible intervals to further inform regulatory decision making. Validation of the estimated K-Cd concentration values was not possible as data for a representative population was not available. We developed a web-based tool implementing these models and other potential adaptations to facilitate PBPK model estimate comparisons.

Updated interim reference levels for dietary lead to support FDA's Closer to Zero action plan.

The Centers for Disease Control and Prevention (CDC) utilizes a blood lead reference value (BLRV) to identify children with elevated blood lead levels (BLLs). At or above the BLRV, the CDC recommends actions be taken to reduce children's BLLs. In 2021, the CDC updated its BLRV to 3.5 µg/dL. To align with the CDC's updated BLRV, the FDA is updating its interim reference levels (IRLs) for lead from food to 2.2 µg/day for children and 8.8 µg/day for females of childbearing age. The updated FDA IRLs for lead will serve as a benchmark to evaluate whether lead exposure from food is a potential concern. The children's BLL associated with the updated IRL is less than those predicted by other agencies to result in 1 intelligence quotient point loss. Dietary lead exposure estimates for children in the U.S. suggest exposures greater than the mean may exceed the updated FDA IRL for children, indicating a need for additional efforts to reduce lead in foods consumed by young children. The US FDA is addressing this need by implementing its Closer to Zero action plan to reduce babies' and children's dietary exposure to toxic elements (e.g., lead, cadmium, arsenic, mercury) over time.

A scoping review of infant and children health effects associated with cadmium exposure.

The U.S. FDA initiative, Closer to Zero, identifies actions the agency will take to reduce toxic element exposure from foods eaten by babies and young children with the goal for exposure to be as low as possible. In support of these efforts, this scoping review sought to characterize the available data for primarily dietary cadmium (Cd) exposure and adverse health effects in infants and children. Based on pre-determined inclusion and exclusion criteria, data were extracted from 59 epidemiology studies, and organ systems/anthropometric data supported by > 3 studies were discussed further. For children, most data available were categorized into the nervous (full-scale IQ and attention), cardiovascular (blood pressure) and urinary systems. Studies identified a negative association between urinary Cd and full-scale IQ, though this was dependent on age and sex. More data are needed to support the associations between Cd exposure and adverse nervous system effects. Studies suggested no association between Cd exposure and blood pressure. Data on renal effects in children were too few and diverse to draw conclusions. For infants, anthropometric measurements and birth timing were studied the most. Some studies found a negative relationship between Cd exposure and birthweight, particularly in females. This finding needs further investigation.

Implementing a risk-risk analysis framework to evaluate the impact of food intake shifts on risk of illness: a case study with infant cereal.

In food safety, process pathway risk assessments usually estimate the risk of illness from a single hazard and a single food and can inform food safety decisions and consumer advice. To evaluate the health impact of a potential change in diet, we need to understand not only the risk posed by the considered hazard and food but also the risk posed by the substitution food and other potential hazards. We developed a framework to provide decision-makers with a multi-faceted evaluation of the impact of dietary shifts on risk of illness. Our case study explored exposure to inorganic arsenic (iAs) and aflatoxins through consumption of infant cereals and the risk of developing lung, bladder and liver cancer over a lifetime. The estimated additional Disability-Adjusted Life Year (DALY) in the U.S. from exposure to iAs and aflatoxin based on available contamination and consumption patterns of infant rice and oat cereal is 4,921 (CI 90% 414; 9,071). If all infant cereal consumers shift intake (maintaining equivalent serving size and frequency) to only consuming infant rice cereal, the predicted DALY increases to 6,942 (CI 90% 326; 12,931). If all infant cereal consumers shift intake to only consuming infant oat cereal, the predicted DALY decreases to 1,513 (CI 90% 312; 3,356). Changes in contaminant concentrations or percent consumers, that could occur in the future, also significantly impact the predicted risk. Uncertainty in these risk predictions is primarily driven by the dose-response models. A risk-risk analysis framework provides decision-makers with a nuanced understanding of the public health impact of dietary changes and can be applied to other food safety and nutrition questions.

Assessment of intestinal absorption/metabolism of 3-chloro-1,2-propanediol (3-MCPD) and three 3-MCPD monoesters by Caco-2 cells.

3-chloro-1,2-propanediol (3-MCPD) and 3-MCPD esters are contaminants present in a variety of processed foods, including infant formulas. Toxicological data are unavailable in humans, but rodent studies have demonstrated renal and testicular toxicity from 3-MCPD and 3-MCPD esters. There is evidence that 3-MCPD esters are hydrolyzed in the digestive system, releasing 3-MCPD that would be absorbed and induce damage. We assessed absorption and metabolism of 3-MCPD and three 3-MCPD monoesters, 1-oleoyl (1-Ol), 1-linoleoyl (1-Li) and 1-palmitoyl (1-Pa) commonly found in U.S. infant formula using differentiated Caco-2 cells. After 1-hour incubation, all three monoesters released free 3-MCPD and free fatty acids (FFA) into Caco-2 cell supernatants. Free 3-MCPD had a high apparent permeability (Papp = 30.36 ± 1.31 cm/s × 10-6) suggesting that it is freely diffusible and highly absorbed by intestinal epithelium. 1-Li released 3-4-fold more 3-MCPD than 1-Ol and 1-Pa over 1 h, suggesting that this variable release rates might contribute to the overall in vivo exposure to 3-MCPD. None of the monoesters or FFA were detected in basolateral supernatants, suggesting that these compounds do not cross the intestinal wall without further transformation. In summary, this study provides relevant data to advance knowledge of in vivo intestinal absorption and metabolism of 3-MCPD monoesters.

Internationalization of read-across as a validated new approach method (NAM) for regulatory toxicology.

Read-across (RAx) translates available information from well-characterized chemicals to a substance for which there is a toxicological data gap. The OECD is working on case studies to probe general applicability of RAx, and several regulations (e.g., EU-REACH) already allow this procedure to be used to waive new in vivo tests. The decision to prepare a review on the state of the art of RAx as a tool for risk assessment for regulatory purposes was taken during a workshop with international experts in Ranco, Italy in July 2018. Three major issues were identified that need optimization to allow a higher regulatory acceptance rate of the RAx procedure: (i) the definition of similarity of source and target, (ii) the translation of biological/toxicological activity of source to target in the RAx procedure, and (iii) how to deal with issues of ADME that may differ between source and target. The use of new approach methodologies (NAM) was discussed as one of the most important innovations to improve the acceptability of RAx. At present, NAM data may be used to confirm chemical and toxicological similarity. In the future, the use of NAM may be broadened to fully characterize the hazard and toxicokinetic properties of RAx compounds. Concerning available guidance, documents on Good Read-Across Practice (GRAP) and on best practices to perform and evaluate the RAx process were identified. Here, in particular, the RAx guidance, being worked out by the European Commission's H2020 project EU-ToxRisk together with many external partners with regulatory experience, is given.

A review of the evidence to support interim reference level for dietary lead exposure in adults.

FDA developed the interim reference level (IRL) for lead of 3 µg/day in children and 12.5 µg/day in women of childbearing age (WOCBA) to better protect the fetus from lead toxicity. These IRLs correspond to a blood lead level (BLL) of 0.5 µg/dL in both populations. The current investigation was performed to determine if the IRL for WOCBA should apply to the general population of adults. A literature review of epidemiological studies was conducted to determine whether a BLL of 0.5 µg/dL is associated with adverse effects in adults. Some studies reported adverse effects over a wide range of BLLs that included 0.5 µg/dL adding uncertainty to conclusions about effects at 0.5 µg/dL; however, no studies clearly identified this BLL as an adverse effect level. Results also showed that the previously developed PTTDI for adults of 75 µg/day lead may not be health protective, supporting use of a lower reference value for lead toxicity in this population group. Use of the 12.5 µg/day IRL as a benchmark for dietary lead intake is one way FDA will ensure that dietary lead intake in adults is reduced.

Long-term in vitro effects of exposing the human HK-2 proximal tubule cell line to 3-monochloropropane-1,2-diol.

3-Monochloropropane-1,2-diol (3-MCPD) is a food processing contaminant in the U.S. food supply, detected in infant formula. In vivo rodent model studies have identified a variety of possible adverse outcomes from 3-MCPD exposure including renal effects like increased kidney weights, tubular hyperplasia, kidney tubular necrosis, and chronic progressive nephropathy. Given the lack of available in vivo toxicological assessments of 3-MCPD in humans and the limited availability of in vitro human cell studies, the health effects of 3-MCPD remain unclear. We used in vitro human proximal tubule cells represented by the HK-2 cell line to compare short- and long-term consequences to continuous exposure to this compound. After periodic lengths of exposure (0-100 mM) ranging from 1 to 16 days, we evaluated cell viability, mitochondrial integrity, oxidative stress, and a specific biomarker of proximal tubule injury, Kidney Injury Molecule-1 (KIM-1). Overall, we found that free 3-MCPD was generally more toxic at high concentrations or extended durations of exposure, but that its overall ability to induce cell injury was limited in this in vitro system. Further experiments will be needed to conduct a comprehensive safety assessment in infants who may be exposed to 3-MCPD through consumption of infant formula, as human renal physiology changes significantly during development.

Persistent behavior deficits, neuroinflammation, and oxidative stress in a rat model of acute organophosphate intoxication.

Current medical countermeasures for organophosphate (OP)-induced status epilepticus (SE) are not effective in preventing long-term morbidity and there is an urgent need for improved therapies. Rat models of acute intoxication with the OP, diisopropylfluorophosphate (DFP), are increasingly being used to evaluate therapeutic candidates for efficacy in mitigating the long-term neurologic effects associated with OP-induced SE. Many of these therapeutic candidates target neuroinflammation and oxidative stress because of their implication in the pathogenesis of persistent neurologic deficits associated with OP-induced SE. Critical to these efforts is the rigorous characterization of the rat DFP model with respect to outcomes associated with acute OP intoxication in humans, which include long-term electroencephalographic, neurobehavioral, and neuropathologic effects, and their temporal relationship to neuroinflammation and oxidative stress. To address these needs, we examined a range of outcomes at later times post-exposure than have previously been reported for this model. Adult male Sprague-Dawley rats were given pyridostigmine bromide (0.1 mg/kg, im) 30 min prior to administration of DFP (4 mg/kg, sc), which was immediately followed by atropine sulfate (2 mg/kg, im) and pralidoxime (25 mg/kg, im). This exposure paradigm triggered robust electroencephalographic and behavioral seizures that rapidly progressed to SE lasting several hours in 90% of exposed animals. Animals that survived DFP-induced SE (~70%) exhibited spontaneous recurrent seizures and hyperreactive responses to tactile stimuli over the first 2 months post-exposure. Performance in the elevated plus maze, open field, and Pavlovian fear conditioning tests indicated that acute DFP intoxication reduced anxiety-like behavior and impaired learning and memory at 1 and 2 months post-exposure in the absence of effects on general locomotor behavior. Immunohistochemical analyses revealed significantly increased expression of biomarkers of reactive astrogliosis, microglial activation and oxidative stress in multiple brain regions at 1 and 2 months post-DFP, although there was significant spatiotemporal heterogeneity across these endpoints. Collectively, these data largely support the relevance of the rat model of acute DFP intoxication as a model for acute OP intoxication in the human, and support the hypothesis that neuroinflammation and/or oxidative stress represent potential therapeutic targets for mitigating the long-term neurologic sequelae of acute OP intoxication.

In vitro toxicological assessment of free 3-MCPD and select 3-MCPD esters on human proximal tubule HK-2 cells.

Chloropropanols are chemical contaminants that can be formed during industrial processing of foods, such as lipids used in commercially available infant and toddler formula in the USA. Many researchers have studied the most common chloropropanol contaminant, 3-monochloropropane-1,2-diol (3-MCPD), as well as its lipid ester derivatives. A plethora of toxicological outcomes have been described in vivo, including effects on the heart, nervous system, reproductive organs, and kidneys. To better understand the concordance of some of these effects to in vitro outcomes, we focused our research on using an in vitro cellular model to investigate whether the proximal tubule cells of the kidney would be vulnerable to the effects of free 3-MCPD and nine of its common esters in commercial formula. Using the established human kidney proximal tubule cell line, HK-2, we performed 24-h treatments using 3-MCPD and nine mono- or di-esters derived from palmitate, oleate, and linoleate. By directly exposing HK-2 cells at treatment doses ranging from 0 to 100 µM, we could evaluate their effects on cell viability, mitochondrial health, reactive oxygen species (ROS) production, and other endpoints of toxicity. Since chloropropanols reportedly inhibit cellular metabolism through interference with glycolysis, we also tested the extent of this mechanism. Overall, we found mild but statistically significant evidence of cytotoxicity at the highest tested treatment concentrations, which were also associated with mitochondrial dysfunction and transient perturbations in cellular metabolism. Based on these findings, further studies will be required to better understand the effects of these compounds under conditions that are more physiologically relevant to human infant and toddler proximal tubules in order to mimic their exposure to chloropropanol-containing foods.

U.S. Food and Drug Administration's interim reference levels for dietary lead exposure in children and women of childbearing age.

Reducing lead exposure is a public health priority for the US Food and Drug Administration as well as other federal agencies. The goals of this research were to 1) update the maximum daily dietary intake of lead from food, termed an interim reference level (IRL), for children and for women of childbearing age (WOCBA) and 2) to confirm through a literature review that with the exception of neurodevelopment, which was not evaluated here, no adverse effects of lead consistently occur at the blood lead level (BLL) associated with the IRL. Because no safe level of lead exposure has yet been identified for children's health, the IRLs of 3 µg/day for children and 12.5 µg/day for WOCBA were derived from the Centers for Disease Control and Prevention reference value of 5 µg/dL BLL, the level at which public health actions should be initiated. The literature review showed that no adverse effects of lead consistently occurred at the BLL associated with the IRLs (0.5 µg/dL). The IRLs of 3 µg/day for children and 12.5 µg/day for WOCBA should serve as useful benchmarks in evaluating the potential for adverse effects of dietary lead.

Lead exposures in older children (males and females 7-17 years), women of childbearing age (females 16-49 years) and adults (males and females 18+ years): FDA total diet study 2014-16.

Dietary exposures to lead were estimated for older children, females of childbearing age and adults based on lead concentration data from the FDA's Total Diet Study and on food consumption data from What We Eat In America (WWEIA), the food survey portion of the National Health and Nutrition Examination Survey (NHANES). Estimated mean exposures varied based on the population and on the three different substitution scenarios for lead values below the limit of detection (non-detects = 0; non-detects = limit of detection; hybrid approach). Estimated mean lead exposures range from 1.4 to 4.0 µg/day for older children (males and females 7-17 years), 1.6 to 4.6 µg/day for women of childbearing age (females 16-49 years) and 1.7 to 5.3 µg/day for adults (males and females 18 years and older). Estimated 90th percentile lead exposures range from 2.3 to 5.8 µg/day for older children, 2.8 to 6.7 µg/day for women of childbearing age and 3.2 to 7.8 µg/day for adults. Exposure estimates suggest some older children may be exposed to dietary lead above the FDA interim reference level for lead in children of 3 µg/day. The results of this study can be used by the FDA to prioritise research and regulatory efforts in the area of dietary lead exposure.

Estimated US infant exposures to 3-MCPD esters and glycidyl esters from consumption of infant formula.

A dietary exposure assessment was conducted for 3-monochloropropane-1,2-diol (3-MCPD) esters (3-MCPDE) and glycidyl esters (GE) in infant formulas available for consumption in the United States. 3-MCPDE and GE are food contaminants generated during the deodorisation of refined edible oils, which are used in infant formulas and other foods. 3-MCPDE and GE are of potential toxicological concern because these compounds are metabolised to free 3-MCPD and free glycidol in rodents and may have the same metabolic fate in humans. Free 3-MCPD and free glycidol have been found to cause adverse effects in rodents. Dietary exposures to 3-MCPDE and GE from consumption of infant formulas are of particular interest because formulas are the sole or primary food source for some infants. In this analysis, US Food and Drug Administration data on 3-MCPDE and GE concentrations (as 3-MCPD and glycidol equivalents, respectively) in a small convenience sample of infant formulas were used to estimate exposures from consumption of formula by infants 0-6 months of age. 3-MCPDE and GE exposures based on mean concentrations in all formulas were estimated at 7-10 and 2 µg/kg bw/day, respectively. Estimated mean exposures from consumption of formulas produced by individual manufacturers ranged from 1 to 14 µg/kg bw/day for 3-MCPDE and from 1 to 3 µg/kg for GE.