Clinical Pharmacist and Master’s student in Clinical Pharmacy with research interests in pharmacovigilance, behavioral interventions in mental health, and AI applications in clinical decision support. Experience includes digital health research with Bloomsbury Health (London) and pharmacovigilance practice in patient support programs. Published work covers drug awareness among healthcare providers, postpartum depression management, and patient safety reporting. 
Clinical Pharmacist and Master’s student in Clinical Pharmacy with research interests in pharmacovigilance, behavioral interventions in mental health, and AI applications in clinical decision support. Experience includes digital health research with Bloomsbury Health (London) and pharmacovigilance practice in patient support programs. Published work covers drug awareness among healthcare providers, postpartum depression management, and patient safety reporting. What was studied?
Total Diet Study heavy metals FY2018-FY2020 data were compiled in an FDA Total Diet Study (TDS) report supplement that summarizes analytical results for multiple elements, including priority heavy metals (notably total arsenic, cadmium, lead, and mercury) measured in a broad set of prepared foods. The document is structured as food-by-food tables listing the number of samples analyzed, the number of detects versus non-detects, and descriptive statistics (mean, standard deviation, minimum, maximum), alongside the reporting limit for each analyte. This format is directly relevant to HMTC because it provides a government-generated reference distribution for metals in commonly consumed foods, highlights where non-detects are typical versus where detects are frequent, and shows the magnitude of variability (including high-end values) that can inform risk-based certification thresholds. The tables also show how reporting limits differ by analyte and matrix, which is critical when translating “non-detect” results into compliance decisions and when setting method performance expectations for certified laboratories.
Who was studied?
No human participants were studied. Instead, Total Diet Study heavy metals FY2018-FY2020 data reflect laboratory testing of foods, with each food item represented by multiple analytical samples (commonly 27 samples for many foods, and smaller counts such as 2–3 for some products). The “who” in this context is the market-basket of foods tested: dairy (including fluid milks and cheeses), meats, fish products, legumes, nut products, grains, and baked goods, among others. Because the results are presented per prepared food, they are most appropriately interpreted as exposure-relevant concentrations in foods as consumed, not raw agricultural commodities. For HMTC, this matters because certification programs typically evaluate finished products and ingredients; these tables help distinguish which food categories tend to show consistent detects (suggesting a predictable background burden) versus categories where metals are often non-detect (suggesting that detects may indicate avoidable contamination, supplier variability, or processing contributions).
Most important findings
Total Diet Study heavy metals FY2018-FY2020 data show that detects and concentration ranges vary sharply by food type, and that “non-detect” is common in some matrices (e.g., several fluid milks for lead and arsenic) while other foods show frequent detects and higher maxima (notably for total arsenic in rice and fish products, and for cadmium/lead in certain nut and grain-based foods). These patterns are directly actionable for HMTC in setting category-specific expectations, defining lot-level triggers, and selecting matrices for enhanced surveillance.
| Critical point | Details |
|---|---|
| Non-detect patterns can define “expected clean” categories | Whole fluid milk showed non-detects for total arsenic, cadmium, lead, and mercury at low reporting limits (e.g., 1 ppb for several metals), supporting a strict HMTC posture for similar low-metal dairy matrices where detects may indicate atypical contamination. |
| Processed/flavored products can shift metal detectability | Chocolate reduced-fat milk had frequent detects for cadmium (detects in all 27 samples; mean 2.6 ppb; max 7.0 ppb) and lead (detects in 21/27; mean 1.0 ppb; max 1.9 ppb), illustrating how ingredients such as cocoa or processing inputs can change background levels versus plain milk. |
| Grain staples show consistent total arsenic detects | Cooked enriched white rice showed detects in all 27 samples for total arsenic (mean 45 ppb; max 75 ppb), reinforcing that HMTC thresholds for rice-based foods should be category-specific and paired with clear product-scoping (ingredient vs finished good) and sampling plans. |
| Nut and legume products may be higher for cadmium and lead | Creamy peanut butter showed cadmium detects (mean 52 ppb; range 42–60 ppb) and lead detects (mean 5.6 ppb; range 5.2–6.1 ppb), supporting enhanced supplier qualification and tighter COA/verification requirements for nut-based ingredients and spreads in HMTC. |
| Fish products can carry very high total arsenic and measurable mercury | Frozen oven-cooked fish sticks/patty showed very high total arsenic (mean 757 ppb; 650–810 ppb) and mercury detects (mean 7.1 ppb; 5.6–9.8 ppb), underscoring HMTC’s need to separate total vs species-specific arsenic where appropriate and to apply matrix-aware benchmarks for seafood-based categories. |
Key implications
For HMTC, Total Diet Study heavy metals FY2018-FY2020 data support category-specific regulatory alignment rather than one-size-fits-all limits, because background detects differ markedly by matrix. Certification requirements should explicitly tie limits to validated reporting limits, define how non-detects are handled, and require method suitability for each food type. Industry applications include risk-tiering suppliers and ingredients (rice, nuts, and seafood warrant more frequent verification) and using maxima distributions to set escalation triggers. Key research gaps include limited speciation context for arsenic and the need for clearer linkage between product inputs and observed detects. Practical recommendations include establishing matrix-based action levels, mandating confirmatory testing when detects exceed typical ranges, and requiring tighter COA verification for higher-risk categories.
Citation
U.S. Food and Drug Administration. FDA Total Diet Study (TDS) FY2018–FY2020 Report Supplement: Summary of Analytical Results. July 2022.
Arsenic is a naturally occurring metalloid that ranks first on the ATSDR toxic substances list. Inorganic arsenic contaminates water, rice and consumer products, and exposure is linked to cardiovascular disease, cognitive deficits, low birth weight and cancer. HMTC’s stringent certification applies ALARA principles to protect vulnerable populations.
Cadmium is a persistent heavy metal that accumulates in kidneys and bones. Dietary sources include cereals, cocoa, shellfish and vegetables, while smokers and industrial workers receive higher exposures. Studies link cadmium to kidney dysfunction, bone fractures and cancer.
Lead is a neurotoxic heavy metal with no safe exposure level. It contaminates food, consumer goods and drinking water, causing cognitive deficits, birth defects and cardiovascular disease. HMTC’s rigorous lead testing applies ALARA principles to protect infants and consumers and to prepare brands for tightening regulations.
Mercury (Hg) is a neurotoxic heavy metal found in various consumer products and environmental sources, making it a major public health concern. Its regulation is critical to protect vulnerable populations from long-term health effects, such as neurological impairment and cardiovascular disease. The HMTC program ensures that products meet the highest standards for mercury safety.
