Mercury in High Fuctose Corn Syrup

This document contains 2 studies finding Mercury in High Fructose Corn Syrup.
The
first was prepared by Institute for Agriculture and Trade Policy, followed by another
study that was completed by Environmental Health.
Not So Sweet: Missing Mercury and High
Fructose Corn Syrup
Not So Sweet: Missing Mercury and HFCS IATP
Not So Sweet: Missing Mercury and High Fructose Corn Syrup
by David Wallinga, M.D., Janelle Sorensen, Pooja Mottl, Brian Yablon, M.D.
Institute for Agriculture and Trade Policy
Minneapolis, Minnesota
Published January 2009 2009 IATP. All rights reserved.
The Institute for Agriculture and Trade Policy works locally and globally
at the intersection of policy and practice to ensure fair and sustainable
food, farm and trade systems.
IATP thanks the Claneil Foundation for their generous support of this report.
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2105 First Avenue South | Minneapolis Minnesota 55404
Executive summary
We live in a truly global food system. Our system typically is geared more toward producing lots of
cheap calories, and then selling those calories to consumers, than it is toward meeting other goals like
reducing fossil fuel use or producing food that is healthy.
In stark relief, new science shows just how blind to healthfulness some processed food makers have
been. Just published online in the journal, Environmental Health (http://www.ehjournal.net/
home/), is a science commentary reporting that mercury was found in 9 of 20 samples of commer-
cial high fructose corn syrup (HFCS), a common sweetener of foods and beverages. The HFCS came
from three different manufacturers.
Mercury is a potent brain toxin that we know accumulates in fish and seafood, although diet is not
the only route by which we are exposed. When babies are exposed to elevated mercury in the womb,
their brains may develop abnormally, impairing learning abilities and reducing IQ. For these youngest
children, the science increasingly suggests there may be no safe level of exposure to mercury.
And yet for decades an increasingly common ingredient in processed foods, HFCS, has been made
using mercury-grade caustic soda.
Caustic soda (also known as sodium hydroxide or lye) and a number of other food industry ingredi-
ents are produced in industrial chlorine (chlor-alkali) plants. Mercury-grade, also known as rayon-
grade caustic soda, comes from chlorine plants still using an outdated 19th century technology that
relies on the use of mercury.
While most chlorine plants around the world have switched to newer, cleaner technologies, some still
rely on the use of mercury. These mercury cell plants may rival coal-fired power plants as sources of
mercury leaked to the environment.
What has not been publicly recognized is that mercury cell technology can also contaminate all the
food grade chemicals made from it, including caustic soda, as well as hydrochloric acid. It was unrec-
ognized, that is, until the lead author of the Environmental Health study, a longtime environmental
investigator of the Food and Drug Administration (FDA), thought to look into it.
What she found was that possible mercury contamination of these food chemicals was not common
knowledge within the food industry despite the availability of product specification sheets for mercu-
ry-grade caustic soda that clearly indicate the presence of mercury (as well as lead, arsenic and other
metals). Upon further investigation, she found mercury contamination in some commercial HFCS,
which can be made from mercury-grade caustic soda.
Through this public scientists initiative, the FDA learned that commercial HFCS was contaminated
with mercury. The agency has apparently done nothing to inform consumers of this fact, however, or
to help change industry practice.
Consumers likely arent the only ones in the dark. While HFCS manufacturers certainly should have
been wary of buying mercury-grade caustic soda in the first place, the food companies that buy
finished HFCS and incorporate it into their processed food products may be equally unaware of how
their HFCS is made, i.e., whether or not it is made from chemicals produced by a chlorine plant still
using mercury cells. The HFCS isnt labeled Made with mercury, just like contaminated pet foods,
chocolates and other products have not been labeled Made with melamine. Under current regula-
tions, that information is not made available to either consumers or to companies further down the
food supply chain.
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When we learned of this gap in information, we set out to do the FDAs work for it. We went to
supermarkets and identified brand-name productsmainly soft drinks, snack foods and other items
mostly marketed to childrenwhere HFCS was the first or second ingredient on the label.
We sent several dozen products to a commercial laboratory, using the latest in mercury detection
technology. And guess what? We found mercury.
In fact, we detected mercury in nearly one in three of the 55 HFCS-containing food products we
tested. They include some of the most recognizable brands on supermarket shelves: Quaker, Hunts,
Manwich, Hersheys, Smuckers, Kraft, Nutri-Grain and Yoplait.
No mercury was detected in the majority of beverages tested. That may be important since sweet-
ened beverages are one of the biggest sources of HFCS in our diets.
On the other hand, mercury was found at levels several times higher than the lowest detectable limits
in some snack bars, barbecue sauce, sloppy joe mix, yogurt and chocolate syrup. Although closer
to the detection limit, elevated mercury levels were also found in some soda pop, strawberry jelly,
catsup and chocolate milk. The top mercury detections are summarized in Table 3, on page 14 of the
report. Results for all 55 products tested can be found in the Appendix.
Environmental mercury from chlorine plants, coal-fired power plants, dental offices and other sources
have helped contaminate albacore tuna, swordfish and many of our favorite fish with mercury. Eating
these fish has long been thought to be the most important mercury exposure for most people.
However, HFCS now appears to be a significant additional source of mercury, one never before consid-
ered. When regulators set safe fish consumption recommendations based on an understanding of existing
mercury exposure, for example, they never built mercury-contaminated HFCS into their calculations.
HFCS as a mercury source is a completely avoidable problem. HFCS manufacturers dont need to
buy mercury-grade caustic soda. And the chlorine industry doesnt need to use mercury cell technol-
ogy. In fact, most chlorine plants in the U.S. dont use it anymore, as it is antiquated and inefficient.
While we wait for the FDA to do its job and eliminate this unnecessary and completely preventable
mercury contamination, we have a few suggestions for what you as consumers and voters can do.
Currently, food manufacturers dont list on their products the source of HFCS and whether or not
it is made from mercury-grade caustic soda. So call them. Make use of the toll-free numbers or Web
sites on many packages, and let companies know youre not comfortable eating their product until
you know exactly what is in it.
As voters, call your elected officials and ask them for hearings to find out why the FDA is not protect-
ing us from mercury in HFCS.
Also, ask these officials to reintroduce legislation originally proposed by then-Senator Barack Obama
a few years ago that will force the remaining chlorine plants to transition to cleaner technologies.
Because even if they stop providing the caustic soda used for HFCS, their mercury pollution is still
contaminating our food system as it falls on farm fields and waterways.
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Missing Mercury - 6
Introduction
The American diet has changed dramatically over the last generation. In particular, the
prevalence of chemical or synthetic inputs to foods has skyrocketed, as has the quantity of
Introduction
such foods we consume.
TheOne example
American diet is
hasthe substitution
changed of HFCS
dramatically for last
over the table sugar. High
generation. fructosethe
In particular, corn syrup was
prevalence of
chemical or synthetic inputs to foods has skyrocketed, as has the quantity of such
introduced to the American market in 1967, and ever since, consumption has exploded.1foods we consume.
Coca-Cola had transitioned to sweetening its sodas sold in the United States with HFCS
One example is the substitution of HFCS for table sugar. High fructose corn syrup was introduced
instead
to the of table
American sugar
market (sucrose)
in 1967, by 1984;
and ever other
since, its beveragehas
consumption companies
exploded.1quickly
By 1984,followed
Coca-Cola
2
suit. Today, HFCS is found in a stunning array of processed foods: breads,
had transitioned to sweetening its sodas sold in the United States with HFCS instead of table cereals,
sugar
breakfast
(sucrose); bars,
other lunchcompanies
beverage meats, yogurts, soups and
quickly followed condiments,
suit.2
Today, HFCS among many
is found in a others.
stunningIts
ar- a
ray cheap staplefoods:
of processed of thebreads,
industry.
cereals, breakfast bars, lunch meats, yogurts, soups and condiments,
among many others. It is a cheap staple of the industry.
From 1970 to 1990, the rising intake of HFCS far exceeded the change for any other food
From 1970 to 1990, the rising intake of HFCS far exceeded the change for any other food or food
or food group.3 On average, Americans today consume about
group.3 On average, Americans today consume about 12 teaspoons
12 teaspoons per day of
per day of HFCS, accounting for
1
HFCS, accounting
approximately for approximately
1 in 10 calories. 1 1 in 10 calories.
Such
Such a rapid
a rapid transformation
transformation in the American
in the American diet raisesdiet raises questions:
important importantWhat
questions:
are the What are the
potential
potential
health impactshealth impacts
of HFCS of HFCSWhat
consumption? consumption? What
exactly is HFCS andexactly is HFCS
where does and
it come where
from? Anddoes it
what additional
come from?risks
Andtowhat
consumers may stem
additional risksfrom the industrialized
to consumers processes
may stem frombythe
which HFCS is
industrialized
made and used?
processes by which HFCS is made and used?
HFCSconsumption
HFCS Consumption
HFCS is used
HFCS primarily
is used for sweetened
primarily beveragesbeverages
for sweetened like soda.4 like soda.4 Abottle
A 20-ounce of Coca-Cola
20-ounce hasCoca-
bottle of
about 17 teaspoons worth. Its reasonable 5to assume that many Americans largely consume their
5
Cola has about 17 teaspoons worth. Its reasonable to assume that many Americans
HFCS in the form of sweetened beverages.
largely consume their HFCS in the form of sweetened beverages.
The average American drank 37 gallons of carbonated, non-diet soft drinks in 2004, but averages
The
mask theaverage American
fact that specific drankcan
age groups 37ingest
gallons of carbonated,
much higher levels.6non-diet soft drinks in 2004, but
averages mask the fact that specific age groups can ingest much higher levels.6
According to Liquid Candy, a report by the Center for Science in the Public Interest, Children start
drinking soda atto
According a remarkably youngaage,
Liquid Candy, and by
report consumption
the Center increases through
for Science inyoung adulthood.
the Public One-
Interest,
fifth of one- and 2-year-old children consume soft drinks. Almost half of children ages 6 to 11 drank
Children start drinking soda at a remarkably young age, and consumption increases
soda in 1994-96, averaging 15 ounces per day.5 Thats the equivalent of over 42 gallons annually.
through young adulthood. One-fifth of one- and 2-year-old children consume soft drinks.
Almost halfdrink
Teenagers of children agesas6well.
a lot of soda to 11 drank boys,
Teenage soda ages
in 199496,
13 to
5
averaging 15 ounces
18, who drink per day.
soda average Thatsthree
an estimated the equivalent
or more cansofa over
day
42 gallons
(over annually.
102 gallons annually). One in 20 drinks at least five cans per
day (over 171 gallons annually).5
Teenagers drink a lot of soda as well. Teenage boys, ages 13
Of 13- to 18-year-old girls who drink soda, average intake is a
tolittle
18,less
who drink soda average an estimated three or more cans
than two cans a day (about 68 gallons annually), and 5
apercent
day (over 102 drink
of them gallons annually).
more than threeOne
cansin 20 drinks
a day (over at least
102 gal-
5
five cans per
lons annually).day
5 (over 171 gallons annually).
Of 13 to
These 18-year-old
data exclude thegirls who drink
substantial amountssoda, average intake
of sweetened non- is a
carbonated drinkse.g., sports drinks, synthetic fruit beverages,
little less than two cans a day (about 68 gallons annually), and
5 energy
percentdrinks, and so onalso consumed by kids, and typically
of them drink more than three cans a day (over 102
containing zero 5to just 10 percent fruit juice.
gallons annually).
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P 5
These data exclude the substantial amounts of sweetened noncarbonated drinkse.g.,
sports drinks, synthetic fruit beverages, energy drinks, and so onalso consumed by
kids, and typically containing zero to just 10 percent fruit juice.
1
In In
1967,
1967,table sugarconstituted
table sugar constituted 86 percent
86 percent of sweeteners
of caloric caloric sweeteners consumed.
consumed.1 From From 1967
1967 to 2005,
to American
2005, American
consumption consumption of caloric sweetenersHFCS,
of caloric sweetenersHFCS, honey
honey and edible syrups andmaple
(molasses, edible syrups
(molasses, maple syrup), as well as table sugarwent1 up 24 percent, to justyear.
syrup), as well as table sugarwent up 24 percent, to just over 141 pounds per person per over 141
Just
about the entire rise is due to HFCS, nonexistent prior to 1967. Table sugar consumption actually
pounds
dropped
per person per year. Just about the entire rise is due to HFCS, nonexistent prior to
over that time.1
1967. Table sugar consumption actually dropped over that time.1
1
Figure 1: HFCS vs.1:Table

Figure HFCS Sugar (Sucrose)
vs. Table Consumption
Sugar (Sucrose) Consumption
500
450
y Total HFCS + Sugar
a
D 400
er
P
de 350
m
us 300
no
C 250 Sugar
se
ir
loa 200
C
150
HFCS
100
50
0
1970 1975 1980 1985 1990 1995 2000
Source: Data from USDA ERS Briefing Room: Sugar and Sweeteners: Data Tables . Available at
http://www.ers.usda.gov/Briefing/Sugar/. Graphic created by IATP.
By 2007, the average American consumed an estimated 40 lbs (dry weight) of HFCS each year
roughly 50 grams, or about 12 teaspoons worth each day.7 The USDA derives this estimate from data
it collects on the total yearly production of sweeteners, including HFCS.
By 2007, the average American consumed an estimated 40 lbs (dry weight) of HFCS each
yearroughly 50 grams,
Using data on fructose or about
consumption 12 teaspoons
patterns worth
from more than each
21,000 day.7 The
American adultsUSDA derives this
and children
estimate
collectedfrom
as partdata itthird
of the collects on Health
National the total
and yearly production
Examination of sweeteners,
Survey (NHANES), we also including
calculate
HFCS.
that adolescents and young adults consume significantly more HFCS than average. As reflected in
Figure 2, American 19- to 30-year-olds consume about 60 grams of HFCS per day. For 12- to 18-year-
olds, HFCS consumption is about 70 grams, or 40 percent more than a 50 gram per day average.8
Using data on fructose consumption patterns from more than 21,000 American adults and
children collected as part of the third National Health and Examination Survey
(NHANES), we also calculate that adolescents and young adults consume significantly
more HFCS than average. As reflected in Figure 2, American 19- to 30-year-olds
consume about 60 grams of HFCS per day. For 12 to 18-year-olds, HFCS consumption is
about 70 grams, or 40 percent more than a 50 gram per day average. 8
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Figure 2: Estimates of Average Daily HFCS Consumption, by Age Grouping

80
70
60
50

Grams
40
30
20
10
0
2-5 yrs 6-11 yrs 12-18 yrs 19-30 yrs 31-50 yrs 51-70 yrs >70 yrs
Adapted from data from Tables 1 and 3 in Vos M, Kimmons J, et al. Dietary fructose consumption among
US children and adults: The third national health and nutrition examination survey. Medscape J Med. 2008.
Figures assume: 1) 60% of fructose came from HFCS; 2) a 50% fructose/50% glucose combination in HFCS
as a conservative measure; 3) calculation of HFCS content excludes fruit, fruit juices and vegetables.
Those 37 gallons of carbonated, non-diet soft drinks the average American consumed in 2004 con-
tained approximately 60,000 calories. The additional 16 gallons of fruit and sport drinks consumed
brings the total to about 85,000 calories.1 Many, if not most, are sweetened with HFCS.
Average HFCS intake translates to around 200 calories per day, or approximately 10 percent of the
calories in the diet.5 Higher-end HFCS consumers easily exceed 300 calories in daily HFCS calories.
A recent survey of all the undergraduates at one college found they consumed an average of 543
calories worth of sweetened beverages per day, with the average African-American student ingesting a
staggering 796 calories per day.9
Where is HFCS found?
In 2004, HFCS represented more than 40 percent of all caloric sweeteners added to beverages and foods.10
HFCS is a mixture of the common carbohydrates, fructose and glucose. The beverage industry alone
uses roughly 60 percent of HFCS suppliesthe vast majority of non-diet drinks are sweetened with
HFCS. HFCS-55, the kind used by soft drink companies, is approximately 55 percent fructose and
45 percent glucose. By comparison, common table sugar (sucrose) is 50 percent fructose and 50
percent glucose.
The other 40 percent of HFCS supplies are used in food production, by commercial bakeries, fruit and
vegetable canners, makers of candy, ice cream, yogurt and other dairy products, and fast food com-
panies. At fast food restaurants, the salad dressings, sauces, buns, shakes, pies, rolls, breads, desserts,
muffins and cookies all contain HFCS. Typically, they use HFCS-42, which is approximately 42 percent
fructose and 58 percent glucose.
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Why do food manufacturers use HFCS?

The sweetener industry claims a preference for HFCS due to its ability to help preserve foods, retain
moisture and enhance other flavors.11 For instance, because our taste buds detect the sweetness of
HFCS early, and that sweetness doesnt linger, its incorporation into salad dressings helps to mellow
the acid bite of vinegar while allowing the mouth to experience the fruity and spicy flavors of other
ingredients more clearly.
Table 1: U.S. HFCS Consumption by Type of User Industry Dufault et al., and the
Corn Refiners As-
(thousand short tons)
sociation report that
Industry 2002 Percent HFCS is also used as a
Beverages (mostly soft drinks) 5270.2 57.0 sweetener to enhance
product shelf lifein
Canned, bottled, and frozen foods 685.7 7.0 other words, as a pre-
Bakery, cereals and allied products 513.1 6.0 servative.11, 12 It is not
known exactly how
Ice cream and dairy products 258.5 3.0
HFCS acts to preserve
Confectionery and related products 83.0 1.0 the color and texture
Total 9294.0 of canned fruits or ap-
plesauce to promote
Source: Beghin JC, Jensen HH. Farm policies and added sugars in
freshness or to inhibit
US diets. Working Paper 08-WP 462. 2008. Iowa State University.
microbial spoilage and
Calculated from U.S. Census Bureau data available as of February 2008.4
extend shelf life.
Under U.S. federal law, chemicals added to foods as preservatives are supposed to be FDA-approved
for that purpose. Even though the industry highly touts and markets HFCS preservative qualities, it
carries no such approval. That is because in 1996 the FDA determined that HFCS is Generally Rec-
ognized As Safe (GRAS). The GRAS designation basically says that although a food ingredient hasnt
been completely studied or tested for safety, the FDA a priori considers it to be safe, putting the onus
instead on the public to somehow marshal evidence after the fact that consumers have been harmed
by it.
The FDAs regulations provide that GRAS ingredients must be reexamined in light of new scientific
information.13 The FDA has been petitioned with no response to reconsider HFCS status as GRAS,
given the building evidence of its health impacts.14
HFCS and mercury

Most attention to HFCS lately, whether in the news or in the scientific literature, has been around
its potential contribution to obesity and other diet-related disease. Increased consumption of calo-
ries has been a major driver of the obesity epidemic. This report deals with another health concern
entirely: mercury contamination.
Just published in the peer-reviewed scientific journal, Environmental Health, is the bombshell that
commercial HFCS appears to be routinely contaminated with mercury.12 It turns out the contamina-
tion isnt so much accidental as newly recognized, given the fact that much HFCS has been made
and continues to be made using mercury-grade caustic soda.
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Caustic soda produced by a mercury cell process is contaminated with 0.2 to 0.3 parts per million
(ppm) of mercury,15 and perhaps as much as 1 ppm, in some cases.16 Much HFCS is produced using
exactly this same mercury-grade caustic soda. Mercury contamination of soft drinks or drink mixes
made from this caustic soda was acknowledged by the National Association of Clean Water Agencies
as early as 2000.17
Other common food ingredients derived from mercury cell chlor-alkali plants include citric acid and
sodium benzoate, a food preservative found in many foods also containing HFCS. To our knowl-
edge, these ingredients have not yet been tested for mercury contamination.
Other common household products made from caustic soda also may be contaminated with low ppb
levels of mercury, including shampoo, toilet tissue, bleach and toothpaste.17
What is mercury-grade caustic soda?

Chlorine is a chemical building block used to make everything from vinyl blinds to lye. Since 1884,
one process for producing chlorine has been to pump brine or saltwater through a vat of mercury,
also known as a mercury cell. These mercury cell chlor-alkali plants average 56 mercury cells each,
with as much as 8,000 pounds of mercury per cell.12 Today, the chlorine industry remains the largest
intentional consumer (end user) of mercury.
The mercury in the plants is supposedly left behind and reused. But in fact mercury is highly volatile,
and it is undisputed that contamination occurs throughout the process. These plants make not only
chlorine, but a number of other products as well, including caustic soda (lye), sodium hypochlorite
(bleach) and hydrochloric acid. Both the products of chlorine plants and the wastewater stream end
up containing mercury residues.
Newer technology exists for making chlorine without mercury. In 2005, for example, 90 percent
of U.S. chlorine production, but just 40 percent of European production, used membrane cell or
diaphragm cell technology instead of mercury cells; 53 mercury cell chlor-alkali plants operate in the
European Union.18 Caustic soda destined for HFCS manufacture comes from either mercury cell or
membrane cell plants, located in the U.S. or abroad.
Four chlor-alkali plants in the U.S. still rely on mercury cell technology. They are run by Olin
Corporation, at two plants in Augusta, Ga., and Charleston, Tenn., Ashta Chemicals in Ashtabula,
Ohio, and PPG Industries in New Martinsville, W. Va.19,20 The Port Edwards, Wis., plant operated by
ERCO Worldwide is in the process of converting to mercury-free technology.21
A longtime enigma of these plants has been their missing mercury.22 The nine mercury cell plants
operating in 2003 reported consuming 38 tons of mercury, but emitting just eight tons into the
environment. What happened to the other 30 tons? The plants cannot account for it.22,23 The five
mercury cell plants still in operation reported emitting more than 3,300 pounds of mercury into the
environment in 2005.20 Their unreported emissions of lost or missing mercury are likely to be far
greater. One estimate is that unmonitored mercury releases from chlor-alkali plants may be nine times
greater than the monitored emissions.20
Where does this missing mercury go? As mercury volatilizes during routine operations, it may end
up in the plants infrastructure, or on the grounds.24 Since 1965, approximately 32 chlor-alkali plants
have closed in the U.S. and of those sites, 14 are now Superfund sites and 27 are undergoing feder-
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ally directed corrective action.23 This months Environmental Health study suggests that additional
tons worth of missing mercury may end up as impurities in the plants products, including those like
caustic soda that are added to the food supply.
This finding only adds to the already compelling argument for eliminating mercury from chlor-alkali
plants once and for all. In addition to avoiding mercury contamination of the environment and
the food supply, newer technologies are more efficient. A report from the nonprofit organization,
Oceana, notes:
Although the cost of converting to mercury-free technology runs in the millions of dollars
(as detailed in the report), analysis shows the majority of costs would be recovered within five
years from energy savings, increased capacity and eliminating millions of dollars in mercury-
related fines, upgrades and treatment costs. Plants that have shifted see increases in energy
efficiency between 25 and 37 percent. Since electricity can make up half of total production
costs, this can vastly improve profitability. Many plants also have increased production capac-
ity by approximately 25 percent in the process of converting to mercury-free technology.20
How is HFCS produced?

HFCS is synthesized in a highly specialized, industrial process using a number of enzymes and other
inputs.2 Either membrane-grade or mercury-grade caustic soda can be used. At the beginning of the
process, caustic soda helps separate the corn starch from the corn kernel. Along with hydrochloric
acid, it also is used throughout the process to maintain a pH balance.
Mercury-contaminated caustic soda can contaminate whatever food or other products are made from
it, like HFCS. Indirectly, it also can contaminate the final food products to which HFCS is added.
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Figure 3: Synthesis of High Fructose Corn Syrup
Corn processors / refiners

Corn kernal
Corn wet milling
Starch
Hydrolysis Polysaccarides
Glucose
Isomerization
HFCS manufacturers
42% Fructose
90% Fructose
Back blending 55% HFCS
Corn processors, like ADM or Cargill, separate the cornstarch from the kernel. Cornstarch is con-
verted into corn syrup through a process called acid hydrolysis. The wet starch is mixed with weak
hydrochloric acid, pressurized and heated to help break down the starch molecules. A genetically
modified enzyme, alpha-amylase, breaks the starch into shorter chains of sugar called polysaccha-
rides. (After this stage, corn processors typically ship the starch to HFCS manufacturers.)
HFCS manufacturers then treat the starch (polysaccharides) using another genetically modified
enzyme, glucoamylase, resulting in glucose. The mixture is passed over columns of a third en-
zyme, converting a portion of the glucose into fructose. The result is HFCS, which is comprised
of approximately 42% fructose, 52% glucose, and 6% higher saccharidesknown as HFCS-42.
Caustic soda is used for various reasons throughout the process.
A separate process can boost fructose content to 90% HFCS. Then, back blending with the
original 42% mixture can yield syrups with 55% fructose, also known as HFCS-55. This was the
mixture adopted by the carbonated beverage industry beginning in 1984.
Mercury and public health

Mercury is a heavy metal with the potential to damage many organ systems, including the heart, im-
mune and nervous systems. Mercury is toxic in all of its various forms.
The very young are especially vulnerable. When babies are exposed to elevated methylmercury in the
womb, their brains may develop abnormally, impairing learning ability and reducing IQ. Children are
thought to be at risk for these effects even at the levels of methylmercury exposure currently found
in the population. Thats why for many years there have been fish advisories recommending young
children and women of childbearing age in particular to limit consumption of fish species known to
have elevated methylmercury.27
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Just like with environmental lead, methylmercury exposure levels considered safe for the very
young have continued to fall as scientists have gotten better at measuring long-term effects. Its not
that mercury has become less safe, we have just become a lot smarter about mercury.
Recent evidence suggests that perhaps no developmental exposure to methylmercury can be con-
sidered safe, because of the sensitivity of the developing brain.27 Mercury contamination of the food
supply, therefore, is especially concerning since a mothers diet can deliver mercury during critical
phases of brain development directly to the fetus via the placenta, or to the infant via breast milk.
In the Environmental Health report, Dufault et al. found among 20 samples of commercial HFCS de-
tectable levels of total mercury ranging from below a detection limit of 0.005 to 0.570 micrograms
mercury per gram of high fructose corn syrup. Nine of the samples had measurable total mercury.
Using the USDAs estimate of 50 grams of average consumption HFCS per day, one might roughly
estimate potential total mercury ingestion via HFCS of up to 28.5ug total mercury/day (50 grams
HFCS X 0.570 ug/g). Using these same assumptions, high-end HFCS consumers potentially could
have much higher total mercury ingestion.
It is difficult to know to what to compare this figure. The EPA has established a reference dose, or
maximum recommended dietary intake of methylmercury. Methylmercury is the form typically found
in fish and seafood. The reference dose of 0.1 ug/kg/day applies to women of childbearing age and
young children, who are thought to be the most at risk from methylmercury exposure. For the aver-
age 55 kg American woman, this would translate into no more than 5.5ug/day of methylmercury.
There is no reference dose for total mercury. The mercury found in HFCS may be a different form of
mercury than the methylmercury typically found in fish (we just dont know), but it poses a risk just
the same. Mercury in any form can be toxic to the developing brain.28
And whatever the source or species, mercury can accumulate in the brain or other tissues of the body,
causing cumulative impacts over time. Contamination of HFCS with total mercury therefore adds to an
already existing problem of methylmercury exposure from seafood consumptionan exposure estimat-
ed to put hundreds of thousands of fetuses every year at risk of harm from their mothers exposure.27
Americans daily ingestion of HFCS also means that mercury exposures will happen routinely and possibly
throughout a persons entire lifetime, beginning pre-conception and continuing in utero and onwards.
Why we tested brand-name foods for mercury

From the new Environmental Health report, we know commercial HFCS is often mercury-contami-
nated, but what about the foods and drinks made from it?
Many of these products are specifically marketed to groups vulnerable to mercury. Soft drinks, fruit
juices, and other junk food are successfully marketed to children not only through Internet and televi-
sion advertising,29 but also in school vending machine and cafeteria options.30 People who rely on food
stamps or who live in lower socioeconomic neighborhoods are also a special target for junk food manu-
facturers, because they offer the most accessible and often least expensive calories in the grocery store.31
P 12
Given the FDAs silence on the issue, we set out to do the nations first public testing of national
food brands that use HFCS for the presence of mercury.
We scouted supermarket shelves, looking both for manufactured foods and beverages marketed
heavily to children as well as for products with HFCS as the first or second labeled ingredient. While
manufacturers are not required to list the exact HFCS (or any other ingredients) composition in
food, they do need to list them in order of volume.
We tested products from some of Americas leading food companies: Kraft, Hersheys, Hunts,
Smuckers, General Mills, Coca-Cola and so on. We sent their sodas, flavored milks, syrups, dressings
and other products off to a commercial lab. The methodology and complete results are summarized
in the Appendix.
Our laboratory analyzed for total mercury (not methylmercury). The samples we tested contained
levels of total mercury ranging from below the limit of detection (LOD)which ranged from 20-
100 parts per trillion (ppt), depending on the nature of the sample and the processes the laboratory
went through to adequately prepare itto a high of 350 ppt.
Overall, we found detectable mercury in 17 of 55 samples, or around 31 percent. Quality control

measures by the laboratory meant that some items in which initially there was no detectable mercury
on re-analysis were found to have mercury above the LOD. If the latter would have been included
our results, we would have found detectable mercury in a total of 20 of 55 samples, or 36 percent.
Table 2. No. of Samples No. with detectable Mercury detected

mercury (above LOD)
Beverages 19 3 15.8%
Dressings and condiments 10 4 40.0%
Dairy products* 5 3 60.0%
Snacks and desserts 8 3 37.5%
Soups and entrees 3 1 33.3%
Syrups and jellies 10 3 30.0%
Total 55 17 30.9%
* Two of three dairy products with detectable mercury were chocolate milk, which also could easily be categorized as beverages.
Mercury was most prevalent in HFCS-containing dairy product samples, followed by dressings and
condiments and then snacks and desserts. The lowest prevalence of mercury detects was among the
19 beverages sampled. Two of the three dairy products with detectable mercury were chocolate milk.
If these had been included instead in the beverage category, that latter category would have had a
prevalence of detectable total mercury of 26 percent.
P 13
Table 3 indicates the food products for which total mercury was detected, highest to lowest.
Table 3.
Product Name Total Mercury Limit of Detection (ppt)
Quaker Oatmeal to Go 350 80
Jack Daniels Barbecue Sauce (Heinz) 300 100
Hersheys Chocolate Syrup 257 50
Kraft Original Barbecue Sauce 200 100
Nutri-Grain Strawberry Cereal Bars 180 80
Manwich Bold Sloppy Joe 150 80
Market Pantry Grape Jelly 130 80
Smuckers Strawberry Jelly 100 80
Pop-Tarts Frosted Blueberry 100 80
Hunts Tomato Ketchup 87 50
Wish-Bone Western Sweet & Smooth Dressing 72 50
Coca-Cola Classic 62 50
Yoplait Strawberry Yogurt 60 20
Minute Maid Berry Punch 40 30
Yoo-hoo Chocolate Drink 30 20
Nesquik Chocolate Milk 30 20
Kemps Fat Free Chocolate Milk 30 20
Of course, our survey was just a snapshot in time; we tested only one sample of each product.
That is clearly not sufficient grounds to give definitive advice to consumers on specific products.
In other words, our efforts were never intended to take the place of full-scale safety testing by the
FDA. But to us they do suggest a strong need for it, since Americans (and American children in par-
ticular) consume an awful lot of HFCS-containing products. Its a big chunk of their diet. That, plus
the simple fact that adding mercury-containing HFCS to the food chain appears completely avoid-
able, makes this an issue worthy of much more attention.
P 14
Conclusion
Consumption of so many calories in sweeteners added to foods carries its own, well-recognized risks.
This report raises a separate, newly recognized problem when those calories come from HFCS. The
long-term use of outdated mercury cell technology for making caustic sodaa key ingredient in HFCS
productionhas contaminated the food supply with an additional, preventable source of mercury.
In our own limited testing, we could detect mercury in about one of every three common foods or
beverages where HFCS was the first or second labeled ingredient. Many of these foods are heavily
marketed to children, who in turn are among those most vulnerable to mercurys toxic effects.
We know mercury is toxic in all its forms. We also know there are safer, readily available alternative
ways to produce HFCS. And, despite the industrys reliance on mercury-grade ingredients, and the
FDAs reluctance to make the public aware of this fact, we know there is a public health imperative to
better protect our food and beverages from this unnecessary contaminant.
Recommendations for industry
Our simplest recommendation: Stop using mercury cell technology. It is an outdated method. Mercury
cells are not necessary to make caustic soda.
Well over 100 chlor-alkali facilities worldwide have mothballed mercury cell technology since the
1970s. Though significant, most conversion costs can be recovered within five years.32
In the U.S., four plants remain uncommitted to phasing out mercury cell technology. Caustic soda
from these and other mercury cell plants overseas could continue to be used to manufacture the
HFCS destined for foods and beverages sold to Americans.
Another immediate solution: Manufacturers of HFCS and other foods should simply discontinue using
mercury-grade ingredients.
In addition, concerned food manufacturers could use readily available, and perhaps safer, alternatives
to HFCSlike table sugar. Coca-Colas sodas sold in Mexico are made using sugar (their Mexican
facilities never made the transition to HFCS). Companies selling in the U.S., such as Jones Soda Co.,
have started using cane sugar in place of HFCS in their drinks.
Moreover, as sales of organic food continue to rise in the United States and globally, the array of
retail food products will contain a smaller percentage of HFCS. The organic beverage market grew
from $23 million in 2002 to $40 million in 2006, and sales have grown by 17 percent to 20 percent
per year over the past few years.33 This may account for some of the recent decline in HFCS produc-
tion and consumption. In addition, publicity around public health concerns with HFCS, as well as
epidemics of diabetes and obesity, likely also play a role.
On the other hand, in economic terms HFCS and table sugar may no longer be considered substi-
tutes for one another. Thats because current technology in corn wet milling, as well as in food pro-
cessing generally, has become highly specialized and specific to HFCS over the last few decades. The
changes that would have to take place in logistics, infrastructure and technology for the soft drink
industry to revert to using cane sugar instead of HFCS, for example, are significant and costly.34
P 15
Policy recommendations
1. Phase out mercury cell technology. Other countries, including Japan, have already banned the
mercury cell chlor-alkali process. In 2007, then-Senator Barack Obama sponsored S. 1818, the
Missing Mercury in Manufacturing Monitoring and Mitigation Act.35 If passed, the legislation
would phase out the remaining mercury cells in use in the U.S. by January 2012.
2. Ban the use of mercury-grade ingredients in food and beverages. The FDA should ban
mercury-grade caustic soda for food uses, given non-mercury alternatives. Pending that,
any food containing HFCS ought to be labeled so as to identify whether the HFCS was
manufactured using mercury-grade ingredients.
3. In light of its mercury contamination, the FDA should revisit its on-again, off-again
approval of HFCS as natural and Generally Recognized As Safe (GRAS). According to
a 1997 FDA statement, the proponent of an exemption from the definition of a food additive
has the burden of proving that the use of the substance is generally recognized as safe. HFCS
manufacturers should be required to have their products independently and publicly tested for
mercury to assess potential human exposure levels.
Personal recommendations
For consumers, the simplest solution for now may be to avoid foods containing HFCS, particularly
when its high on the label.
Even if U.S. chlor-alkali plants discontinue using the mercury-based process, there are other plants
worldwide that still do and they export to the United States. American consumers are still likely to
eat food products containing HFCS that may be contaminated with mercury from these plants.
Beyond this fact, HFCS content, particularly high on the label, is a signal for a highly processed
food high in added sweeteners (and therefore calories), and often high in added fats as well. Parents
instead ought to be preferentially serving children whole, unprocessed foods.
Reduce other sources of mercury exposure to your kids, including dental amalgam and consumption
of fish species known to contain mercury. Use IATPs Smart Fish Guide to learn more about safer
fish consumption at: www.healthobservatory.org.
P 16
Appendix
In the fall of 2008, IATP purchased 55 branded food products, many of them marketed to children,
with the purpose of testing them for contamination with mercury. The food products selected
sodas, other sweetened beverages, syrups, dressings, snack foods and otherswere ones where HFCS
was listed as the first or second labeled ingredient. While food manufacturers are not required to list
the exact ingredient composition, they do need to list them in order of volume.
Food Product Product Type

7-Up Beverage
A & W Root Beer Beverage
Aunt Jemima Original Syrup Syrup
Campbells Tomato Soup Soup
Coca-Cola Classic Beverage
Dr. Pepper Beverage
Fanta Orange Beverage
Hawaiian Punch Fruit Juicy Red Beverage
Heinz Hotdog Relish Condiment
Heinz Tomato Ketchup Condiment
Hersheys Caramel Syrup Syrup
Hersheys Chocolate Syrup Syrup
Hersheys Strawberry Syrup Syrup
Hi-C Wild Cherry Beverage
Hunts Tomato Ketchup Condiment
Hy-Top Syrup Syrup
Jack Daniels Barbecue Sauce (Heinz) Condiment
Jell-O Strawberry Snack
Kemps Fat Free Chocolate Milk Dairy
Kool-Aid Bursts Tropical Punch Beverage
Kool-Aid Cherry Jammers Beverage
Kraft Original Barbecue Sauce Condiment
Land O Lakes Chocolate Milk Dairy
Lipton Green Tea Beverage
Manwich Bold Sloppy Joe Entre
Market Pantry Applesauce Snack
Market Pantry Cranberry Sauce Condiment

Market Pantry Grape Jelly Jelly
Market Pantry Ice Pops Dessert
Market Pantry Thousand Island Dressing Dressing
Market Pantry Tomato Soup Soup
Minute Maid Berry Punch Beverage
Motts Applesauce Snack
Mrs. Butterworth Original Syrup Syrup
Nesquik Chocolate Milk Dairy
Nesquik Strawberry Milk Dairy
NOS High Performance Energy Drink Beverage
Nutri-Grain Strawberry Cereal Bars Snack
Ocean Spray Cranberry Sauce Condiment
Pepsi Beverage
Pop-Tarts Frosted Blueberry Snack
Powerade Orange Beverage
Quaker Oatmeal to Go Snack
Smuckers Strawberry Jelly Jelly
Smuckers Strawberry Syrup Syrup
Snapple Peach Iced Tea Beverage
Sunny-D Beverage
Tropicana Twister Cherry Berry Blast Beverage
Welchs Grape Jelly Jelly
Wish-Bone Thousand Island Dressing Dressing
Wish-Bone Western Sweet & Smooth Dressing Dressing
Wylers Italian Ices Dessert
Yoo-hoo Chocolate Drink Beverage
Yoplait Strawberry Yogurt Dairy
Zoo Juice Orange Beverage
P 17
We collected products from some of Americas leading food companies: Kraft, Hersheys, Coca-
Cola, and so on. We sent them off to a commercial food and chemistry laboratory, Bodycote Testing
Group (www.Bodycotetesting.com) of Santa Fe Springs, California. The laboratory performs analyses
for total mercury using atomic fluorescence (AF) spectroscopy.
In the Leeman Labs Hydra AF Gold Plus system, mercury is determined using the traditional cold
vapor technique coupled with dual AF detectors. The system is compliant with EPA Methods 1631
and 245.7. Advantages to this method include extremely low detection limits in the part per trillion
range, and a wide dynamic range (ppm to sub-ppt). The laboratory received the food and beverage
samples with chain-of-custody intact. Preparation of the samples for analysis differed depending on
the kind of food item. Subsamples were digested with weakly acidic solutions of aqua regia, or 4:1
HCl/HNO3), with some samples undergoing additional digestion using a solution of 30 percent
hydrogen peroxide. Blanks were run using these same preparations so as to ensure that any mercury
detections were not due to the reagents used.
After digestion, samples underwent total mercury analysis using Cold Vapor Atomic Fluorescence
(CVAF). The detection limits varied for different laboratory runs of the food products, depend-
ing on the characteristics of the food item (e.g., carbonation, viscosity, etc.), and the preparation and
dilution needed.
For each of the individual products tested, the following tables list the limit of detection calculated
for that item, followed by total mercury (Hg) detected in that sample. ND refers to a non-detectable
level, meaning that if there was mercury present, it could be below the limit of detection.
P 18
Beverages Limit of detection (ppt) Total Hg detected (ppt)

7-Up 30 ND
A & W Root Beer 30 ND
Coca-Cola Classic 50 62*
Dr. Pepper 30 ND
Fanta Orange 30 ND
Hawaiian Punch Fruit Juicy Red 50 ND
Hi-C Wild Cherry 30 ND
Kool-Aid Bursts Tropical Punch 30 ND
Kool-Aid Cherry Jammers 30 ND
Lipton Green Tea 30 ND
Minute Maid Berry Punch 30 40
NOS High Performance Energy Drink 50 ND
Pepsi 30 ND
Powerade Orange 30 ND
Snapple Peach Iced Tea 30 ND
Sunny-D 30 ND
Tropicana Twister Cherry Berry Blast 30 ND
Yoo-hoo Chocolate Drink 20 30
Zoo Juice Orange 30 ND
* Retesting of this result, for quality control purposes, revealed a ND result
Dressings and condiments Limit of detection (ppt) Total Hg detected (ppt)

Heinz Hotdog Relish 100 ND
Heinz Tomato Ketchup 100 ND
Jack Daniels Barbecue Sauce (Heinz) 100 300
Hunts Tomato Ketchup 50 87
Kraft Original Barbecue Sauce 100 200
Market Pantry Cranberry Sauce 100 ND
Market Pantry Thousand Island Dressing 100 ND
Ocean Spray Cranberry Sauce 100 ND
Wish-Bone Thousand Island Dressing 100 ND
Wish-Bone Western Sweet & Smooth Dressing 50 72
P 19
Dairy Limit of detection (ppt) Total Hg detected (ppt)

Kemps Fat Free Chocolate Milk 20 30
Land OLakes Chocolate Milk 20 ND
Nesquik Chocolate Milk 20 30
Nesquik Strawberry Milk 20 ND
Yoplait Strawberry Yogurt 20 60
Snacks and Desserts Limit of detection (ppt) Total Hg detected (ppt)

Jell-O Strawberry 100 ND
Market Pantry Applesauce 100 ND
Market Pantry Ice Pops 30 ND
Motts Applesauce 100 ND
Nutri-Grain Strawberry Cereal Bars 80 180
Pop-Tarts Frosted Blueberry 80 100
Quaker Oatmeal to Go 80 350
Wylers Italian Ices 30 ND
Soups and Entres Limit of detection (ppt) Total Hg detected (ppt)

Manwich Bold Sloppy Joe 80 150
Campbells Tomato Soup 100 ND
Market Pantry Tomato Soup 100 ND
Syrup & jellies Limit of detection (ppt) Total Hg detected (ppt)

Aunt Jemima Original Syrup 100 ND*
Hersheys Caramel Syrup 100 ND
Hersheys Chocolate Syrup 50 257**
Hersheys Strawberry Syrup 100 ND
Hy-Top Syrup 50 ND
Market Pantry Grape Jelly 80 130
Mrs. Butterworth Original Syrup 100 ND
Smuckers Strawberry Jelly 80 100
Smuckers Strawberry Syrup 100 ND
Welchs Grape Jelly 100 ND
* Retesting of this result, for quality control purposes, yielded a result of 51 ppt
** Retesting of this result, for quality control purposes, yielded a result of 209 ppt
P 20
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Environmental Health
This Provisional PDF corresponds to the article as it appeared upon acceptance. Fully formatted
PDF and full text (HTML) versions will be made available soon.
Mercury from chlor-alkali plants: measured concentrations in food product

sugar
Environmental Health 2009, 8:2 doi:10.1186/1476-069X-8-2
Renee Dufault (rdufault@uttc.edu)

Blaise LeBlanc (blaise_ll@hotmail.com)
Roseanne Schnoll (rschnoll@brooklyn.cuny.edu)
Charles Cornett (cornettc@uwplatt.edu)
Laura Schweitzer (schweitl@uwplatt.edu)
Lyn Patrick (lpatrick@frontier.net)
Jane Hightower (jhightowermd@aol.com)
David Wallinga (dwallinga@iatp.org)
Walter Lukiw (wlukiw@lsuhsc.edu)
ISSN 1476-069X
Article type Commentary
Submission date 9 September 2008
Acceptance date 26 January 2009
Publication date 26 January 2009
Article URL http://www.ehjournal.net/content/8/1/2
This peer-reviewed article was published immediately upon acceptance. It can be downloaded,
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which permits unrestricted use, distribution, and reproduction in any medium, provided the original work is properly cited.
Mercury from chlor-alkali plants: measured concentrations in food
product sugar
Renee Dufault*1, Blaise LeBlanc2, Roseanne Schnoll3, Charles Cornett4, Laura Schweitzer4,
David Wallinga5, Jane Hightower6, Lyn Patrick7, Walter Lukiw8
1
United Tribes Technical College, Bismarck, ND, USA
2
Carl Hayden Bee Research Center, Tucson, AZ, USA
3
Department of Health and Nutrition Sciences, Brooklyn College of CUNY, Brooklyn, NY, USA
4
Department of Chemistry and Engineering Physics, University of Wisconsin-Platteville,
Platteville, WI, USA
5
Institute for Agriculture and Trade Policy, Minneapolis, MN, USA
6
Department of Internal Medicine, California Pacific Medical Center, San Francisco, CA, USA
7
Contributing Editor, Alternative Medicine Review, Durango, CO, USA
8
Professor of Neuroscience and Ophthalmology, LSU Neuroscience Center. Louisiana State
University Health Sciences Center, New Orleans, LA, USA
Email:
Renee Dufault*- rdufault@uttc.edu; Blaise LeBlanc - blaise_ll@hotmail.com; Roseanne Schnoll
rschnoll@brooklyn.cuny.edu; Charles Cornett - cornettc@uwplatt.edu; Laura Schweitzer -
schweitl@uwplatt.edu; David Wallinga - dwallinga@iatp.org; Jane Hightower -
jhightowermd@aol.com; Lyn Patrick - lpatrick@frontier.net; Walter Lukiw -
wlukiw@lsuhsc.edu
*
Corresponding author
Abstract
Mercury cell chlor-alkali products are used to produce thousands of other products
including food ingredients such as citric acid, sodium benzoate, and high fructose corn
syrup. High fructose corn syrup is used in food products to enhance shelf life. A pilot
study was conducted to determine if high fructose corn syrup contains mercury, a toxic
metal historically used as an anti-microbial. High fructose corn syrup samples were
collected from three different manufacturers and analyzed for total mercury. The samples
were found to contain levels of mercury ranging from below a detection limit of 0.005 to
0.570 micrograms mercury per gram of high fructose corn syrup. Average daily
consumption of high fructose corn syrup is about 50 grams per person in the United
States. With respect to total mercury exposure, it may be necessary to account for this
source of mercury in the diet of children and sensitive populations.

Background
Chlorine and caustic soda are produced at chlor-alkali plants using mercury cells
or the increasingly popular membrane technology that is mercury free and more energy-
efficient. Worldwide there are approximately fifty mercury cell chlor-alkali plants in
operation [1]. Of those there are eight in the United States (US) [2]. In 2003 the EPA
reported in the Federal Register that on average approximately seven tons of mercury
were missing from each plant in the year 2000 [3]. These chlor-alkali plants have an
average of fifty-six cells, each containing as much as 8,000 pounds of mercury [4] and,
every year the chlor-alkali industry reports unaccounted for mercury losses to the EPA
[5]. Mercury is a danger to unborn children whose developing brains can be damaged if
they are exposed to low dose microgram exposures in the womb [6]. Since mercury is a
potent neurological toxin, these unaccounted for mercury losses from the chlor-alkali
industry are of concern as they could be a source of exposure for humans, wildlife, and
the environment. An Environmental Health Officer (EHO) at the Food and Drug
Administration (FDA) conducted an investigation to find the missing mercury in the
chlor-alkali industry [7].
The path of the investigation
An employee of the Environmental Protection Agency (EPA) suggested that the
EHO contact the Wisconsin Department of Natural Resources (DNR) for information on
Vulcan Chemicals mercury balance sheet. Vulcan Chemical was the only chemical
company to find its missing mercury. Upon request, the Wisconsin DNR provided the
EHO with Vulcan Chemicals annual mercury balance sheet that reported their mercury
losses in their products for the year that the mercury balance was done. Vulcan Chemical
submitted this mercury balance sheet to the Wisconsin DNR in 2003 with their
wastewater discharge permit re-issuance application. This information led to the
realization that mercury residue may be found in all products produced by the mercury
cell chlor-alkali industry. A representative of the Chlorine Institute confirmed in a
telephone interview that the amount of mercury residue in mercury cell chlor-alkali
products varies, depending on the manufacturing process at each plant. It is found in
mercury grade caustic soda according to product specification sheets [8].
According to an archived web page report initially produced by Vulcan
Chemicals, mercury grade caustic soda and hydrochloric acid are primarily used by the
high fructose corn syrup industry [9]. Following this lead, the EHO conducted an
interview with an organic producer of high fructose corn syrup (HFCS) in 2004 and
was told that the HFCS industry uses both mercury grade caustic soda and membrane
grade caustic soda in their manufacturing process to enhance product shelf life. A review
of the literature revealed that HFCS is indeed used as a sweetener by food manufacturers
to stabilize food products and enhance product shelf life [10]. HFCS is the end product
from a corn wet-milling process that involves a number of steps in a product line that
yields corn oil, animal feed, starch products, and corn sweeteners. Several chemicals are
required to make HFCS, including caustic soda, hydrochloric acid, alpha-amylase, gluco-
amylase, isomerase, filter aid, powdered carbon, calcium chloride, and magnesium
sulfate [11]. The caustic soda and hydrochloric acid are used throughout the milling
process to adjust the pH of the product line. The product line starts with corn and the
cornstarch molecule is then converted to different products by various methods that
involve acids, bases, sodium hypochlorite and enzymes [12]. Should mercury grade
caustic soda, hydrochloric acid, or sodium hypochlorite (derived from mercury grade
chor-alkali chemicals) be used in the milling process, it seemed plausible to the EHO that
mercury may well end up in the final product HFCS. A limited screening of HFCS
samples for mercury was initiated by the EHO and researchers at NIST found low levels
of total mercury. [13].
To determine the extent of total mercury in HFCS products, the EHO then used
additional government resources to collect HFCS samples from different manufacturers
and collaborate with individuals outside of the federal government to analyze the samples
for total mercury content. It should be noted that these activities occurred before the
EHO retired in January 2008.
HFCS sample collection and analytical method
The EHO working under the Office of the FDA Commissioner instructed an
investigator in a FDA regional office to collect HFCS samples from different
manufacturers. During the week of February 17-24, 2005, the FDA field investigator
successfully conducted three separate sampling events, one at each manufacturer. Prior
to each sampling event, the FDA field investigator soaked the 20-milliliter (mL) sample
vials overnight in a 50 percent (%) nitric acid solution and then rinsed them with distilled
water before allowing them to air dry. Per directed assignment from the FDA researcher,
the FDA field investigator collected five samples of 42% HFCS and five samples of 55%
HFCS from Manufacturer A, five samples of 42% HFCS from Manufacturer B, and five
samples of 55% HFCS from Manufacturer C. Each 20 mL sample vial contained
approximately 10 mL of HFCS at the end of each of the sampling events. Each sample
vial was appropriately labeled with the manufacturers name, % HFCS, date, and the
initials of the field investigator. All samples were kept under lock and key prior to being
shipped via FEDEX overnight to a laboratory for analyses.
Researchers at the University of Wisconsin-Platteville received the samples from
a federal employee with chain-of-custody intact and sub-sampled them for total mercury
analysis using NIST Oyster Tissue 1566b as the standard reference material. The NIST
Certificate of Analysis for the Oyster Tissue 1566b stated that as a standard, it could
validate the accuracy of the methods and instruments used to analyze twenty-two
different elements including total mercury. All samples, blanks (water and acid matrix),
and NIST standard reference material Oyster Tissue 1566b were analyzed by the
following method using Optima Grade Fisher Scientific hydrochloric and nitric acids that
were certified to contain less than 0.0001 microgram (g) mercury per gram (g) reagent.
Approximately 1.0 g (to nearest 0.1 milligram) of a HFCS sample, blank, or reference
material was accurately weighed into a clean 50 mL XP1500 Plus microwave cell.
Approximately 5 mL of nitric acid (Optima Grade Fisher Scientific) was added to the
cell. The cell was sealed, and the contents were digested in a high-pressure microwave
oven (CEM Mars 5). The resulting solution was allowed to cool before gravimetrically
diluting the sample to 50.0 grams (to nearest 0.1 milligram) with 2 Molar (M)
hydrochloric acid (Optima Grade Fisher Scientific; 18 M-cm water). Each sample was
analyzed within three hours to minimize mercury loss.
A Leeman Labs Hydra AA cold vapor atomic absorption spectrometer (CVAAS)
was used for the total mercury analysis. A calibration curve ranging from 10 to 200
picograms mercury/g was constructed using gravimetric dilutions (2M hydrochloric acid
described above) of a primary standard mercury solution (GFS Chemicals). Samples,

blanks, and reference materials were introduced along with stannous chloride (GFS
Chemicals) reductant at a rate of 5 mL/minute. Each sample and reference material was
analyzed in triplicate.
Results of analyses
Inter-sample blanks displayed no mercury signal above the method detection limit
of 0.005 g mercury/g sample. Mercury recovery of spiked reference materials (GFS
Chemicals) averaged 98.8 0.3 %. The results from the total mercury analysis of NIST
reference material Oyster Tissue 1566b (0.036 0.006 g /g mercury) exhibited good
agreement with certified values (0.037 0.001 g /g mercury). The NIST Oyster Tissue
1566b analyses were performed prior to samples, between samples, and post-samples
with no significant difference (p < 0.05) in the total mercury content between these
analyses.
Mercury was detected in nine of the twenty samples analyzed (Table 1). Of ten
samples from manufacturer A, nine were below the 0.005 g mercury/g sample
detection limit with the sole exception being a sample that was 0.012 g mercury/g
HFCS. Of the remaining ten samples from two other manufacturers, two were below the
detection limit and the mercury content of the other eight samples ranged from 0.065 g
to 0.570 g mercury/g HFCS (Table 1).
Implications
Mercury was not detected in eleven out of twenty HFCS samples analyzed
(detection limit 0.005 g mercury/g). A single manufacturer produced nine of these
eleven samples. These samples were likely manufactured using caustic soda produced by
a membrane chlor-alkali plant which does not use mercury in its manufacturing process.
Eight of the nine HFCS samples exhibiting mercury levels between 0.065 g to 0.570 g
mercury/g HFCS were produced by the other two manufacturers. This could indicate the
use of mercury grade caustic soda or hydrochloric acid in the manufacturing processes
used by these two manufacturers. Such use would account for the mercury in these
HFCS products. With key aspects of the HFCS manufacturing process considered
proprietary information, we could not confirm the composition of the raw materials used
by the individual HFCS manufacturers and the subsequent source of the mercury. While
more sophisticated methods produce lower detection limits, the CVAAS method used in
these analyses was sufficient as it clearly and reliably demonstrated significant levels of
mercury in 45% of the HFCS samples analyzed. Clearly the sample size of this
preliminary trial is too small but there was no support to collect additional samples for
analyses. When university researchers outside of the government attempted to obtain
additional HFCS samples direct from the manufacturer they were unable to get them.
However, with 45% of the HFCS samples containing mercury in this small study, it
would be prudent and perhaps essential for public health that additional research be
conducted by the FDA or some other public health agency to determine if products
containing HFCS also contain mercury. In 2004, several member states of the European
Union reported finding mercury concentrations in beverages, cereals and bakery ware,
and sweeteners [14] all of which may contain HFCS. FDA does not currently have a
mercury surveillance program for food ingredients such as added sugars or preservatives
manufactured with mercury grade chlor-alkali products.
The FDA does analyze some foods for mercury through the ongoing surveillance
program known as the Total Diet Study (TDS). The TDS, however, does not test all
foods for mercury. Mercury is routinely detected by the TDS in fish, liver, and poultry
because farmers routinely use fishmeal and/or fish oil as feed for certain livestock to
include chickens, swine, dairy cows, and farmed fish. Animals that are fed fishmeal can
bioconcentrate monomethyl mercury in protein matrices that are then passed on to the
consumer in the fat components of derived foods [15]. A list of the foods that were
recently tested for total mercury along with the results of the analyses may be found at
the FDA website [16]. In 2003, FDA tested 48 foods for mercury during the TDS and of
those only three may have contained HFCS. Average daily US consumption of HFCS for
the year 2007 was approximately 49.8 g per person according to the US Department of
Agriculture website [17]. High-end consumers of beverages sweetened with HFCS
could easily be ingesting more HFCS than the average person. Results of a recent study
of dietary fructose consumption among US children and adults indicate that fructose
consumption by Americans represents ten percent (10%) of calories consumed in a 24-
hour period [18]. Seventy four percent (74%) of this fructose came from foods and
beverages other than fruits and vegetables.
With respect to product labeling, FDA requires food manufacturers to list on the
food product label ingredients in descending order of weight from most to least [19]. For
example, HFCS is commonly listed as the first ingredient in chocolate syrup on the
product label, therefore all that can be known is that of all the ingredients in chocolate
syrup, there is more HFCS in the product than any other ingredient. Product labels listing
HFCS as a first or second ingredient may contain detectable levels of mercury if the
HFCS was manufactured with mercury grade chlor-alkali chemicals. As part of the
review process for this article, the authors contacted manufacturers for more information
on the % concentration of HFCS in their products and the common response back from
manufacturers was that this information is proprietary. With the reported average daily
consumption of 49.8 g HFCS per person, however, and our finding of mercury in the
range of 0.00 to 0.570 g mercury/g HFCS, we can estimate that the potential average
daily total mercury exposure from HFCS could range from zero to 28.4 g mercury. This
range can be compared to the range of total mercury exposure from dental amalgam in
children reported by Health Canada [20]. In the report issued by Canada, daily estimates
of total mercury exposure from dental amalgam in children ages 3-19 ranged on average
from 0.79 to 1.91 g mercury. Canada and other countries do not recommend the use of
mercury amalgam in pregnant women or children.
Current international food processing standards allow 1.0 g mercury/g
caustic soda [21, 22] and there is no standard for mercury in food grade hydrochloric
acid. Both of these chemicals may be used to make HFCS. The FDA has approved
HFCS for use as an added sugar in food products but a review of food product labels
reveals that it is often added to a product in addition to sugar presumably to enhance
product shelf life. Regardless of its intended use, it is imperative that public health
officials evaluate this potential source of mercury exposure, as HFCS is presently
ubiquitous in processed foods and therefore significantly consumed by people all over the
world.
Mercury in any form either as water-soluble inorganic salt, a lipid-soluble
organic mercury compound, or as metallic mercury- is an extremely potent neurological
toxin [23]. Organic mercury compounds such as methylmercury that are fat-soluble and
readily cross the blood brain barrier are especially damaging to developing nervous
tissues [24, 25]. For example, prenatal exposure as low as 10 mg/kg methylmercury, as
measured in maternal hair growing during pregnancy, may adversely affect the
development of the fetal brain [25, 26]. Confounding associations and concerns with
various stages of brain development related to cumulative early life exposure to mercury
include the following sources of mercury: maternal fish consumption during pregnancy,
the thimerosal (sodium ethylmercurithiosalicylate, approximately 49% mercury weight)
content of certain vaccines and dental amalgam [27].
Mercury regulation varies from country to country. While the US government
only regulates methylmercury in fish, several other governments regulate all forms of
mercury in all foodstuffs. In the US, the current action level of 1 g methylmercury/g
fish or seafood was set in 1977 during court proceedings of the United States of
American v. Anderson Seafoods, Inc. [28]. The data used to determine the action level in
fish came from a poisoning incident that occurred in Iraq under Saddam Husseins
regime in 1971-1972. There was not a chain of custody for the specimens taken from the
victims of that poisoning that were tested by World Health Organization or American
researchers, and an appropriate epidemiological study was not undertaken [29]. Further
risk assessment for methylmercury has been conducted using human data from the
massive episodes of mercury poisoning in the tragic Minimata Bay incident in Japan, as
well as from large scale epidemiological studies concerning childhood neurodevelopment
and neurotoxicity in relation to fetal exposure in various fish eating communities around
the world [24, 25]. There has never been a blinded, placebo, controlled study published
giving humans mercury or methylmercury, nor would this kind of study be ethically
considerable. Quantitative information on long-term effects of inorganic mercury

compounds on humans does not exist [30]. Inorganic mercury compounds react with
DNA and are clastogenic [30]. Because the mechanisms of these reactions remain
unknown, it is currently impossible to establish a no adverse-effect-level for mercury in
humans. Sensitive populations such as neonates lacking the ability to efficiently excrete
mercury or individuals that retain mercury in their body due to impairments in
detoxification pathways may not be protected by any exposure limit. The implications
for mercury in ingested HFCS are not known and clearly more epidemiological and
neurotoxicological studies are required.
Conclusions
An EHO at the FDA conducted an investigation of the chlor-alkali industry in
2004 and found mercury residue in all of the mercury cell chlor-alkali products including
caustic soda, chlorine, potassium hydroxide, and hydrochloric acid. Mercury is widely
accepted to be a neurotoxic heavy metal [23]. The American Academy of Pediatrics has
recommended that minimizing any form of mercury exposure is essential for optimal
child health and nervous system development [6]. Current international food processing
standards allow 1.0 g mercury/g caustic soda [21, 22] and there is no standard for
mercury in food grade hydrochloric acid. Both of these chemicals may be used to make
HFCS. Mercury contamination of food products as a result of the use of mercury
contaminated HFCS seems like a very real possibility. With daily per capita
consumption of HFCS in the US averaging about 50 grams and daily mercury intakes
from HFCS ranging up to 28 g, this potential source of mercury may exceed other major
sources of mercury especially in high-end consumers of beverages sweetened with
HFCS. Food products that contain a significant amount of HFCS should be tested for
mercury contamination in the end product and the public should be informed of any
detections. Clearly, more research is needed to determine the extent of mercury exposure
in children from mercury contaminated HFCS in food products.
Abbreviations
AA Atomic Absorption; CEM Corporation that makes microwave accelerated

reaction systems; CVAAS Cold Vapor Atomic Absorption Spectrometer; DNR
Department of Natural Resources; EHO Environmental Health Officer; EPA
Environmental Protection Agency; FDA Food and Drug Administration; GFS Grade
Fisher Scientific; HFCS High Fructose Corn Syrup; M Molar; MARS Microwave
Accelerated Reaction System; NIST National Institute of Standards and Technology;
TDS - Total Diet Study; US United States; XPI Cross Polar Isolation
Competing interests
The authors declare that they have no competing or conflict of interests.
Authors contributions
RD carried out the environmental investigation, conceived the study, acquired the
samples for analyses, and was involved in drafting the manuscript. BL provided
assistance in the study design and was involved in drafting the manuscript. CC and LS
analyzed the samples, acquired the data and were involved in drafting the manuscript.
RS, LP, JH, DW and WJL were all instrumental in drafting the manuscript and revising it
critically for intellectual content. All authors read and approved the final manuscript.
Acknowledgements
This research article is based on the views of the authors and does not represent an
official FDA position. Thanks to Dr. Isaac Pessah and Dr. Howard Hu for their helpful
reviews and feedback on the way to present this information to the public. Thanks to Dr.
Barry Lai for providing assistance with sample transportation.

References
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Table 1 - total mercury (Hg) in high fructose corn syrup (HFCS) samples
Sample Name Hg content Sample Name Hg content (g

(g Hg/g Hg/g HFCS)
HFCS)
MANUFACTURER A < DL MANUFACTURER B < DL (0.005)

(0.005)
HFCS 42% (sample 1) HFCS 42% (sample 1)
MANUFACTURER A < DL MANUFACTURER B < DL (0.005)

(0.005)
MANUFACTURER A 0.012 MANUFACTURER B 0.350
MANUFACTURER A < DL MANUFACTURER B 0.390

(0.005)
MANUFACTURER A < DL MANUFACTURER B 0.065

(0.005)
MANUFACTURER A < DL MANUFACTURER C 0.130

(0.005)

(0.005)

(0.005)

(0.005)

(0.005)
DL - Detection Limit

Mercury in High Fuctose Corn Syrup

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Mercury in High Fuctose Corn Syrup

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This document contains 2 studies finding Mercury in High Fructose Corn Syrup.

Not So Sweet: Missing Mercury and High Fructose Corn Syrup

Published January 2009 2009 IATP. All rights reserved.

P 2| USA | 612.870.0453 | Fax 612.870.4846 | iatp.org

Figure 1: HFCS vs.1:Table

Figure 2: Estimates of Average Daily HFCS Consumption, by Age Grouping

Where is HFCS found?

Why do food manufacturers use HFCS?

HFCS and mercury

What is mercury-grade caustic soda?

How is HFCS produced?

Figure 3: Synthesis of High Fructose Corn Syrup

Corn processors / refiners

Mercury and public health

Why we tested brand-name foods for mercury

Overall, we found detectable mercury in 17 of 55 samples, or around 31 percent. Quality control

Table 2. No. of Samples No. with detectable Mercury detected

Recommendations for industry

Food Product Product Type

Market Pantry Cranberry Sauce Condiment

Beverages Limit of detection (ppt) Total Hg detected (ppt)

Dressings and condiments Limit of detection (ppt) Total Hg detected (ppt)

Dairy Limit of detection (ppt) Total Hg detected (ppt)

Snacks and Desserts Limit of detection (ppt) Total Hg detected (ppt)

Soups and Entres Limit of detection (ppt) Total Hg detected (ppt)

Syrup & jellies Limit of detection (ppt) Total Hg detected (ppt)

Mercury from chlor-alkali plants: measured concentrations in food product

Renee Dufault (rdufault@uttc.edu)

Article type Commentary

Submission date 9 September 2008

Acceptance date 26 January 2009

Publication date 26 January 2009

Article URL http://www.ehjournal.net/content/8/1/2

For information about other BioMed Central publications go to

2009 Dufault et al. , licensee BioMed Central Ltd.

source of mercury in the diet of children and sensitive populations.

Administration (FDA) conducted an investigation to find the missing mercury in the

chlor-alkali industry [7].

The path of the investigation

An employee of the Environmental Protection Agency (EPA) suggested that the

wastewater discharge permit re-issuance application. This information led to the

cell chlor-alkali industry. A representative of the Chlorine Institute confirmed in a

products varies, depending on the manufacturing process at each plant. It is found in

mercury grade caustic soda according to product specification sheets [8].

According to an archived web page report initially produced by Vulcan

cornstarch molecule is then converted to different products by various methods that

of total mercury. [13].

additional government resources to collect HFCS samples from different manufacturers

EHO retired in January 2008.

HFCS sample collection and analytical method

investigator in a FDA regional office to collect HFCS samples from different

samples of 55% HFCS from Manufacturer C. Each 20 mL sample vial contained

shipped via FEDEX overnight to a laboratory for analyses.

Researchers at the University of Wisconsin-Platteville received the samples from

analyzed within three hours to minimize mercury loss.

A Leeman Labs Hydra AA cold vapor atomic absorption spectrometer (CVAAS)

described above) of a primary standard mercury solution (GFS Chemicals). Samples,

of 0.005 g mercury/g sample. Mercury recovery of spiked reference materials (GFS

to 0.570 g mercury/g HFCS (Table 1).

(detection limit 0.005 g mercury/g). A single manufacturer produced nine of these

analyses. When university researchers outside of the government attempted to obtain

manufactured with mercury grade chlor-alkali products.

Agriculture website [17]. High-end consumers of beverages sweetened with HFCS