Black spatulas

If you’ve been paying attention to the food scare news, you will have heard that black plastic spatulas are EVIL and then that they are probably ok.  Predicted exposures to brominated flame retardants were close to the ‘reference level’ because of a simple decimal-place error and there’s now a ten-fold safety margin. The summary by Joel Schwarcz at McGill University in Canada is good; as he notes, there is no actual need for spatulas to be flame-retardant and while the level of fire retardants doesn’t look dangerous, the target level should be roughly zero.

There are two additional points I want to make. First, units.  The original scare paper quoted the ‘oral reference dose’ as 7000 nanograms per kg per day. The EPA document that it cited said 0.007 mg per kilogram per day. These are terrible units.  The SI system gives us names every three orders of magnitude precisely so we don’t have to do this sort of thing and can say 7 micrograms per kilogram per day. It’s a lot easier to work with numbers like this.

Second, what does the reference dose mean?  If you look at the relevant EPA document you will see that the 7 micrograms per kilogram per day comes by taking a reference dose for non-cancer effects in mice and multiplying it by 10 because humans might be more sensitive than mice, and a further 10 because you might be more sensitive than the typical human and a further 3 because long-term exposure might matter more than short-term exposure.  And, on reading further, that the dose for mice was the highest dose tested in that experiment and did not show any adverse effects.  So, the 7 micrograms per kilogram per day reference dose is 300 times the highest dose they even tested for mice.  Some other experiments did find adverse effects in rats, but at doses nearly a thousand times higher: 6 milligrams per kg per day.

Taking all this together you can see the fuzziness in the calculations. There’s now a ten-fold margin of safety between a generously estimated dose and a reference dose — which is not a danger dose, but one that should have no effect.  On top of that, there’s an unknown (and possibly large) safety factor because of the choice of doses in the mouse safety experiments.  The basic problem is that you can’t tell accurately what doses will cause harm in humans without causing harm in humans; some sort of extrapolation is unavoidable in safety assessment.