The reality of melamine in animal feeds and milk products has crossed the ocean and landed on the shores of North America. Trace levels of melamine have been detected in certain baby formula products in the US.

The National Milk Providers Federation (NMPF) has responded with a statement on their position on adulterants. Having been in the milk processing business as a quality control chemist, I can add that my experience with the industry is consistant with the statement by the NMPF.

To understand the true level of confusion and diverse practices relating to this problem, it is important to note that the analytical methods used by US milk processors are insensitive to the presence of melamine itself. Here is why: Raw milk arriving to a processing facility is tested for the presence of antibiotics, fat content, flavor, pH, and total solids. To my knowledge, there is no batch QC protein analysis anywhere in the US manufacturing flow. In Asia, apparently protein analysis is common. 

The practical consequence of this analytical protein blindness in the US is that there is no benefit to adding melamine to milk because pricing is not determined by protein content. Milk is sold by the pound and its premium value is determined by the butterfat content.

Milk has been subject to many kinds of fraudulent modifications in the past. Sour milk has been neutralized with caustic. Today all milk is taste-tested for off flavor. Milk has been diluted for higher profit. Today all raw milk is tested for % solids and % fat to detect dilution. It should be above a certain minimum on both accounts. Cows have been milked abusively into chronic mastitis and given antibiotics. All milk is now tested for antibiotic residues via chemical and microbial assays. Finally, milk that contains an excessive microbial loading is rejected.

If Chinese milk processors adopted a similar testing protocol, the benefit of direct adulteration of milk with melamine would disappear. The effects of melamine-laced cattle feed is another issue. I have not heard of studies that connect ingestion of melamine contaminated feedstocks to milk contamination. Perhaps this has already been done.

According to the Wall Street Journal–

Dr. [Stephen] Sundlof said the melamine traces stemmed from the products coming in contact with the chemical during processing. The FDA approved melamine as a “food contact substance” about four decades ago.

The article continues-

The FDA said last month that it’s safe for consumers to eat most food with melamine below 2.5 parts per million, but infant formula was the exception. “FDA is currently unable to establish any level of melamine and melamine-related compounds in infant formula that does not raise public health concerns,” it said.

I am heartened to see that the FDA is reluctant to establish a threshold for safe consumption by infants. But at the same time, the matter of a 2.5 ppm threshold for everyone else amounts to a sh*t sandwich for the public.

The levels detected by US companies and agencies seems rather low. Again, from WSJ-

A spokesman for Mead Johnson Nutritionals, owned by Bristol-Myers, said the company’s own tests haven’t turned up any melamine, and the FDA tests turned up melamine levels “lower than the 0.25 parts per million limit that can be measured by the published FDA test method.” Mead Johnson, he said, maintains “stringent standards at all our manufacturing sites to ensure the high quality and safety of our products that our customers have come to expect.”

Dr. Sundloff said the melamine detected was tiny. Out of 87 samples, it found one sample with 0.137 parts per million and 0.140 parts per million on a verification test.

While toxicological threat to US consumers at the sub-ppm level is unclear at the moment, what seems to be lacking at FDA is a discussion as to the need to allow any level of melamine in any consumable.

Here is what is clear to Th’ Gaussling:

There is no overlap in the material streams of melamine or melamine resin manufacture with any dairy product. No dairy operation should reasonably expect to require containers of melamine monomer in its warehouse, nor should any supplier to dairy product manufacture.

Melamine contamination by contact exposure to melamine resin components can be averted by the use of many other food grade materials of construction, i.e., stainless steel.

If melamine is detected in food articles, it is the duty of the manufacturer to promptly audit all suppliers and eliminate the source of contamination.

Rather than tolerate and regulate the presence of a material whose only purpose is to perpetrate fraud, the FDA should ban food products containing detectable amounts of melamine. If the FDA goes forward with acceptable levels of melamine in dairy products, suppliers would begin to game the system. In a short time, ppm levels of melamine will be considered “normal” and suppliers of melamine contaminated feedstocks will be legitimized up to the regulatory threshold. 

A firm stand by regulatory agencies will strengthen the motivation of manufacturers to maintain strong audit trails and take away the financial incentive to use this fraudulent additive.