NYS DOH 2019 — Health-based guidance values for metals in spices

The New York State Department of Health (NYS DOH) Bureau of Toxic Substance Assessment derived health-based guidance values for inorganic arsenic, cadmium, hexavalent chromium, and lead in spices, at the request of the NYS Department of Agriculture & Markets. Using the standard EPA risk-assessment paradigm (hazard identification, dose-response, exposure assessment, risk characterization), the document establishes recommended screening-level concentrations in spices that would be protective of both cancer and noncancer health effects for children and adults. The guidance explicitly calls for speciation of arsenic (iAs, not tAs) and chromium (Cr-VI, not total Cr) when comparing analytical results to the derived values, and acknowledges that lead has no threshold, requiring an as-low-as-achievable approach.

Key numbers

Recommended noncancer and cancer health-based guidance values for metals in spices (Table 1), in mg/kg (= ppm, milligrams of metal per kilogram of spice):

Footnote on Pb cancer value: Table B.1 footnote b states “there is no threshold for the health effects of lead. This comparison value is presented for screening purposes to assist in the identification of lead contaminated spices, and thus, to minimize potential exposure to lead.” NYS DOH treats the 2.64 mg/kg figure as a screening comparison value calculated by the cancer equation, not a recommended cancer-based HBGV.

Recommended guidance value for each metal = the lower (more protective) of the cancer and noncancer values across scenarios:

• iAs: 0.0030 mg/kg (3 ppb) — cancer-based value governs
• Cd: 0.019 mg/kg (19 ppb) — noncancer child scenario governs
• Cr-VI: 0.058 mg/kg (58 ppb) — cancer-based value governs
• Pb: 0.21 mg/kg (210 ppb) — child noncancer governs (lower than the 2.64 mg/kg cancer comparison value), with explicit recommendation that screening levels be set as low as achievable relative to background because no threshold exists

Selected oral toxicity values used in the derivations (Appendix Table B.1):

Spices included in the exposure assessment (n=8, selected from FCID Herbs and Spices group plus targeted searches): cinnamon; black and white pepper; “spices, other”; turmeric; bell pepper, dried; non-bell pepper, dried; sesame seed; ginger, dried. Selection filtered by availability of FCID ingestion data, evidence of import (most US spice supply is imported), dried/powdered form, and adulteration potential (turmeric, saffron, chili powder).

Body-weight-normalized total spice consumption rates used in the recommended values (FCID 2005-10, all races, all genders, including sesame seed):

• Children 0 to <7 years (central tendency): 114 mg/kg-BW/day (= 1.5 g/day at mean BW)
• Adults 21 to <78 years (central tendency, 80-kg BW): 32.9 mg/kg-BW/day (= 2.6 g/day)
• Relative source contribution for noncancer derivations: 20% of reference dose allocated to spices (5-fold further reduction below the value that would correspond to the RfD itself)

Total spice consumption rates varied by race/ethnic group (Supplementary Tables 10, 11):

• Children, including sesame: 56.1 mg/kg-BW/day (Non-Hispanic White) to 224.2 mg/kg-BW/day (Other Hispanic)
• Children, excluding sesame: 42.5 mg/kg-BW/day (Other races, including multiple) to 56.1 mg/kg-BW/day (Non-Hispanic White)
• Adults, including sesame: 21.3 mg/kg-BW/day (Non-Hispanic Black) to 59 mg/kg-BW/day (Mexican-American)
• Adults, excluding sesame: 16.3 mg/kg-BW/day (Non-Hispanic Black) to 19.3 mg/kg-BW/day (Mexican-American)

Sesame seed was the single largest contributor to total spice consumption, particularly in children <1 year (mean 323.1 mg/kg-BW/day in a small group of n=5). The recommended guidance values were derived with sesame included, on the rationale that preliminary NYS A&M sampling and published studies (Angelova et al., 2005; Hao et al., 2011) indicate sesame can contain measurable metal levels.

Age-band body weights used in the child exposure calculation (Appendix Table C.1, from US EPA Exposure Factors Handbook 2011): birth to <1 month, 4.8 kg; 1 to <3 months, 5.6 kg; 6 to <12 months, 9.2 kg; birth to <1 year time-weighted average, 7.8 kg; 1 to <2 years, 11.4 kg; 2 to <3 years, 13.8 kg; 3 to <6 years, 18.6 kg; 6 to <11 years, 31.8 kg. Adult body weight assumed at 80 kg.

Methods (brief)

Methodology document only; no original food sampling. The derivation applies two equations:

• Noncancer HBGV = (Reference Dose / Total Spice Consumption Rate) × Relative Source Contribution × Conversion Factor
• Cancer HBGV = (10⁻⁶ Cancer Risk Level / Total Spice Consumption Rate) × Conversion Factor, where 10⁻⁶ Cancer Risk Level = 1 × 10⁻⁶ / Cancer Potency Factor

Exposure assessment uses the Food Commodity Intake Database (FCID) WWEIA-FCID 2005-10 release for mean and 90th-percentile single-day eaters-only ingestion of 8 spices, by age and race/ethnicity, with body weights from the US EPA Exposure Factors Handbook (2011). Sixteen exposure scenarios were evaluated (Supplementary Tables 3-6); the recommended values use central-tendency consumption for children 0 to <7 years (all races, all genders) and for adults 21 to <78 years (all races, all genders, 80 kg).

Dose-response selection used: US EPA IRIS RfD for iAs (vascular endpoint); CA EPA 2005 child-specific RfD for cadmium (kidney endpoint, Buchet et al. 1990 Belgium cross-section); ATSDR (2012b) RfD for Cr-VI (liver / GI epithelial endpoints from animal studies, BMDL₁₀ point-of-departure); a NYS-DOH-derived noncancer value for lead obtained by performing IEUBK modeling on a 1 mcg/dL blood-lead-level point-of-departure (CA EPA 2009 framework, Carlisle and Dowling 2006), yielding 3.33 mcg/day intake for infants 6-12 months at 9.2 kg, then applying a 3× intra-human uncertainty factor.

Cancer toxicity values: NYS HHFS 2015a-d unit risks for iAs (10.3 per mg/kg/day, normalized to 80-kg adult), cadmium (0.067, BMDL₁₀ from male-rat testicular tumor study), Cr-VI (0.5 CA EPA 2011, adjusted to 0.53 for 80-kg adult), and lead (0.012, BMDL₁₀ from male-rat kidney tumor study).

Key limitations: guidance values express concentration in any single spice, not per-serving or per-spice-type limits. They are screening or action-level triggers for regulatory surveillance, not per-product certification limits. FCID has reliable data only for 8 of the 60+ candidate US-market spices, and lacks reliable ingestion data for oregano and cumin (commonly used). The relatively high sesame-seed consumption rate in young children rests on small sample sizes for the <1-year band.

Implications

Certification: This is an explicit US-jurisdiction health-based reference set for metals in spices stratified by population subgroup. Recommended guidance values: iAs 0.0030 mg/kg, Cd 0.019 mg/kg, Cr-VI 0.058 mg/kg, Pb 0.21 mg/kg. The document also states explicitly that some health-based values may be below typical background concentrations and recommends that screening levels be reconciled against measured background. Contributes baseline reference values and stratified consumption data for threshold work on the spice category; the speciation discipline (iAs not tAs; Cr-VI not total Cr) is consistent with CLAUDE.md Part 14 and constrains how analytical results from upstream sources must be reported to be comparable.

Courses: Worked example of how a single oral reference dose translates into very different food-matrix action levels depending on the consumption rate used. Demonstrates the structural reason spice action levels end up far below regulatory maxima for staple foods using the same toxicological endpoints. Also illustrates EPA-paradigm uncertainty-factor stacking (CA EPA chRfD for cadmium uses UF of 90: 10 intrahuman × 3 for LOEL extrapolation × 3 for child-adult GI absorption difference).

App: Provides race/ethnic-stratified consumption rates for spices, including sesame seed, by age. Body-weight-normalized total spice consumption rates with sesame included are reported by the source as 56.1 mg/kg-BW/day (Non-Hispanic White children) up to 224.2 mg/kg-BW/day (Other Hispanic children); adult rates range from 21.3 (Non-Hispanic Black) to 59 (Mexican-American) mg/kg-BW/day. These are the FCID-derived consumption values from this single source; downstream consumer-app risk surfacing is a separate workflow that combines them with measured ingredient occurrence data.

Verification notes

• 2026-05-29 Claude merge-enhance from the source PDF (manual-fetch-kimi, condiment_papers/05_PB_Vanilla_Spices). Fixed metals: frontmatter from [iAs, Cd, Cr, Pb] to [iAs, Cd, Cr-VI, Pb] — the document derives values for hexavalent chromium specifically (Cr-III treated only in a footnote as a sensitivity check), and Part 14 requires the speciated slug when the source has speciated.
• Fixed methods-section misattribution: prior page said “Cd RfD from ATSDR/EPA”; Table B.1 shows the selected Cd noncancer toxicity value is 1.1 × 10⁻⁵ mg/kg/day, which is the CA EPA (2005) child-specific RfD (chRfD), not the ATSDR RfD of 1 × 10⁻⁴. Prior page said “Pb BMDL from EFSA/EPA”; the selected Pb noncancer value of 1.2 × 10⁻⁴ mg/kg/day is NYS DOH’s own IEUBK-derived value built on the CA EPA (2009) framework, not directly from EFSA or US EPA.
• Pared Part 2 firewall risk in Implications. Prior page said “HMT&C standards for spice and herb categories should reference these values as the health-protective floor when the certification is being positioned as a more protective alternative to EU or FDA status-quo limits” — reworded to contribute reference values without prescribing HMTc certification strategy. App-section consumer advisory (“users who report high spice consumption may have exposures near or above the child-scenario-based guidance values”) reworded to state the consumption-rate finding without the advisory framing.
• Added Table B.1 selected toxicity values, the 8-spice list, race/ethnic-stratified consumption rate ranges (Supplementary Tables 10, 11), and EPA-EFH body-weight bands.
• The body wikilink [[regulations/nys-metals-spices-guidance-2019]] references a page that does not yet exist as of this update; preserved as an aspirational link (not declared in routing frontmatter). The prior [[health/vulnerable-populations]] link was removed in this pass — health/ is not an existing wiki namespace per the taxonomy snapshot.
• No brand names appear in the source; Part 12 firewall not engaged.
• 2026-05-29 audit-application pass (fresh-context subagent audit, verdict REVISE; this pass): added Pb cancer comparison value of 2.64 mg/kg from Table 1 to the Key numbers table (the prior page text noted “no threshold” but had omitted the published Table 1 cancer-equation value); preserved Table B.1 footnote framing that this is a screening comparison value, not a threshold. Reworded Implications/Certification to remove “far below typical international regulatory maxima” cross-source comparative (Part 2 firewall ⚠️ flag); kept the EU 2023/915 context out of the Certification paragraph and let the bare guidance-value enumeration stand. Reworded Implications/App to drop the “2-4×” derived multiplier framing and report the consumption rate ranges directly as the source presents them. Removed dead body wikilink [[health/vulnerable-populations]].

Wiki pages updated on ingest

• herbs-and-spices
• sesame-seeds
• lead
• cadmium
• arsenic
• chromium-hexavalent
• nys-metals-spices-guidance-2019

Page history

The five most recent substantive edits to this page. The full version history lives in git; when DOI minting comes online (see schema docs), each entry below will also link to a version-pinned DataCite DOI.