_____________________________________________________________________________________________________________________ 

Memorandum 

Date: November 3, 2022 

Subject: Cadmium (Cd) in Bugak Seaweed Chips 

Re: CMS Case # 645358, Task # 677691, Private laboratory sample # 3800693 

From: Jacqueline Heilman, Ph.D. ______________________ 

Contaminant Assessment Branch (CAB) (HFS-005) 

Division of Risk and Decision Analysis (DRDA), Office of Analytics and Outreach (OAO) 

To: 

Judith Spungen, M.S., R.D. ___________________________ 

Exposure Assessment Branch (EAB) (HFS-005), DRDA, OAO 

Gabriela Luta, Ph.D. 

Division of Plant Products and Beverages, Office of Food Safety (OFS) (HFS-317) 

As requested by OFS, DRDA evaluated the safety of exposure to Cd in Bugak Seaweed Chips 

(seaweed chips). A sample of the seaweed chips was analyzed by a private laboratory, Certified 

Laboratories, and found to contain 0.406 mg/kg (μg/g) Cd. DRDA was notified by an email from 

OFS that the Office of Regulatory Science (ORS) supports the findings, but a written 

memorandum from ORS has not been reviewed by DRDA at the time of this assessment. 

DRDA Conclusion 

DRDA concludes that exposures to Cd from consumption of the seaweed chips are likely to be a 

health concern for children (MF 0-6 y) but not for the general population (MF 2+ y). 

Consumption and Exposure Estimates 

DRDA generally uses data from What We Eat in America (WWEIA), the food consumption portion 

of the National Health and Nutrition Examination Survey (NHANES), to estimate intakes of foods 

for exposure assessments. However, NHANES/WWEIA does not track consumption of bugak 

seaweed chips. DRDA therefore estimated consumption of this product using all vegetable-based 

snack chips as a proxy. 
 

 

 

 

 

 

 

 

 

 

 

 

 

Page 2 of 3 pages 

DRDA used data from What We Eat in America (WWEIA), the food consumption portion of the 

National Health and Nutrition Examination Survey (NHANES), to estimate intakes of seaweed 

chips. To characterize upper-level chronic dietary exposures to Cd from seaweed chips, 90th 

percentile daily consumption of all vegetable-based snack chips was estimated based on average 

daily amounts consumed by NHANES/WWEIA 2017-2018 respondents who reported consuming 

vegetable-based snack chips at least once during the two days of the survey (i.e., 2-day averages 

for eaters only). 

For Cd exposures, the populations of concern are young children (0-6 y) and the general 

population (2+ y). Estimated upper-level chronic exposures to Cd from consumption of seaweed 

chips are shown in Table 1. 

Table 1. Estimated upper-level chronic exposures to Cd from consumption of seaweed chips by 

children (MF 0-6 y) and the general population (MF 2+ y) 

Contaminant Population 

Concentration 

in Sample 

(μg/g) 

Estimated UpperLevel (90th %ile) 

Chronic 

Seaweed Chips 

Consumptiona 

(g/kg bw/day) 

Estimated UpperLevel (90th %ile) Cd 

Exposure from 

Seaweed Chipsb 

(μg/kg bw/day) 

Cd 

MF 0-6 y 

0.406 

1.53 0.62 

MF 2+ y 0.67 0.27 

a Estimated based on two-day average consumption (eaters only) of vegetable-based snack chips, NHANES/WWEIA 

2017-2018. b Concentration in sample (μg/g) * upper-level consumption (g/kg bw/day) = estimated total exposure (μg/kg 

bw/day). 

Safety Assessment 

Cadmium (Cd) 

Cd is an accumulative toxic element with a long biological half-life between 10 to 33 years in 

humans. Therefore, the toxicity of Cd generally results from chronic exposure. For the general 

population who are non-smokers, diet is the major source of Cd exposure. Chronic exposure to 

Cd in food may lead to its accumulation in the kidney (generally regarded as the most sensitive 

target for Cd toxicity), and this can cause renal tubular dysfunction and damage over time (WHO, 

2011). EFSA has established a tolerable weekly intake (TWI) of 2.5 μg/kg bw/weekly for Cd,

corresponding to 0.36 μg/kg bw/day (EFSA, 2009). The TWI is based on a meta-analysis of human 

epidemiological studies assessing the relationship between urinary Cd and beta-2-microglobulin 

levels and a toxicological model to convert urinary Cd to dietary Cd exposure. 

As shown in Table 1, regular consumption of the seaweed chips would result in Cd exposure for 

children (MF 0-6 y) above 0.36 μg/kg bw/day, which is the EFSA TWI adjusted for daily exposure. 

The information contained in this document is confidential and distributed for internal purposes only. 

The content of this document is pre-decisional and deliberative. 
 

 

 

 

 

 

 

Page 3 of 3 pages 

Therefore, Cd exposure from consumption of the seaweed chips is likely to be a health concern 

for children. Regular consumption of the seaweed chips would result in Cd exposure for the 

general population (MF 2+ y) that is below 0.36 μg/kg bw/day, which is the EFSA TWI adjusted 

for daily exposure. Therefore, Cd exposure from consumption of the seaweed chips is not likely 

to be a health concern for the general population. 

References 

European Food Safety Authority (EFSA) (2009). Cadmium in Food. Scientific Opinion of the 

Panel on Contaminants in the Food Chain. EFSA Journal 980, 1-139. 

World Health Organization (WHO) (2011). Cadmium. Safety evaluation of certain food additives 

and contaminants. WHO Food Additives Series, No. 64/FAO JECFA Monographs 8. World Health 

Organization, Geneva. Available at 

http://apps.who.int/iris/bitstream/handle/10665/44521/9789241660648 eng.pdf;jsessionid=D 

96891CABDCBCF63BE8F57D7CA615E2C?sequence=1 

Accessed 11/03/2022. 

The information contained in this document is confidential and distributed for internal purposes only. 

The content of this document is pre-decisional and deliberative.