Untested Food Additives

SFDA Allows Chemicals in Food Despite Lack of Toxicity Testing

Jennifer Sass

Posted August 14, 2013 in Health and the Environment, U.S. Law and Policy

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Chemicals are added to food to preserve, flavor, thicken, or otherwise alter it in some desirable way. Used this way, the chemicals are called ‘food additives’. In other contexts the same chemicals may be considered industrial chemicals or pesticides.

For example, sulfites were banned by FDA in 1986 for use on fruits and vegetables that are eaten raw, but are still allowed as a preservative in cooked and processed foods, and they occur naturally in wines and beers. They are also approved by EPA as pesticides, to prevent fungus and preserve grape crops. When eaten in foods, they induce allergy-like reactions in many people (FDA estimates that 1 in 100 people are sensitive to sulfites in food). When FDA approved their use as a food additive in the 1970s, sulfites were deemed to be Generally Recognized As Safe (GRAS) and exempted from FDA premarket approval requirements.

In 1974, the FDA allowed asbestos-contaminated salt produced by one company, United Salt in Houston, to be sold as table salt, as GRAS. FDA had even received comments from the trade group Salt Institute that it had looked at this type of salt – called diaphragm salt – and seen asbestos fibers by optical microscopy. Only in response to public outrage did FDA do a proper analysis of the salt at outside labs, using the more powerful electron microscopy, whereupon tens of millions of asbestos fibers per gram was found and FDA revoked its approval.


The black box of FDA food regulations came under the spot light when technical experts at The Pew Charitable Trusts started working to answer these questions and others about how chemicals in our food are regulated.

Today, Pew released a report in the scientific journal Reproductive Toxicology reporting that less than 38% of over 8,000 FDA-regulated additives (including those added directly to food intentionally, and food contact materials that may contaminate foods) have a published feeding study. (Feeding studies comprise the basic toxicology test – the first test a scientist would do to evaluate the safety of a chemical additive.) For the direct additives (added intentionally to the food) only 21.6% (out of almost 4,000) have the feeding studies necessary to estimate a safe level of exposure, and only 6.7% have reproductive or developmental toxicity data in FDA’s database.

It appears FDA and companies were often making safety decisions by comparing one chemical to another rather than doing an actual toxicology study.  They were building a house of cards based on assumptions and unsupported extrapolations instead of direct scientific evidence.

How did our food regulations go so terribly wrong? The Pew team has a few insights:

Once a chemical use is cleared to be added to the food supply, it is seldom re-assessed for ongoing safety. So, the manufacturer has no incentive to support additional toxicity testing. And the FDA doesn’t have the authority to require testing if it has questions about a chemical.

GRAS determinations are permitted to be made by the chemical manufacturer, not FDA (unless the additive affects food color). If the additive is self-determined to be GRAS by the company, then it can choose whether or not to alert the FDA about the new food additive. In other words, even reporting GRAS additives to FDA is voluntary. Had the company selling the asbestos-contaminated table salt opted not to notify FDA, it may have stayed on the market.

In fact, the Pew team believes that about one thousand food additives are in the food supply without FDA’s knowledge. An example is the 2010 debacle with caffeine-alcohol drinks marketed for young people without informing the FDA. The manufacturer had considered the additives to be GRAS, until alcoholic poisonings and blackouts resulted in public outrage and Congressional scrutiny.

A 2010 report by the US Government Accountability Office (GAO), providing Congressional oversight, called the whole messed-up GRAS process into question when it learned that engineered nanomaterials were being deemed GRAS food additives. GAO concluded that, “FDA does not know to what extent, or even whether, companies track evolving scientific information about their GRAS substances. FDA’s approach to regulating nanotechnology allows engineered nanomaterials to enter the food supply as GRAS substances without FDA’s knowledge.” It is disturbing that nanomaterials are deemed to be GRAS food additives, when the legal definition of GRAS is that there is, “a reasonably certainty in the minds of competent scientists that the substance is not harmful under the intended conditions of use”, and there is no scientific consensus on how to even test the toxicity or safety of nanomaterials.

Last week, the Pew team published a report in The Journal of the American Medical Association Internal Medicine showing that “financial conflicts of interest are ubiquitous” in the process leading to determining that a chemical is GRAS. Considering the lack of toxicity data for thousands of chemicals (many of which are designated as GRAS) allowed in food, one wonders 1) who made the decision that they were safe and 2) whether their judgment was influenced by the manufacturer.

A commentary by Dr. Marion Nestle highlights the obvious conflicts of interest as one of the biggest problems with chemical food additive regulations (or lack thereof). She emphasizes the fact that Pew reported that all – that’s 100% – of the members of the expert panels that review food additives to make GRAS determinations have financial relationships with companies that manufacture the food additives being reviewed. Follow the money! (An editorial today in the prestigious journal Nature discusses the Pew study and highlights the problems of financial conflicts)

I’ve extensively documented the problem of chemical manufacturers testing the safety of their own products. It isn’t rocket science to think that a bias and a financial conflict may lead to a misrepresentation of the potential toxicity of a chemical. But, when those chemicals are intentionally added to the food supply, well, things just got a lot more serious!

This past spring, NRDC officially requested a copy of the FDA database of food additives that includes both the names of the chemicals and the basis for the FDA’s approving them for use in food. FDA failed to respond, so we had to file a lawsuit against FDA for this public information. What is FDA hiding from the public? Thanks to the Pew team, the public is starting to learn about failures in the food additives regulatory process.

Steps to Get Rid of GMO’s

11 Steps for GMO Eradication: Help Grow the “GEM”

11th March 2012

By Jack Adam Weber

Contributing Writer for Wake Up World

Dear Fellow Sane Human Beings,

Greetings. It’s a pleasure to write to you again.

By now you likely have plenty of information and encouragement for why not to purchase GMOs (Genetically Modified Organisms). What we need now is to band together and take action. So below I have outlined “How” to do this.

If you need more information on GMOs or GM Foods, please search this site for “GMO” or see my articles.

GEM stands for “GMO Eradication Movement.” It of course also refers to our beautiful planet. So to “Grow the GEM” means eradicating GMOs to beautify our world. The 11 Steps for Growing the GEM are divided among three levels of participation. An overview of the three levels for being a GEM (GMO Eradication Mover) are:

Level I: Learning how to identify GMO products and not to buy them.

Level II: Includes Level I knowledge and action and shares it with others: friends, businesses, restaurants, grocery stores, etc.

Level III: Includes Level I & II, and implements public outreach to masses of people, and puts their hands in the soil.

I have also set up a GEM Facebook Page. This will be a crucial resource for us as we go forward, and your participation will help us all. So please join us here to meet and join forces.

As we learn more, the list below will be amended and updated. Please help us “Grow the GEM” by passing on this information. We absolutely need all of us now workingtogether. Time is urgent. We cannot procrastinate.

Feel free to copy and share the 11 Steps and please cite the source provided at the end of the list.

These Steps are the heart of GMO Eradication. Please consider them carefully and implement them as soon as possible. We all have to get down to business and be disciplined about this if we hope to win this thing. We have to do it together; please be a leader.



1) Learn which foods are GMO and do not buy them (unless organic). The current GM food crops are:

  • Corn (includes “sweet corn”)
  • Soy  (includes lecithin)
  • Sugar beets
  • Honey (via GMO crops’ pollen)
  • Cotton (including cottonseed oil)
  • Canola (including canola oil)
  • Alfalfa
  • Hawaiian papaya
  • Tobacco
  • Yellow crookneck and zucchini squash,
  • Dairy Products (tainted with rBGH and from animals fed GM food)
  • Meat (all kinds, from animals fed GM food)
  • Salmon (the actual animal is slated to be GMO)
  • (Hydrolyzed Vegetable Protein), TVP (Textured Vegetable Protein), xanthan gum, vanillin, sucrose, lactose, dextrose, lactic acid, maltodextrin, Vitamins A, B2, B6, B12, C, D, E, K may be from GMO.

2) Print out the list and carry it with you; memorize it if you can.

3) Check food labels for GMO ingredients; if they are not listed as organic, they are likely GMO. Don’t buy it. Exceptions are products that bear the “NON GMO Project” label.

a) Example 1: Canola is a GMO crop. If a product contains canola oil and does not specify it is organic, it is likely GMO. Don’t buy it.

b) Example 2: Soy is a GMO crop. Tofu, tempeh, and soy yogurt are all made from soy. Also check for soy in veggie burgers and veggie sausages. If it is not organic don’t buy it.

4) Buy as little commercially farmed processed food and as much organic food as possible. Processed foods are more likely to have GMOs as well as hidden GMO ingredients.

a) Example 1: Corn is a GMO crop. Corn syrup, vitamin E, citric acid, polysorbate 80 and sodium citrate all can be derived from corn, and likely from GMO corn.

b) Example 2: Commercial beef, chicken, and turkey are almost always fed GM food. Only buy organic meat. “Free Range” meat is not necessarily organic.

5) Avoid commercial restaurants. Restaurants that are not specifically organic (far and few between), often use cheap food, which is often GMO and non-organic.




6) Share information about the dangers of GMO foods with everyone you can. Share with them any of myarticles, Jeffrey Smith’s video(s), or just Google it.

7) Ask grocery stores and restaurants, family and friends, not to deal in GM foods. Talk to your children’s’ food director/organizer at school. Everywhere you go, let food-related organizations and people know: NO GMO.

8.) Call or email food companies that do not specify suspect ingredients as GMO and ask if they are GMO.

a) Example 1: Soy lecithin is often GMO. Call companies that make foods with soy lecithin and ask if it is from GMO soybeans. As them to send you verification in writing by email.

b) Example 2: If a label says “sugar” it may come from sugar beets, which are a GMO crop. Call the label’s company and proceed as with lecithin example.

c) Example 3: I recently called Twinlab, Kal, and Lessaffre (makers of Red Star Yeast) companies, all manufacturers of nutritional yeast products. Only one, Kal Brand, told me they guarantee both the yeast and the culture medium for the yeast (often corn and beet, both GMO crops) to be non-GMO. I told the others I would not buy their products until they guarantee non-GMO on the label.

9) Encourage anyone you know not to use Roundup because it is integral to GM food production, much more toxic than once suspected, and buying it supports Monsanto



10) Organize rallies, protests, donate to and support organic groups, create and circulate petitions, set up information booths, and begin a public outreach to masses of people to denounce GMOs and support organics.

Additional actions: pass out GMO warning flyers, write articles, post notes at work, go to protests, Google GMO articles and videos. Host movie nights.

11) Plant that organic garden already! And get your family and community involved.

Source: GMO Eradication Movement – GEM (Facebook Page)



In sum, the overall safest, healthiest, and most economical way to empower our GMO Eradication Movement is to buy whole organic foods, grow you own, prepare your own meals, and buy from as many local organic farmers as possible.

If a food is organic it is not GMO. Knowing GM food crops will tell you which foods to look out for in their non-organic form. If not organic, a food may still be non-GMO, but this is becoming more and more unlikely. For example, sugar beets come organic, GMO, and conventionally grown (often grown with pesticides and synthetic fertilizers, but not necessarily GMO). Organic sugar beets are non-GMO. Conventionally grown sugar beets might be GMO (you have to ask), but best to avoid because they are likely laden with pesticides.

If a food ingredient contains “sugar,” it is likely GMO because a lot of sugar comes from GMO sugar beets! If the label reads “cane sugar” it likely has pesticide residues but at this point in time is not GMO. Health tip: stay away from “sugar” for good physical and emotional health and to be a GEM!


* Vitamin C (ascorbic acid) can be made from GMO corn

* Vitamin D and vitamin K may have “carriers” derived from GMO corn (such as   glucose, sugar, starch, and maltodextrin)

* Vitamin E is often made from soy

* Vitamins A, B2, B6, and B12 may be derived from GMO sources

Remember “All Natural” and “Natural” labels don’t mean squat. These foods can still be GMO.

Thank you for becoming a GEM, not a GMO! The 11 Steps can be downloaded here on one convenient page, though without the “examples” mentioned in the 11 steps above. Please share the 11 Steps everywhere you can and join us on Facebook.

In Solidarity,


from:   http://wakeup-world.com/2012/03/11/11-steps-for-gmo-eradication-help-grow-the-gem/