A Food Color Safety Petitionwas submitted to U.S. Food and Drug Administration on March 22, 2011 by FIHRI, Institute of Neurotoxicology and Neurological Disorders, American Association of Intellectual and Developmental Disorders, TRANSCEND Research/Neuroscience, Institute for Agriculture and Trade Policy and Government Accountability Project. Download PDF file below and for more information read Food Color FAQs.
What do food color additives and corn syrups have in common? Both kinds of ingredients may contain heavy metal residues due to their manufacturing processes.
Federal and international food regulations allow mercury and other heavy metal residues in certain food ingredients due to their manufacturing process (1, 2). Using a certification process, the U.S. Food and Drug Administration (FDA) regulates the allowable amount of heavy metal residue in each batch of synthetic food color (2). Yellow #5, yellow #6, and red #40 are all synthetic food colors made from petroleum that is extracted from deep inside the earth. These food colors must undergo the certification process to ensure they do not contain more than 1 ppm mercury, 10 ppm lead and 3 ppm arsenic in each batch (2).
How do we know that mercury can be found as an impurity in high fructose corn syrup? Three different studies have found mercury in high fructose corn syrup and/or products containing high fructose corn syrup (3, 4, 8). The results of two of these studies were published in a peer reviewed science journal. How do we know that mercury in food color additives and high fructose corn syrup is harmful to children?
Studies have shown that consumption of food color or corn syrup ingredients may lead to zinc loss and/or deficiency in humans (5, 6, 7). Mercury exposure through the consumption of high fructose corn syrup and food color additives may alter metabolism in children leading to zinc deficiency. Such deficiency may impact learning in hyperactive and autistic children. One review article published by Dufault et al. in the Behavioral and Brain Functions Journal in 2009 provides a model that explains how this may happen (9).
Another article published in the Lancet in 2007 by McCann et al describes a study in which children were given a daily dose of food color additives in the United Kingdom and then their behavior was tracked in three different ways by different observers (10). The authors concluded that artificial colors or a sodium benzoate preservative (or both) in the diet result in increased hyperactivity in 3-year old and 8/9 year -old children in the general population. The authors of course did not know to look for mercury in the food colors or even to determine that the healthy children had likely been exposed to mercury. We can only presume that the children probably had mercury exposure based upon the fact that the food colors in the McCann study are allowed by law to contain a certain level of mercury in them (2). In clinical trials long ago, Dr. Neil Ward found that hyperactive children showed a significant reduction in zinc over a relatively short period time with the consumption of certain food colors - FD & C #5 Tartrazine and FD & C #6 Sunset Yellow (6, 7). The model published in 2009 by Dufault et al in the Behavioral and Brain Functions journal explains how this zinc deficiency may occur when mercury exposure occurs through the consumption of food color additives (9). Do all governmental food safety agencies share FDA's view that it is ok to expose children to low levels of inorganic mercury, lead and arsenic when they eat breakfast cereals or drink beverages containing ingredients with allowable heavy metal residues? It is important for the consumer to realize that the United States FDA has a point of view that is not shared by all governments. For example, since 2010, the United Kingdom (UK) Food Standards Agency has been warning parents about the impact harmful food color additives may have on their children (11). Foods in the UK that contain sunset yellow (yellow #6), tartrazine (yellow #5), allura red (red #40) or other synthetic colors made from petroleum must bear the following warning label on the food packaging: may have an adverse effect on activity and attention in children (11). All countries in the European Union have the same warning label requirement (12). Has the Food Ingredient and Health Research Institute done anything to try to educate FDA on the dangers of exposing children to these harmful food colors? In 2011, we put together a petition and submitted it to FDA for consideration by the Food Advisory Committee members. Representatives from the following non-profit groups signed our petition. Steven G. Gilbert, PhD - Institute of Neurotoxicology and Neurological Disorders http://toxipedia.org/display/toxipedia/The+Institute+of+Neurotoxicology+and+Neurological+Disorders+%28INND%29 Renee J. Dufault, DHEd (candidate) - Food Ingredient and Health Research Institute http://www.foodingredient.info/
Amanda Hitt, MPH, JD - Government Accountability Project http://www.whistleblower.org David Wallinga, MD - Institute for Agriculture and Trade Policy http://www.iatp.org Martha Herbert, MD - TRANSCEND Research/Neuroscience http://nmr.mgh.harvard.edu/transcend/ Joyce Martin, JD - American Association of Intellectual and Developmental Disabilities http://www.aaidd.org Along with our petition we provided a power point that was presented for the American Association of Intellectual and Developmental Disabilities explaining how consumption of certain food colors and high fructose corn syrup leads to zinc deficiency and impacts learning in children. We have not heard back from the FDA on our petition so we don't know if they read it or not. Is there any reason to explain why FDA would continue to allow these food color additives if they are harmful to children? It is hard to say why FDA would continue to allow these food color additives when evidence seems to indicate they are clearly harmful to some children. One explanation may have to do with the way FDA is funded to accomplish its mission of food safety. FDA earns money from certifying food color additives. For every batch submitted to FDA for certification, the manufacturer must pay fees. Part of FDA's mission is to provide services to food manufacturers for fees rendered and the fees are used to pay the operating costs of the FDA programs providing the services. As long as FDA employee salaries and programs are paid for by industry user fees, FDA will not be in a position to survive as a regulatory agency unless Congress makes changes in the way FDA programs are funded. Where can I go to find out what foods contain these potentially harmful food color additives? You can educate yourself while you are at the grocery store. Read the ingredient label on each food package before you decide to buy it. If the label indicates the product contains yellow #5, yellow #6 or red #40, then don't buy it. What can I do if I am a concerned about the safety of food color additives in our food supply? Write your local U.S. representative and senator. Write your state representative and senator. Ask your representatives and senators to sponsor a bill to require warning labels on foods containing certified food colors. Congress must tell FDA to require the warning labels on food packaging. FDA will not mandate the warning labels unless Congress passes a bill. The California legislature has a label bill under consideration (13). You can send a link to that bill to your representative so he or she does not have to write the bill from scratch.
(10). McCann et al. Food additives and hyperactive behavior in 3-year-old and 8/9-year-old children in the community: a randomized, double-blinded placebo-controlled trial. Lancet 2007, 370(9598):1560-1567. Pub Med Link to McCann et al.