193
Our Polluted Food—fact
or
fancy?
FOOD ADDITIVES — IS THERE A SPECTRE AT THE FEAST?
DAPHNE GROSE M.B.E., B.A. Head of Representation ’Which?’ Consumers’ Association restaurant in Brussels. been in the Common the Referendum was still to come. The fish was good and I was trying not to think about the reports I had read on the heavy contamination of mussels and other fish. This was difficult. My normally good companion from France was explaining with great passion that British consumers had their heads in the sand. Future generations could be threatened. We were not talking about the peace of Europe or social or agricultural policy, but about food additives. She was utterly convinced of the potential toxic effects of colours on the foetus. The sulphur dioxide in the wine, and the possible mercury in the fish were spectres at the feast. Last summer CA’s Head of Research returning from a holiday in France came rushing into my room at the office to describe how people in France were actually demanding to be told by shopkeepers if the food they were buying contained amaranth and certain other’reds and yellows, In April the Union Federale des Consommateurs had issued a call for people to avoid sweets, ice cream, drinks, cakes, cheese crusts and even meat wrappers containing certain additives. In contrast, last November Consumers’ Association discussing in its magazine Which? the improvers in bread, said mildly, &dquo;It’s a pity that the necessary testing, first called for in the previous report of the [Food Additives and Contaminants Committee] in 1960, has still not been completed&dquo;. This remark caused little comment. Why are we seemingly so different? Which country has the right attitude?
WAS
SITTING in
~ Britain had -~Market, and
,
not
a
long
ARE CONSUMERS WORRIED? ARE FOOD products safe for their intended use? Are the mysterious emulsifying salts necessary and without danger? Is caramel as harmless as it sounds? To the vast majority of us, including a surprising number with scientific training, this question appears to be simple to answer. In a survey carried out by CA’s survey unit in 1971 over ninety per cent of respondents agreed with the statement that additives should not be allowed until proved safe. Only a fifth were prepared to agree that an additive should be allowed so long as a wide margin of safety existed between the no-effect level found in animal experiments and levels permitted in foods for human consumption. We demand that our foods be absolutely safe. Most of us do not understand that abso-
does not exist for eating and drinking any than it does for any other activity. An effort has to be made to convince us that life is not so simple. We are able to accept the risk of driving a motor car, mending an electrical appliance, drinking alcohol, but are truly unhappy about any degree of risk from ’chemicals’ in food. The difference between us and our European cousins is one of degree. Last year during in-depth interviews with housewives as part of another CA survey one woman said &dquo;Like I said before, we don’t know what they are and what they do to the food and why they are in there.&dquo; Such uncertainty is most worrying. Food is an emotional subject. Water, warmth and food are the essentials of survival. In our complex technically advanced western world, where so many of us eat too much, the old associations fostered by advertising imagery linger on. Even so food, and particularly ’good’ and ’pure’ food, still does not have quite the status here that it has on the Continent, but deep down we have feelings of guilt. We suspect we should be more worried than we are. CA’s 1971 survey emphasised that people in this country have great faith in government and trade. Typical comments from the people interviewed were, &dquo;They can’t let the food get on the market and nobody check it&dquo;. &dquo;By a natural process there must be somebody. Who he is I don’t know, but there must be somebody&dquo;. &dquo;Surely there is some sort of food guidance council and governing body that wouldn’t allow something to be put on the market if there was any harm in it.&dquo; Almost seventy per cent of the respondents thought that all additives can be used only in a limited number of specified foods and in fixed quantities. In other words, they thought that the very strictest controls which are peculiar to preservatives applied to all additives. Those who are informed, know that if a colour, emulsifier, or miscellaneous additive is on the permitted list, then with one or two exceptions, they can be used in the majority of processed foods. Nonetheless we trust that because the additives have been cleared for inclusion on the permitted list, all is well. Our Continental neighbours are saying to us that this is euphoria. They are more sceptical. I sometimes suspect too that they underestimate the use of additives in their own foods. lute
safety
more
DO WE NEED ADDITIVES? VERY FEW people, whether here
or
overseas, would
194
argue that we could manage entirely without preservatives and antioxidants except at huge costs in establishing a temperature controlled chain of distribution and changing to other methods of production. For preservatives the questions centre on the adequacy of the toxicological testing and the degree of urgency with which alternative anti-microbical and other agents are being investigated to replace present additives which are under suspicion. When we turn to the multitude of other then the ordinary person becomes
additives,
bewildered and worried. In 1975, according to one survey, sales of food additives in West Germany, France,
Belgium, Netherlands and United Kingdom totalled £175m. Preservatives and antioxidants were said to account for only about six per cent of additives usage by value. Flavours, flavour enhancers, thickeners and stabilisers, emulsifiers, food acids, colours, sweeteners make up most of the rest of the sales. (Surprisingly, since they are considered strongly anti-additive, West Germany was estimated to be the largest of the national markets with an additive usage of about £60m. a year for the products studied.) When to these are added anticaking agents, antifoaming agents, humectants,
release agents and several more, then the non-technical mind begins to boggle. Trade tells us that we vote for the use of these additives by our buying habits. We will not buy brown-green canned peas or food which is unevenly coloured. We like oils which are not easily absorbed by the food it is frying. We are unhappy when powders clog. This is a very old argument. In the last century the early cooperative movement sent out to travel Britain to convince people that tea did not have to be bright green. In those days the colours and adulterants used in food were acutely toxic and scandalous, but trade argued that people wanted adulterated food because it was cheap and that they would not buy tea unless it was bright green. Is the argument as false today as it was then? Should the authorities be saying that many additives are not necessary and that we can live without them.
speakers
SHOULD WE BE WORRIED? WHEN CONSUMER representatives talk to the food industry about additives, they are made to feel alarmist and irresponsible, if they suggest that there is the slightest degree of risk. Civil servants often point out that no one has ever been known to have suffered any harm, either in the short- or the long-term, from an additive and point to the recorded dangers of some of the natural constituents and contaminants of food such as the heavy metals. They stress the amount of research that has already taken place and that additives must be fairly low in the list of priorities for government expenditure on research. Seeming fiascos such as the cyclamate scare and the more recent and extremely inelegant experiments in the United States on the red dye No. 2, (amaranth) have tended to increase sympathy for a cool and fairly relaxed attitude to additives. However, there are a series of facts which cannot be forgotten. Very distinguished scientists do express fears about the total load of substances that people inhale and ingest. Also, official attitudes were not so different in 1960 when little testing for safety had been done, particularly for colours. Subsequent work has resulted in a number of additives no longer being permitted. The results of the short- and long-term tests on animals in these cases caused the authorities, on scientific advice, to take this action. Further, these tests may not provide the whole answer. Even a layman can grasp from the scientific literature that there is no simple formula for assessing
hazards from prolonged and repeated exposure to low doses of substances of any type. It is possible that the question of their combined effect on the nutrients could be as important as the possible mutagenic effect. Add to this the very high cost of present animal including metabolic tests, (a rough, overall estimate for exhaustive tests on one substance is over £150,000) and it is easy to see that the answers may not come quickly. Therefore no consumer organization could say without qualification &dquo;Do not worry. There is absolutely no question of any risk either today or in the future&dquo;. Nevertheless most of the additives now permitted have been tested by more than one team of researchers and their use is controlled. We can but try and get the whole question into perspective and we can only do that if we are given information and feel that nothing is being kept back. TRUST US!
TOXICOLOGISTS AND food scientists are often on the defensive. Consumers and their representatives including the mass media want clear cut answers. Is the additive safe or is it not? Is the pesticide harmful or is it not? Maybe, appears to be equivocation. Then further to foul communication, scientists do not always agree, or
their comments are taken out of context. The amaranth scare is typical of the problem. In earlier years consumer organizations heard of adverse results from tests in Eastern Europe. They were then told further work would be done in Europe and North America. The next event is the appearance in the press of alarming reports from the United States followed by highly critical comments on the quality of the toxicological research from other scientists. There is little doubt now that the not of the best but, in several European counwork was tries, amaranth or Red No. 2 has become a dirty word. Consumer confidence has been destroyed. The same problem arises with all environment hazards. One evening this past autumn there was a documentary on television about dioxin, the villain of the explosion at Seveso which is also a contaminant found in the weedkiller 2,4,5-T. On the programme scientists in the United States explained the acute toxicity at very low levels of dioxin, and urged the banning of the weedkiller. Soon after a reassuring statement was made in the House of Commons. How could there be this conflict? Apparently the two countries use different production processes and the British product has no measurable dioxin. Of course this leaves unanswered the question of imports and the actual dangers of production, but it explains how easy it is for the public to be confused by partial facts. The fault is not entirely with the media or the consumer organizations. Scientists seem to be divided into two classes. Those who love and seek publicity and broadcast limited and questionable results before these have been adequately assessed. While their opposites challenge the public’s right to know. These are the scientists who despise the layman and believe all sciencebased decisions should be taken in private by the very few and that their advice should never be questioned. Neither group attempts to provide the well-balanced but open explanation of an admittedly difficult subject. However, if it is not attempted, no-one has the right to complain if people in general react irrationally. This is a most important matter at this time. CA has long been concerned that questions of safety in relation to pesticides have been taken behind closed doors and that some of the toxicological evidence on which decisions have been reached is regarded as confidential
195 commercial information. The sitution with food additives is very much better. The Food Additives and Contaminants Committee has published its reports although circulation recently has been more limited since the shorter reports have not been published by the Stationery Office. The reports of the Joint FAO/WHO Expert Committee on Food Additives have been particularly good in explaining the reasoning behind the experts’ opinions. Now, however, decisions will increasingly be taken in Brussels, and will be based on the advice of the Scientific Committee for Food. Unfortunately they do not always give the references to the research on which their decisions are based, for example the Opinion on colours of June 1975. If the people of Europe are to have faith in their conclusions we must be given, to use legal jargon, better and fuller
particulars.
The fact is that additives have been withdrawn from by governments and the public has not noticed. It is only when there is controversy about the toxicological data that there may be a communication problem. This reinforces the case for greater openness. The need is all the greater because the number of people who have the expertise to interprete the toxicological data is limited so there are few experts that can be consulted by consumers and journalists who were not involved in the original decisions. In these circumstances we must either trust them or disbelieve them. It is easier to believe if the decisions are fully explained. use
WHAT DO WE EAT? SCIENTISTS AND officials constantly remind those of us who try to represent the consumer interest, that the size of dosage is all important. Of course they also add that the figures for acceptable daily intakes of pesticides and additives laid down by international and national authorities are arbitrary and that small differences at such low levels cannot make a vital difference to the general safety of the population. Nevertheless the figures exist and the amount ingested would seem to be crucial. The lack of evidence of intake is therefore startling. Studies have been mainly based on the production and usage of additives by industry, and not related to actual food eaten by individuals. Manufacturers are asked to supply details of additive levels in foods and estimates on intake are then made on basis of intake of the foods. This probably gives a very high estimate of additive intake, which may provide a builtin safety factor; particularly as ’shopping basket’ studies cannot take into account the ’loss’ of additives due to processing and cooking. So maybe there is nothing to worry about. However, if it was known how many grams of colours a normal child eats every year there might be cause for alarm. Think of a pack of children’s sweets. Add to the sweets such favourites as orange drinks, biscuits, fish fingers, soup and it begins to seem a very good idea that the intake of various groups of children should be investigated. The problem is that there are so many questions to be asked about the food we eat. In 1966 the Panel on the Residues of Pesticides in Foodstuffs set up a study of residues in the total diet to gain information about the intake by the average person in the U.K. of pesticide contaminants from the diet as a whole. More recently studies of the intake of heavy metal have taken place. When the consumer organisations ask for similar studies for other contaminants and additives, they are reminded of the cost of such work and asked to decide on priorities. In a list that includes for example mercury, asbestos and the PCBs, the additives must come
low
on
the list. Nevertheless there is
a
strong
case
for
a
special study with children. Possibly the Food Additives and Contaminants Committee will have something to say
on
this in its next report soon. It should.
on
colours which is
expected
ARE GOVERNMENT CONTROLS ADEQUATE? THERE IS a series of questions that governments have to answer. Should they like the U.S.A. allow all additives which can in the light of existing toxicological data be placed on a positive list? This procedure may reduce the likely intake of any one additive, but allows the widest use of additives. Or should they like the U.K. restrict the permitted additives to the smallest number consistent with technological need? Such a restriction may increase the intake of individual additives but might, in the long-term, contain the use of additives. The second seems the better method but how does one define technological need? The International Organization of Consumers Unions as an Observer at the FAO/WHO Food Standardization Programme’s meetings (otherwise known as the Codex Alimentarius Commission) has found itself at the centre of controversy about technological need and asked to say whether or not people want a colour. This is not an easy question to answer. Colour is important to people. Yet many governments and consumers believe that colours can be used, particularly with fruits and vegetables, to disguise the use of poor quality produce or bad processing. Possibly the answer will be decided by the toxicological data. The number of all types of permitted colours in the U.K. has fallen to forty eight. Others may be removed in the future. The blue dye used in canned peas has been challenged by the EEC who have called for more testing. The food industry would be wise gradually to accustom people to less highly coloured food. Why should not the frozen food industry over time fade our fish fingers to the colour of those sold in France? We might not even notice. Sweden has adopted such a policy. Consumer organizations have been asked to support an alternative technological development. The most suspect of the colours are the azo dyes. Alternative synthetics are the dyes which duplicate the pigments found in nature. Of course some food firms, in any case, make a point of using only colours, such as carotene, from vegetables and similar sources. We certainly support the use of the ’natural’ and ’natural-identical’ dyes since the odds in favour of them being safer than the azo dyes seem considerable. However we feel compelled to be somewhat dog-in-the-manager in our attitude and out that natural products too need to be tested for safety, that even with these additives an excess may not be good. Above all, we cannot support the proposition that ’nature-identicals’ should be called ’natural colours’. Their chemical structure may be the same but they do not come from the vegetable kingdom and that is the meaning given by people to the word natural in this context. Neither the food industry or the government are the adequate likely to have the necessary resources testing of all the additives the processors would like to use. Producers, consumers and governments should together decide which additives are essential. For these the resources for testing must be found. For example, although the question was never posed most people would probably think it right that large resources have been put by government and industry into research into the hazards thought to be associated with nitrites and cured meats. However, industries should not be
point
for
196 allowed to go on using additives, and particularly those only offering sensory or other ’improvements’, when they are not willing to spend the money to satisfy the recognised scientific authorities that the additive is toxacceptable. The answer must be no. icolo~ically This does not resolve the difficult question of the
thousands of flavours which are used. In parts of Europe a distinction is made between natural and natural-identical flavours and artificial flavouring. The U.K. has argued that there should be permitted lists for both types with exemptions for natural food substances. This is right. However, the first permitted list is likely to resemble the earliest list of colours and few of the substances included will be covered by adequate data. It will take a long time to check the flavours. Nonetheless the gap between actual practice and consumer expectations and belief that all additives are tested, controlled, and limited as to use, should be closing. In due course there should be a positive list for flavours. No additive should be permitted for use unless it is on a positive list. Permitted colours should be restricted in use. Even acids, which occur naturally in food, and are used as additives to change or stabilize the acidity of food should be reviewed and, if the quantity in the diet is getting out of balance, controlled. One more question, enforcement, should concern the authorities. At this time of financial stringency, local authorities do not welcome questions about the extent of enforcement of the food laws. This is understandable. Trade, too, resents questions about compliance. They, again understandably, think it reflects on their integrity. Yet it is wrong, in discussing this matter, to fall back on the possibility that imports may be breaking the law. The facts are that consumers cannot themcheck if the foods they purchase comply with the law. They have a right to ask the authorities for an assurance that the safety requirements for additives are being met. How can the question be answered if a reasonable number of samples are not checked from time to time. At present there is no systematic and organized check. Further, while the colours are easy to check, some additives which are not permitted are not easily distinguished from the permitted additives within the same class. Progress is needed within the area of enforcement.
selves
CAN FOODS WITHOUT ADDITIVES BE SELECTED? APPARENTLY MANY people trust the Government to look after them when it comes to the safety of additives but are most sceptical as to whether they are told the truth on food labels. CA’s survey work has shown that many people do not realize that the lists of ingredients on labels are there by law, with one or two exemptions, and that these lists must include all the ingredients, with the exception of water, including additives. They are further confused because some permitted additives preservatives, antioxidents, emulsifiers, stabilizers, colours and flavours may by law be declared by this generic name while other additives, such as pH regulators, are declared by their specific name. So the following list of ingredients is typical: &dquo;Ingredients: -
-
f.
B~ . ’ .
’1- ’ .,B;1z ~ .
_
,
.
skimmed milk, sugar, butter,
glucose syrup, double whey solids, emulsifier, stabilizers, sodium citrate, colour, flavouring&dquo;. (Incidentally, thank you to the ice cream producer who voluntarily gives a list of ingredients.) There is no justification in logic or use for cream,
this mixed system. All additives should be declared either by their specific name or by statutory generic names. Or should both pieces of information be given? CA had to decide whether to back the use of generic (functional) names or specific names for additives. Research produced the interesting information that just over half the people in a quantitative survey (when shown two labels) favoured the generic terms of ’flavouring’ and ’colouring’ to the list of specific chemical designations, and less than a third positively favoured specific designations. However, during indepth interviews, a third possibility was the most preferred. This was specific ingredients listed under generic names. The case against specifics alone is obvious. To most people BHT or carotene is a foreign language. The specific name will not tell buyers why the additive has been added to the food. The specific designation may, and this is a subjective judgment, cause shoppers to decide that they cannot understand the lists of ingredients and, therefore, cease to read them. On the other side of the debate, certain consumer organizations argue that individuals have allergic reactions to additives and need the specific information. Officials reject this argument because the evidence, at present, is so limited. Possibly more convincing to them would be the point that the use of specifics enable the authorities to know the likely in-take by groups of the population of any one additive. It also assists enforcement. The EEC is offering a solution to the debate. As EEC permitted lists of additives are agreed, each additive is allocated a number. The draft food labelling directive proposes that both the generic name and the E-number should be given. Already some manufacturers with an export trade have adopted this practice. The list of ingredients are not impossibly long but anyone who wants to check the specific additives can do so. In Sweden the shops supply lists identifying the E-numbers. The one obstacle is the lack of functional names for anti-caking agents, pH regulators and so on. Surely trade and consumer bodies could produce generics that would indicate function without being as precise as ’pH regulator’. We must try. Any way the British consumer organizations are supporting the EEC proposal. In conclusion 1 return to my conversation with my French friend. She has not convinced me that there is at this time sufficient evidence for me to stand up and call for the banning of all additives. I suspect that there are contaminants that may be a far greater danger. I suspect that in time we may be able to conclude, without reservation, that the dangers to individuals of food additives were small. However, even if the chance of serious damage is a one-in-a-ten-million chance, we have the right to demand a duty of care from all concerned. The authorities should err on the side of caution. They must also recognize the right of consumers to be told what is in the food they eat, why it is there, and what has been done to try and ensure that it is safe.
Our Polluted Food—fact
or
fancy?
FOOD ADDITIVES — IS THERE A SPECTRE AT THE FEAST?
DAPHNE GROSE M.B.E., B.A. Head of Representation ’Which?’ Consumers’ Association restaurant in Brussels. been in the Common the Referendum was still to come. The fish was good and I was trying not to think about the reports I had read on the heavy contamination of mussels and other fish. This was difficult. My normally good companion from France was explaining with great passion that British consumers had their heads in the sand. Future generations could be threatened. We were not talking about the peace of Europe or social or agricultural policy, but about food additives. She was utterly convinced of the potential toxic effects of colours on the foetus. The sulphur dioxide in the wine, and the possible mercury in the fish were spectres at the feast. Last summer CA’s Head of Research returning from a holiday in France came rushing into my room at the office to describe how people in France were actually demanding to be told by shopkeepers if the food they were buying contained amaranth and certain other’reds and yellows, In April the Union Federale des Consommateurs had issued a call for people to avoid sweets, ice cream, drinks, cakes, cheese crusts and even meat wrappers containing certain additives. In contrast, last November Consumers’ Association discussing in its magazine Which? the improvers in bread, said mildly, &dquo;It’s a pity that the necessary testing, first called for in the previous report of the [Food Additives and Contaminants Committee] in 1960, has still not been completed&dquo;. This remark caused little comment. Why are we seemingly so different? Which country has the right attitude?
WAS
SITTING in
~ Britain had -~Market, and
,
not
a
long
ARE CONSUMERS WORRIED? ARE FOOD products safe for their intended use? Are the mysterious emulsifying salts necessary and without danger? Is caramel as harmless as it sounds? To the vast majority of us, including a surprising number with scientific training, this question appears to be simple to answer. In a survey carried out by CA’s survey unit in 1971 over ninety per cent of respondents agreed with the statement that additives should not be allowed until proved safe. Only a fifth were prepared to agree that an additive should be allowed so long as a wide margin of safety existed between the no-effect level found in animal experiments and levels permitted in foods for human consumption. We demand that our foods be absolutely safe. Most of us do not understand that abso-
does not exist for eating and drinking any than it does for any other activity. An effort has to be made to convince us that life is not so simple. We are able to accept the risk of driving a motor car, mending an electrical appliance, drinking alcohol, but are truly unhappy about any degree of risk from ’chemicals’ in food. The difference between us and our European cousins is one of degree. Last year during in-depth interviews with housewives as part of another CA survey one woman said &dquo;Like I said before, we don’t know what they are and what they do to the food and why they are in there.&dquo; Such uncertainty is most worrying. Food is an emotional subject. Water, warmth and food are the essentials of survival. In our complex technically advanced western world, where so many of us eat too much, the old associations fostered by advertising imagery linger on. Even so food, and particularly ’good’ and ’pure’ food, still does not have quite the status here that it has on the Continent, but deep down we have feelings of guilt. We suspect we should be more worried than we are. CA’s 1971 survey emphasised that people in this country have great faith in government and trade. Typical comments from the people interviewed were, &dquo;They can’t let the food get on the market and nobody check it&dquo;. &dquo;By a natural process there must be somebody. Who he is I don’t know, but there must be somebody&dquo;. &dquo;Surely there is some sort of food guidance council and governing body that wouldn’t allow something to be put on the market if there was any harm in it.&dquo; Almost seventy per cent of the respondents thought that all additives can be used only in a limited number of specified foods and in fixed quantities. In other words, they thought that the very strictest controls which are peculiar to preservatives applied to all additives. Those who are informed, know that if a colour, emulsifier, or miscellaneous additive is on the permitted list, then with one or two exceptions, they can be used in the majority of processed foods. Nonetheless we trust that because the additives have been cleared for inclusion on the permitted list, all is well. Our Continental neighbours are saying to us that this is euphoria. They are more sceptical. I sometimes suspect too that they underestimate the use of additives in their own foods. lute
safety
more
DO WE NEED ADDITIVES? VERY FEW people, whether here
or
overseas, would
194
argue that we could manage entirely without preservatives and antioxidants except at huge costs in establishing a temperature controlled chain of distribution and changing to other methods of production. For preservatives the questions centre on the adequacy of the toxicological testing and the degree of urgency with which alternative anti-microbical and other agents are being investigated to replace present additives which are under suspicion. When we turn to the multitude of other then the ordinary person becomes
additives,
bewildered and worried. In 1975, according to one survey, sales of food additives in West Germany, France,
Belgium, Netherlands and United Kingdom totalled £175m. Preservatives and antioxidants were said to account for only about six per cent of additives usage by value. Flavours, flavour enhancers, thickeners and stabilisers, emulsifiers, food acids, colours, sweeteners make up most of the rest of the sales. (Surprisingly, since they are considered strongly anti-additive, West Germany was estimated to be the largest of the national markets with an additive usage of about £60m. a year for the products studied.) When to these are added anticaking agents, antifoaming agents, humectants,
release agents and several more, then the non-technical mind begins to boggle. Trade tells us that we vote for the use of these additives by our buying habits. We will not buy brown-green canned peas or food which is unevenly coloured. We like oils which are not easily absorbed by the food it is frying. We are unhappy when powders clog. This is a very old argument. In the last century the early cooperative movement sent out to travel Britain to convince people that tea did not have to be bright green. In those days the colours and adulterants used in food were acutely toxic and scandalous, but trade argued that people wanted adulterated food because it was cheap and that they would not buy tea unless it was bright green. Is the argument as false today as it was then? Should the authorities be saying that many additives are not necessary and that we can live without them.
speakers
SHOULD WE BE WORRIED? WHEN CONSUMER representatives talk to the food industry about additives, they are made to feel alarmist and irresponsible, if they suggest that there is the slightest degree of risk. Civil servants often point out that no one has ever been known to have suffered any harm, either in the short- or the long-term, from an additive and point to the recorded dangers of some of the natural constituents and contaminants of food such as the heavy metals. They stress the amount of research that has already taken place and that additives must be fairly low in the list of priorities for government expenditure on research. Seeming fiascos such as the cyclamate scare and the more recent and extremely inelegant experiments in the United States on the red dye No. 2, (amaranth) have tended to increase sympathy for a cool and fairly relaxed attitude to additives. However, there are a series of facts which cannot be forgotten. Very distinguished scientists do express fears about the total load of substances that people inhale and ingest. Also, official attitudes were not so different in 1960 when little testing for safety had been done, particularly for colours. Subsequent work has resulted in a number of additives no longer being permitted. The results of the short- and long-term tests on animals in these cases caused the authorities, on scientific advice, to take this action. Further, these tests may not provide the whole answer. Even a layman can grasp from the scientific literature that there is no simple formula for assessing
hazards from prolonged and repeated exposure to low doses of substances of any type. It is possible that the question of their combined effect on the nutrients could be as important as the possible mutagenic effect. Add to this the very high cost of present animal including metabolic tests, (a rough, overall estimate for exhaustive tests on one substance is over £150,000) and it is easy to see that the answers may not come quickly. Therefore no consumer organization could say without qualification &dquo;Do not worry. There is absolutely no question of any risk either today or in the future&dquo;. Nevertheless most of the additives now permitted have been tested by more than one team of researchers and their use is controlled. We can but try and get the whole question into perspective and we can only do that if we are given information and feel that nothing is being kept back. TRUST US!
TOXICOLOGISTS AND food scientists are often on the defensive. Consumers and their representatives including the mass media want clear cut answers. Is the additive safe or is it not? Is the pesticide harmful or is it not? Maybe, appears to be equivocation. Then further to foul communication, scientists do not always agree, or
their comments are taken out of context. The amaranth scare is typical of the problem. In earlier years consumer organizations heard of adverse results from tests in Eastern Europe. They were then told further work would be done in Europe and North America. The next event is the appearance in the press of alarming reports from the United States followed by highly critical comments on the quality of the toxicological research from other scientists. There is little doubt now that the not of the best but, in several European counwork was tries, amaranth or Red No. 2 has become a dirty word. Consumer confidence has been destroyed. The same problem arises with all environment hazards. One evening this past autumn there was a documentary on television about dioxin, the villain of the explosion at Seveso which is also a contaminant found in the weedkiller 2,4,5-T. On the programme scientists in the United States explained the acute toxicity at very low levels of dioxin, and urged the banning of the weedkiller. Soon after a reassuring statement was made in the House of Commons. How could there be this conflict? Apparently the two countries use different production processes and the British product has no measurable dioxin. Of course this leaves unanswered the question of imports and the actual dangers of production, but it explains how easy it is for the public to be confused by partial facts. The fault is not entirely with the media or the consumer organizations. Scientists seem to be divided into two classes. Those who love and seek publicity and broadcast limited and questionable results before these have been adequately assessed. While their opposites challenge the public’s right to know. These are the scientists who despise the layman and believe all sciencebased decisions should be taken in private by the very few and that their advice should never be questioned. Neither group attempts to provide the well-balanced but open explanation of an admittedly difficult subject. However, if it is not attempted, no-one has the right to complain if people in general react irrationally. This is a most important matter at this time. CA has long been concerned that questions of safety in relation to pesticides have been taken behind closed doors and that some of the toxicological evidence on which decisions have been reached is regarded as confidential
195 commercial information. The sitution with food additives is very much better. The Food Additives and Contaminants Committee has published its reports although circulation recently has been more limited since the shorter reports have not been published by the Stationery Office. The reports of the Joint FAO/WHO Expert Committee on Food Additives have been particularly good in explaining the reasoning behind the experts’ opinions. Now, however, decisions will increasingly be taken in Brussels, and will be based on the advice of the Scientific Committee for Food. Unfortunately they do not always give the references to the research on which their decisions are based, for example the Opinion on colours of June 1975. If the people of Europe are to have faith in their conclusions we must be given, to use legal jargon, better and fuller
particulars.
The fact is that additives have been withdrawn from by governments and the public has not noticed. It is only when there is controversy about the toxicological data that there may be a communication problem. This reinforces the case for greater openness. The need is all the greater because the number of people who have the expertise to interprete the toxicological data is limited so there are few experts that can be consulted by consumers and journalists who were not involved in the original decisions. In these circumstances we must either trust them or disbelieve them. It is easier to believe if the decisions are fully explained. use
WHAT DO WE EAT? SCIENTISTS AND officials constantly remind those of us who try to represent the consumer interest, that the size of dosage is all important. Of course they also add that the figures for acceptable daily intakes of pesticides and additives laid down by international and national authorities are arbitrary and that small differences at such low levels cannot make a vital difference to the general safety of the population. Nevertheless the figures exist and the amount ingested would seem to be crucial. The lack of evidence of intake is therefore startling. Studies have been mainly based on the production and usage of additives by industry, and not related to actual food eaten by individuals. Manufacturers are asked to supply details of additive levels in foods and estimates on intake are then made on basis of intake of the foods. This probably gives a very high estimate of additive intake, which may provide a builtin safety factor; particularly as ’shopping basket’ studies cannot take into account the ’loss’ of additives due to processing and cooking. So maybe there is nothing to worry about. However, if it was known how many grams of colours a normal child eats every year there might be cause for alarm. Think of a pack of children’s sweets. Add to the sweets such favourites as orange drinks, biscuits, fish fingers, soup and it begins to seem a very good idea that the intake of various groups of children should be investigated. The problem is that there are so many questions to be asked about the food we eat. In 1966 the Panel on the Residues of Pesticides in Foodstuffs set up a study of residues in the total diet to gain information about the intake by the average person in the U.K. of pesticide contaminants from the diet as a whole. More recently studies of the intake of heavy metal have taken place. When the consumer organisations ask for similar studies for other contaminants and additives, they are reminded of the cost of such work and asked to decide on priorities. In a list that includes for example mercury, asbestos and the PCBs, the additives must come
low
on
the list. Nevertheless there is
a
strong
case
for
a
special study with children. Possibly the Food Additives and Contaminants Committee will have something to say
on
this in its next report soon. It should.
on
colours which is
expected
ARE GOVERNMENT CONTROLS ADEQUATE? THERE IS a series of questions that governments have to answer. Should they like the U.S.A. allow all additives which can in the light of existing toxicological data be placed on a positive list? This procedure may reduce the likely intake of any one additive, but allows the widest use of additives. Or should they like the U.K. restrict the permitted additives to the smallest number consistent with technological need? Such a restriction may increase the intake of individual additives but might, in the long-term, contain the use of additives. The second seems the better method but how does one define technological need? The International Organization of Consumers Unions as an Observer at the FAO/WHO Food Standardization Programme’s meetings (otherwise known as the Codex Alimentarius Commission) has found itself at the centre of controversy about technological need and asked to say whether or not people want a colour. This is not an easy question to answer. Colour is important to people. Yet many governments and consumers believe that colours can be used, particularly with fruits and vegetables, to disguise the use of poor quality produce or bad processing. Possibly the answer will be decided by the toxicological data. The number of all types of permitted colours in the U.K. has fallen to forty eight. Others may be removed in the future. The blue dye used in canned peas has been challenged by the EEC who have called for more testing. The food industry would be wise gradually to accustom people to less highly coloured food. Why should not the frozen food industry over time fade our fish fingers to the colour of those sold in France? We might not even notice. Sweden has adopted such a policy. Consumer organizations have been asked to support an alternative technological development. The most suspect of the colours are the azo dyes. Alternative synthetics are the dyes which duplicate the pigments found in nature. Of course some food firms, in any case, make a point of using only colours, such as carotene, from vegetables and similar sources. We certainly support the use of the ’natural’ and ’natural-identical’ dyes since the odds in favour of them being safer than the azo dyes seem considerable. However we feel compelled to be somewhat dog-in-the-manager in our attitude and out that natural products too need to be tested for safety, that even with these additives an excess may not be good. Above all, we cannot support the proposition that ’nature-identicals’ should be called ’natural colours’. Their chemical structure may be the same but they do not come from the vegetable kingdom and that is the meaning given by people to the word natural in this context. Neither the food industry or the government are the adequate likely to have the necessary resources testing of all the additives the processors would like to use. Producers, consumers and governments should together decide which additives are essential. For these the resources for testing must be found. For example, although the question was never posed most people would probably think it right that large resources have been put by government and industry into research into the hazards thought to be associated with nitrites and cured meats. However, industries should not be
point
for
196 allowed to go on using additives, and particularly those only offering sensory or other ’improvements’, when they are not willing to spend the money to satisfy the recognised scientific authorities that the additive is toxacceptable. The answer must be no. icolo~ically This does not resolve the difficult question of the
thousands of flavours which are used. In parts of Europe a distinction is made between natural and natural-identical flavours and artificial flavouring. The U.K. has argued that there should be permitted lists for both types with exemptions for natural food substances. This is right. However, the first permitted list is likely to resemble the earliest list of colours and few of the substances included will be covered by adequate data. It will take a long time to check the flavours. Nonetheless the gap between actual practice and consumer expectations and belief that all additives are tested, controlled, and limited as to use, should be closing. In due course there should be a positive list for flavours. No additive should be permitted for use unless it is on a positive list. Permitted colours should be restricted in use. Even acids, which occur naturally in food, and are used as additives to change or stabilize the acidity of food should be reviewed and, if the quantity in the diet is getting out of balance, controlled. One more question, enforcement, should concern the authorities. At this time of financial stringency, local authorities do not welcome questions about the extent of enforcement of the food laws. This is understandable. Trade, too, resents questions about compliance. They, again understandably, think it reflects on their integrity. Yet it is wrong, in discussing this matter, to fall back on the possibility that imports may be breaking the law. The facts are that consumers cannot themcheck if the foods they purchase comply with the law. They have a right to ask the authorities for an assurance that the safety requirements for additives are being met. How can the question be answered if a reasonable number of samples are not checked from time to time. At present there is no systematic and organized check. Further, while the colours are easy to check, some additives which are not permitted are not easily distinguished from the permitted additives within the same class. Progress is needed within the area of enforcement.
selves
CAN FOODS WITHOUT ADDITIVES BE SELECTED? APPARENTLY MANY people trust the Government to look after them when it comes to the safety of additives but are most sceptical as to whether they are told the truth on food labels. CA’s survey work has shown that many people do not realize that the lists of ingredients on labels are there by law, with one or two exemptions, and that these lists must include all the ingredients, with the exception of water, including additives. They are further confused because some permitted additives preservatives, antioxidents, emulsifiers, stabilizers, colours and flavours may by law be declared by this generic name while other additives, such as pH regulators, are declared by their specific name. So the following list of ingredients is typical: &dquo;Ingredients: -
-
f.
B~ . ’ .
’1- ’ .,B;1z ~ .
_
,
.
skimmed milk, sugar, butter,
glucose syrup, double whey solids, emulsifier, stabilizers, sodium citrate, colour, flavouring&dquo;. (Incidentally, thank you to the ice cream producer who voluntarily gives a list of ingredients.) There is no justification in logic or use for cream,
this mixed system. All additives should be declared either by their specific name or by statutory generic names. Or should both pieces of information be given? CA had to decide whether to back the use of generic (functional) names or specific names for additives. Research produced the interesting information that just over half the people in a quantitative survey (when shown two labels) favoured the generic terms of ’flavouring’ and ’colouring’ to the list of specific chemical designations, and less than a third positively favoured specific designations. However, during indepth interviews, a third possibility was the most preferred. This was specific ingredients listed under generic names. The case against specifics alone is obvious. To most people BHT or carotene is a foreign language. The specific name will not tell buyers why the additive has been added to the food. The specific designation may, and this is a subjective judgment, cause shoppers to decide that they cannot understand the lists of ingredients and, therefore, cease to read them. On the other side of the debate, certain consumer organizations argue that individuals have allergic reactions to additives and need the specific information. Officials reject this argument because the evidence, at present, is so limited. Possibly more convincing to them would be the point that the use of specifics enable the authorities to know the likely in-take by groups of the population of any one additive. It also assists enforcement. The EEC is offering a solution to the debate. As EEC permitted lists of additives are agreed, each additive is allocated a number. The draft food labelling directive proposes that both the generic name and the E-number should be given. Already some manufacturers with an export trade have adopted this practice. The list of ingredients are not impossibly long but anyone who wants to check the specific additives can do so. In Sweden the shops supply lists identifying the E-numbers. The one obstacle is the lack of functional names for anti-caking agents, pH regulators and so on. Surely trade and consumer bodies could produce generics that would indicate function without being as precise as ’pH regulator’. We must try. Any way the British consumer organizations are supporting the EEC proposal. In conclusion 1 return to my conversation with my French friend. She has not convinced me that there is at this time sufficient evidence for me to stand up and call for the banning of all additives. I suspect that there are contaminants that may be a far greater danger. I suspect that in time we may be able to conclude, without reservation, that the dangers to individuals of food additives were small. However, even if the chance of serious damage is a one-in-a-ten-million chance, we have the right to demand a duty of care from all concerned. The authorities should err on the side of caution. They must also recognize the right of consumers to be told what is in the food they eat, why it is there, and what has been done to try and ensure that it is safe.
