Food Protection Trends - September/October 2022 - 410

GENERAL INTEREST PAPER
How Much is Too Much?
Regulatory Limits Versus Public Health Limits
Bob Lijana*
Chapel Hill, NC 27516, USA
ABSTRACT
Is food safe even when it meets federally-mandated
standards? Such " regulatory limits " certainly provide agreedupon
and transparent metrics by which a scientific (and
political) consensus can be reached. However, such limits
may not be understood or even cared about by the consumer.
So often, the consumer simply wants " none " of the chemicals
or ingredients that the consumer believes might cause harm.
Reconciling these " public health limits " with regulatory
limits is inherent to moving food safety and food science
forward. This article provides examples of the stressors
between these two types of limits and suggestions about how
to handle them.
INTRODUCTION
Our food in the United States is safe. As a consumer, how
does one assess " how safe " when there are so many factors in
play? These factors include where the ingredients come from;
how they are handled, processed, and transported; how they are
transformed into food; what other ingredients they are mixed
with; what chemicals hitch a ride and end up in the food; and
how much of the food is consumed.
Hence, we trust others to keep an eye on food safety for us,
which is why there are many scientific groups (e.g., the Joint
FAO/WHO Expert Committee on Food Additives), regulatory
agencies (e.g., the U.S. Food and Drug Administration
[FDA] and the U.S. Department of Agriculture [USDA]),
state health organizations (e.g., California's Proposition 65),
certification bodies (e.g., organic or gluten free), auditing bodies
(e.g., the Global Food Safety Initiative), information groups
(e.g., the Food Allergy Research and Resource Program,
University of Nebraska), and scientific associations (e.g., the
International Association for Food Protection). The sum total
of their work is to keep our food safe so that we as consumers
do not have to worry when we make choices at a supermarket.
GETTING MORE INFORMATION
However, at times we want more information. This desire
may be triggered by simple curiosity (because of something
you heard or read) or by changes in the nutrition facts label
(all food manufacturers are now complying with new rules).
Your children may have asked questions about what is in their
food, or you may have a relative or friend who had a negative
reaction to a food.
*
Author for correspondence. Phone: +1.609.352.9968; Email: boblijana@gmail.com
410 Food Protection Trends September/October
Those consumers who dig deeper quickly learn that
different limits apply to how much of an ingredient or
chemical can be in food. Some limits are defined by regulatory
bodies (regulatory limits), and some are determined by
what the court of public opinion deems acceptable (public
health limits).
An example of a regulatory limit is the speed limit posted
on a highway. However, a public health limit can be lower
or higher than the regulatory limit, depending upon one's
beliefs and value systems or by previous experience (e.g.,
injuries at an intersection, implying that the posted or
agreed-to speed limit should actually be lowered). Some
people believe that vehicles should be driven more slowly
than the posted speed and certainly no higher. Yet many
other people believe that the " regulatory limit " simply
provides some guidance and that going faster than this limit
is fine. This analogy is appropriate for limits applied to our
food ingredients and chemicals.
The USDA (5) has provided a thorough summary on its
website for " labeling ingredients guidance and inspection
methods to protect consumers from misbranding. " The FDA
(10) has provided an inventory of substances allowed in
food; this guidance used to be called " Everything Added to
Foods in the United States " but is now called " Substances
Added to Food. "
INGREDIENTS
For ingredients, the issue is usually straightforward
because so many foods have federally mandated standards
of identity that must be met for the products to be sold.
For example, legal definitions exist for vanilla extract versus
vanillin. Lists of acceptable additives for foods, such as
preservatives, are also publicly available and have the force
of law behind them. Manufacturers must use ingredients
that are allowed; not doing so is illegal. The ingredients are
thoroughly checked by the USDA during their inspections of
a company's food and its labeling.
Laws also dictate that the ingredients of a food must be
listed on that food's label. All ingredients must be specified
(in order of decreasing amounts); thus, an ingredient cannot
be added to the food unless it is listed on the label. The
exceptions to this requirement are small amounts (<2%) of
minor ingredients such as flavors and spices. For example,
" natural flavors " can be listed, but the exact ingredients do
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Food Protection Trends - September/October 2022

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