Food Protection Trends - September/October 2022 - 412

through federal laws. For example, how much of the work
associated with development of the COVID-19 vaccine was
driven by medical need, by politics, and by the need for corporate
profits? Many other political examples can be found
in the EPA for regulation of air pollution. For limits on materials
such as CO2
, how much of the research has been driven
by the science supporting climate change, by new equipment
that can scrub gases, and by politics?
Amid the haze of changing science, consumers very vocally
raising issues, and politicians trying to drive regulatory limits
to meet the parochial needs of the people they represent,
consumers can take comfort in the fact that limits do get
imposed. At a minimum, they provide a target from which
further discussion, argument, and scientific development can
evolve. Do not get mad at such limits; rejoice that they exist.
THE FUZZINESS OF PUBLIC HEALTH LIMITS
In contrast to limits, many people really want " zero "
amounts of an ingredient or chemical of concern. These consumers
may be thinking that lower concentrations are always
better, and zero concentrations are best. This target can be a
fair because more is at stake than just the final measurement
of that ingredient or chemical. A common phrase is " you
can't test quality in, " which means that actions need to be
taken from the beginning to ensure that " zero " is achievable.
For food ingredients, actions include consideration of
where something is grown, what kinds of farming practices
are used, what kinds of controls are in place for the chemicals
used on the farm, and what clean-up protocols are used to
remove unwanted materials from the ingredient. Testing
must be conducted along the way, not just at the end.
A public health limit is therefore different from acceptance
of the validity of a regulatory limit set for a specific substance
REFERENCES
1. AGCanada. 2014. Saccharin cleared for use in
foods in Canada. Available at: https://www.
agcanada.com/daily/saccharin-cleared-foruse-in-foods-in-canada.
Accessed 2 March
2022.
2. Center for Science in the Public Interest.
2022. Saccharin. Available at: https://www.
cspinet.org/article/saccharin. Accessed 2
March 2022.
3. Government of Canada. 2007. Saccharin.
Available at: https://www.canada.ca/en/
health-canada/services/food-nutrition/foodsafety/food-additives/sugar-substitutes/
saccharin-artificial-sweeteners.html.
Accessed
2 March 2022.
4. National Toxicology Program of the National
Institutes of Health. 1999. NTP report on
carcinogens 1997 background document for
saccharin. Available at: https://ntp. niehs.nih.
gov/ntp/newhomeroc/other_background/
saccharin1_3apps_508.pdf. Accessed 2
March 2022.
5. U.S. Department of Agriculture, Food Safety
and Inspection Service. 2014. Ingredients
guidance. Available at: https://www.fsis.
usda.gov/inspection/compliance-guidance/
labeling/ingredients-guidance. Accessed 2
March 2022.
6. U.S. Environmental Protection Agency. n.d.
Assessing human health risk from pesticides.
Available at: https://www.epa.gov/pesticidescience-and-assessing-pesticide-risks/
assessing-human-health-risk-pesticides.
Accessed
2 March 2022.
7. U.S. Environmental Protection Agency. 2020.
Glyphosate. Available at: https://www.epa.
gov/ingredients-used-pesticide-products/
glyphosate. Accessed 2 March 2022.
8. U.S. Environmental Protection Agency. 2022.
Chlorpyrifos. Available at: https://www.epa.
gov/ingredients-used-pesticide-products/
chlorpyrifos. Accessed 2 March 2022.
9. U.S. Food and Drug Administration. 2014.
Bisphenol A (BPA): use in food contact
applications. Available at: https://www.
fda.gov/food/food-additives-petitions/
bisphenol-bpa-use-food-contact-application.
Accessed 2 March 2022.
10. U.S. Food and Drug Administration. 2018.
Substances added to food. Available at:
https://www.fda.gov/food/food-additivespetitions/substances-added-food-formerlyeafus.
Accessed 2 March 2022.
11. U.S. Food and Drug Administration. 2022.
Direct food substances affirmed as generally
recognized as safe. Available at: https://www.
accessdata.fda.gov/scripts/ cdrh/cfdocs/
cfcfr/cfrsearch.cfm?fr=184.1733. Accessed 2
March 2022.
(e.g., a pesticide). In making a risk assessment, the EPA practice
is to evaluate aggregate sources (6), as in this " teacup "
analogy. Consider the different sources of an undesirable
substance (e.g., food, water, your lawn, the air, a hard surface
that you touch), and put each amount into a teacup. The
regulatory limits would indicate that the amount from each
separate source is " safe, " but if you put all of those insults into
one teacup, would you drink from that teacup?
HINT: Always remember that the human body is a remarkable
machine, able to take in various chemicals from the environment,
metabolize them appropriately, and then excrete them, all
with no harm done.
LIMIT YOURSELF
By now you just might be more confused or more worried.
Overall, the people who are setting limits can be trusted
to make, on par, the right decisions. However, regulatory
limits are just that-founded on regulations based on the
current science that has been peer reviewed but still subject
to debate. The resulting limits might be compromises but
do act as standards against which a food ingredient can be
measured. This process is conducted professionally and
diligently because regulatory limits have the force of law.
This approach levels the playing field, catalyzes honesty and
transparency, and truly puts maximum limits on substances,
ingredients, and chemicals.
However, imperfections in the process exist, especially
when the results are in conflict with personal value systems.
Thus, consumers may need to become more involved in the
process and better educated. Consumers can make their
choices speak at the supermarket! Just make sure you do not
exceed the speed limit as you drive there.
412 Food Protection Trends September/October

https://www.agcanada.com/daily/saccharin-cleared-for-use-in-foods-in-canada https://www.agcanada.com/daily/saccharin-cleared-for-use-in-foods-in-canada https://www.fsis.usda.gov/inspection/compliance-guidance/labeling/ingredients-guidance https://www.fda.gov/food/food-additives-petitions/bisphenol-bpa-use-food-contact-application https://www.agcanada.com/daily/saccharin-cleared-for-use-in-foods-in-canada https://www.fsis.usda.gov/inspection/compliance-guidance/labeling/ingredients-guidance https://www.fda.gov/food/food-additives-petitions/bisphenol-bpa-use-food-contact-application https://www.fsis.usda.gov/inspection/compliance-guidance/labeling/ingredients-guidance https://www.fda.gov/food/food-additives-petitions/bisphenol-bpa-use-food-contact-application https://www.cspinet.org/article/saccharin https://www.cspinet.org/article/saccharin https://www.epa.gov/pesticide-science-and-assessing-pesticide-risks/assessing-human-health-risk-pesticides https://www.fda.gov/food/food-additives-petitions/substances-added-food-formerly-eafus https://www.fda.gov/food/food-additives-petitions/substances-added-food-formerly-eafus https://www.epa.gov/pesticide-science-and-assessing-pesticide-risks/assessing-human-health-risk-pesticides https://www.fda.gov/food/food-additives-petitions/substances-added-food-formerly-eafus https://www.epa.gov/pesticide-science-and-assessing-pesticide-risks/assessing-human-health-risk-pesticides https://www.canada.ca/en/health-canada/services/food-nutrition/food-safety/food-additives/sugar-substitutes/saccharin-artificial-sweeteners.html https://www.canada.ca/en/health-canada/services/food-nutrition/food-safety/food-additives/sugar-substitutes/saccharin-artificial-sweeteners.html https://www.canada.ca/en/health-canada/services/food-nutrition/food-safety/food-additives/sugar-substitutes/saccharin-artificial-sweeteners.html https://www.epa.gov/ingredients-used-pesticide-products/glyphosate https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/cfrsearch.cfm?fr=184.1733 https://www.canada.ca/en/health-canada/services/food-nutrition/food-safety/food-additives/sugar-substitutes/saccharin-artificial-sweeteners.html https://www.epa.gov/ingredients-used-pesticide-products/glyphosate https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/cfrsearch.cfm?fr=184.1733 https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/cfrsearch.cfm?fr=184.1733 https://www.epa.gov/ingredients-used-pesticide-products/glyphosate https://www.epa.gov/ingredients-used-pesticide-products/chlorpyrifos https://ntp.niehs.nih.gov/ntp/newhomeroc/other_background/saccharin1_3apps_508.pdf https://www.epa.gov/ingredients-used-pesticide-products/chlorpyrifos https://ntp.niehs.nih.gov/ntp/newhomeroc/other_background/saccharin1_3apps_508.pdf https://www.epa.gov/ingredients-used-pesticide-products/chlorpyrifos https://ntp.niehs.nih.gov/ntp/newhomeroc/other_background/saccharin1_3apps_508.pdf

Food Protection Trends - September/October 2022

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