As a scientist I don’t think this change is really science based.
Banning artificial colors because “chemicals are bad” isn’t logical. Banning artificial dyes because one random paper maybe found a cancer link isn’t rational (generally if studies are all over the place the effect is so small you’re seeing noise).
If you want to avoid artificial dyes, cool, avoid them! But blanket bans of dyes where the data is questionable about harm isn’t logical.
The problem isn't that "chemicals are bad" but that we don't know which chemicals are bad. Ones that we have been eating for centuries are unlikely to be significantly harmful and we can stop consuming them them when evidence is found. But for things that we haven't been eating for that long we don't really know. Right now the system is sort of set up as default-allow. So what happens is that some company wants a blue dye because they think blue candy will sell. They try things until they find something that isn't obviously harmful and start selling it. Then in 20 years it is found that it actually was harmful in the long term and impacted a huge swath of the population. The company then searches around until they find another blue dye that isn't obviously harmful and the cycle repeats.
To some degree we do need to experiment and try new things. However for something like food dyes it likely isn't really worth the risk. Or at least they are far overused. Many of the foods with dyes aren't that healthy anyways, so maybe it is is best to have them less attractive to avoid ingesting more chemicals which we don't have strong long-term evidence that it is safe.
We see a very similar cycle with plastics, refrigerants and many other things. We use something for a long time before realizing that it actually has harmful effects, then industry just creates a new very similar chemical that isn't known to be bad yet (or at least isn't bad in the same way the last one is). In some cases it is probably worth it (refrigeration is a valuable technology) but in the cases where it isn't as valuable to society we should be much more conservative with what we allow.
That being said, the proposed regulation isn't scientific and doesn't play with this nuance. A more reasonable approach would be raising the standards for introducing new chemicals (natural or artificial) to food. Not just banning anything "artificial" (whatever that means).
Yes, and due to having been used for a long time we are aware of the effects (and at least for lead have implemented reasonable rules around its use).
My point is that the longer we have used and consumed something the better we understand it. We are more likely to know and understand the risks. So we should be extra cautious with new materials. Something that we have been eating for hundreds of years with no known negative effects is wildly different than something that a company discovered (naturally or artificially) last year and didn't find any negative effects with some short-term tests.
Trump admin is trying to prevent the banning of asbestos, and undo the regulations that have been banning it. Trump seems convinced that "it's all fine, actually" and policy is being based around that, but the catalyst seems to be that the Biden era finalized the last ban on the last type of asbestos still being used (which would take up to twelve years to take effect anyway).
It wouldn't surprise me at this point if the Trump administration started rolling back regulations on lead pipes and enforcing minimum cadmium concentrations in tobacco.
As a non-scientist, I am not really any more qualified to give an opinion on this than any random person, but the fear around food dyes seems way overblown IMO.
You can read the statement from the FDA where they banned red dye 3, it's very short. [1] Here's a relevant quote:
>claims that the use of FD&C Red No. 3 in food and in ingested drugs puts people at risk are not supported by the available scientific information.
As a scientist there are a few things to drive my opinion it’s overblown:
- you can’t prove a negative (“this dye isn’t harmful”), all you can do is run a panel of tests and interpret the data
- food additives are tested in animal models at levels that are several orders of magnitude higher than what any human might consume. Animals are then autopsied to see if there are *any abnormalities in any organ system. This is done with several species.
- Cell models are also used to test things like carcinogeniticity, cell-specific toxicity, toxicity of chemicals formed when the additive breaks down, toxicity of trace impurities, etc. It’s quite extensive.
- Data is rarely 100% clear. You may get a signal in some animal model at 1000x expected exposure. What does it mean? Plenty of animals exhibit toxicity not seen in humans and slight abnormalities may or may not translate to humans. But the FDA tends to err on the side of caution, especially with food additives as there is little benefit to offset any risk.
- It’s not unusual to run 10 studies, find 9 are negative, 1 shows a signal but it’s not statistically significant. What RFK tends to do is cherry pick the 1 study and say “there is data to prove it’s harmful!” That’s not how science works. You look at the totality and quality of the data and make the best conclusion you can. Is it 100% foolproof? Of course not, but it’s pretty solid evidence that likely no harm will result.
- The one risk is the “unknown unknowns”. If you don’t know what to look for, you’ll never find it. But that’s true with everything we ingest - drugs, natural foods (peanuts and aflatoxin!), synthetic chemicals, water purification chemicals, etc, etc. We can only do the best with the knowledge we have.
- If you see 10 studies and 5 are positive (barely) and 5 are negative, either the effect is really small (I.e. you should worry more about other things) or it’s just noise.
I have the same view, and I was hoping that someone would provide some evidence as to why they are harmful in typical quantities found in foods. It seems to me that because these additives are so widely used, we would know for sure if they were dangerous.
We have extremely pervasive health problems across the west, and many theories (you can surely think of 20), but all of them are weak under scrutiny, specifically because the phenomena are effectively impossible to isolate and pin down. You can't actually achieve a strong signal.
So if multiple studies link a low-value and/or easily replaceable additive to problems, we can remove it as a precaution.
Food colorants in particular serve _primarily_ an advertising role. In general, advertising junk food to children is often restricted and highly contested. The difference here is the child is expected to physically consume the artefact.
We should adopt a "default deny" stance and contested ingredients at least should show some kind of value. You can make a case for many preservatives. Paint is not like that.
That fails the scientific method in several places.
Science doesn’t ban things with questionable data from poorly designed studies when other studies say the opposite.
Science doesn’t ban things because of some other problem where a causal link hasn’t been proven.
We already have a “default deny” system in place. Unless you have data saying it’s safe (according to regulations), a chemical can’t be used as a food additive.
Edited to add:
GRAS definition....."the use of a food substance may be GRAS either through scientific procedures or, for a substance used in food before 1958, through experience based on common use in food Under 21 CFR 170.30(b), general recognition of safety through scientific procedures requires the same quantity and quality of scientific evidence as is required to obtain approval of the substance as a food additive."
It literally says “GRAS must meet the same standards as new additives”.
The only reason GRAS exists is that FDA regulations have changed over time.
Unless you wanted all food additives immediately banned until years of tests could be conducted, the FDA created GRAS based on the evidence at the time but also required additional studies to bring existing additives up to the same safety standards as new additives.
Feel free to click on any of the GRAS decisions to read all about the studies done.
Science is a tool for finding truth, or at least weighing evidence. It isn’t policy and doesn’t have anything to say about policy.
You can have a policy of waiting for overwhelming proof of harm before banning anything. But there are an awful lot of chemicals added to our food and environment, with precious few studies competently and honestly tracking their effects. I want a much more careful policy - don’t put unknown chemicals in my body without convincing me the benefit.
Easy, just avoid any processed food. Eat only fresh meat, fruit, and vegetables. Make your own bread, jams, pickles, etc. Never eat any fast food, anything from a cafe, or anything at a restaurant. Wrap all your work lunches in linen you made yourself from flax you grew yourself. Boom, problem solved, no more toxic chemicals in your food unless they were in the air or groundwater where your fruits and vegetables were grown, harvested, or processed, or your cattle grazed or were slaughtered or packaged.
Why would one color meat, fruit or vegetables? This can create false expectation of their freshness and quality and must be banned. This is much easier solution.
Also coloring cheese should be banned. I always choose cheese without dyes but many people might be not aware that many types of cheese are artificially colored.
It's called the precautionary principle. It's generally a good idea. And yes, you have to implement it at the regulatory level because otherwise Food Inc. will try to get away with everything they can.
As a chemist, I can tell you that nearly everything you can think of -- "natural" or otherwise -- has been correlated to some negative outcome, in some organism, by some (usually crappy) study. These get laundered and blurred into "linked to negative health effects", by the lay press, which is widely repeated by people who don't know what they're talking about. P-hacking virtually guarantees that this will be the case, as long as someone, somewhere has the incentive to publish.
If you apply the "precautionary principle" this broadly, there's nothing left. It's basically the same reason that everything is labeled as "linked to cancer" by CA prop 65 (e.g. coffee, or...trees [1]).
Dye is not an essential component of food and therefore should be banned, at least for food that has natural color (like meat or cheese). Not only it might be harmful, it causes false expectation of quality and freshness and should not be allowed. Because otherwise for a manufacturer it is easier to color low-quality product rather than make high-quality product.
The precautionary principle is not entirely benign. Here, though, it's not even apposite: the dyes being ditched here have been intensively studied for decades.
The precautionary principle is not "Ban scary sounding things", it's "Prove that chemical is safe before you can expose people to it", which places like the EU often attempt to do.
But notably, nothing about this action takes any steps or effort towards enforcing "Prove it is safe BEFORE you sell it" and "natural" does not make any impact there. Ricin is plenty natural, so is methanol, and this change would not stop you from selling people literal poison as long as it wasn't already banned.
If Bayer makes a new derivative of carminic acid ("Natural" red #4) tomorrow that is easier for production lines to handle but also gives you cancer if you eat it for 20 years, there's no legal requirement that they demonstrate it doesn't give you cancer before they can sell it. It is YOUR RESPONSIBILITY as a consumer to do that science for them! It being "Natural" is utterly meaningless marketing bullshit.
None of this bullshit safety theater makes any of us more safe.
As I note elsewhere, this isn't exactly damaging though. Most other countries already encouraged manufacturers to develop formulas without artificial dyes, primarily due to differences in consumer opinion (which is usually similarly not fact based), so companies are going to make a big hubub about how this will be so hard for them and then they just shut down the "this is American specific" production line and retool it for the international formula and then insist that they made such a huge change to help everyone.
But "natural colors only" has zero relation to "more healthy", and that goes double when you are talking about processed food. If you actually wanted people to eat healthier, you would be better off banning all food coloring additives, all food texture additives, and anything that lets you modify how food presents itself after processing. People would buy less processed food if it all looked like what it actually was.
Other countries have better food than the US because 1) They often force food additives to be PROVEN safe before any use and much more importantly 2) consumers are way more discerning about food. European bread doesn't have a spoonful of sugar or sugar syrup because Europeans don't want their bread to be addictively sweet, while Americans objectively buy more bread that's been sweetened than "normal" bread. I'm not a fan of treating "revealed preferences" as too meaningful, but it's hard to sell bread to people who wont buy it because they would rather eat the cake in bread form. So it's important to ask why Europeans want their cakes cakey, and their bread not.
>You wouldn’t eat something you don’t know if it’s edible just because it has a nice color
Easy for you to say while writing a HN comment, but people would certainly be turned off by gray yolks[1] for instance, even if theoretically they were safe to eat.
These colors are all extensively tested, precisely because people were scarred of them being "unnatural".
The "natural" colors HAVE NOT been tested so extensively.
So do you want to put "Natural" but utterly untested chemicals in our food or "unnatural" but extensively tested chemicals?
Because unless you ban food coloring outright, companies are going to color your food. They have the data that in the American market, (fake) bright yellow yolks sell more and for more profit than natural yolk colors.
Your assumption of "artificial dye" == "Untested" is currently wrong. The US requires almost no testing for pretty much anything put in our food right now, due to "Generally recognized as safe" bullshit. There are hundreds of chemical additives that have not really been tested that you can just put in food legally.
US food law does not distinguish between "artificial" chemicals and "natural" chemicals except in labeling. You can source a chemical from oranges, turn it into a completely different chemical, put that in your food product, and call it "natural". The only difference from a chemistry standpoint is that you sourced your chemical feedstock from some sort of plant or animal instead of taking simple hydrocarbons and building up your chemical.
Salicylic acid does the exact same thing in your body whether you process it from willow bark or build it up from Phenol, and both versions are simultaneously a horrible birth defect inducing toxin, as well as an utterly essential and safe modern medicine.
I think that's the biggest issue nowadays/back then: we don't test shit like at all and find out decades later that it destroys us. For what? Because the market incentivizes temporary gains for "competitiveness". The whole system is misaligned. We have those e/acc and silicon valley peeps telling us it's for the PrOgReSs and it's necessary. All the while they eat grass fed beef. You gotta live what you preach!
They may eat "grass fed beef" (which in no way magically makes a steak any healthier) but they are the same people who microdosed LSD for two years because it was the fad of the time.
They aren't super aware and taking advantage of us, they are actually that utterly stupid. They are the epitome of that software dev you worked with who only just learned about <thing> yesterday, read a few articles and wikipedia pages, and assume they must know enough about <thing> to have better takes than people who have been working knee deep in <thing> for 30 years. They love to say they are "reasoning from first principles" because they have no actual expert experience to how those "first principles" haven't been useful or relevant in that field for centuries.
It's the classic "I know just enough to be dangerous" problem we are all familiar with of Users of our software products, the kind that uninstall System32 to "speed up their machine" like the internet told them, but 100 million people gave them the power of the US government. They vastly overestimate how much of the space they have so far learned, and don't even know how much they don't know.
Banning artificial colors because “chemicals are bad” isn’t logical. Banning artificial dyes because one random paper maybe found a cancer link isn’t rational (generally if studies are all over the place the effect is so small you’re seeing noise).
If you want to avoid artificial dyes, cool, avoid them! But blanket bans of dyes where the data is questionable about harm isn’t logical.