Our email to the Irish Nurtirion and Dietetics Institute, regarding food additives:

--- Original Message -----

From: David Egan To: info@indi.ie

Sent: Tuesday, February 14, 2006 11:14 AM Subject: Food additives

Hi

As a concerned parent, I am very interested in your stance on food additives.

In your fact sheet on food labelling (http://www.indi.ie/assets/81/AA381A38-D17C-188B-6431C488B6AB8EB7_document/food_label_factsheet.pdf) you suggest that consumers should not be concerned about foods that contain “E-numbers”.

Whilst I am sure that the “E-numbers” you mention (E220 sulphur dioxide and E410 Locust bean gum) are harmless, I would be interested to know your opinion on some of the more controversial “E-numbers”...for example, E104 Quinoline Yellow and E133 Brilliant Blue. Brilliant Blue is banned in several EU countries, but is used in products available for sale in Ireland. Quinoline Yellow is banned in the US, Australia and Norway, but is again present in products sold in Ireland...you can find both dyes in peanut M&M’s, for example. What is your position on these coal-tar dyes?

Recent research has suggested that combining food additives could have a damaging effect on the nervous system (see Lau, K., et al., Synergistic Interactions between Commonly Used Food Additives in a Developmental Neurotoxicity Test. Toxicol Sci, 2006. 90(1): p. 178-187) and the food standards agency in the UK state that:

“even though the use of single food additives at their regulated concentrations is believed to be relatively safe, their combined effects are unclear and until now have not been widely studied.”

Should your publication not be amended to reflect the uncertainty that surrounds the “cocktail effect” of mixing different chemical additives in food?

Yours,

David

Response from INDI, received 27/02/06:

Dear David,

Thank you for your E mail received recently regarding your concerns about certain food additives . The INDI have consulted with the Food Safety Authority of Ireland with regards to your query as they are the component authority in Ireland for food law.

Food additive means "any substance not normally consumed as a food in itself and not normally used as a characteristic ingredient of food whether or not it has a nutritive value, the intentional addition of which to food for technological purpose in the manufacture, processing , preparation, treatment, packaging , transport or storage of food results, or may be reasonably expected to result, in it or its by products becoming directly or indirectly a component of such foods" (EC 89/107/EEC Article 1). Please find a link to the directive and its amendments on the FSAI website http://www.fsai.ie/legislation/food/legislation_foodadditives.asp

Food additives are natural or manufactured substances, added to foods for a variety of reasons - to restore colours lost during processing (e.g. colours), to provide sweetness in low sugar products (e.g. sweeteners), to prevent deterioration during storage and to guard against food positioning (e.g. preservatives). Whether the additive comes from a natural source or is man made, the question of safety is central to the decision as to whether or not an additive should be permitted in food. The use of additives in food is strictly controlled by European Union (EU) legislation which requires that only authorised additives may be used in the manufacture or preparation of foodstuffs. A new additive which requires authorisation in the EU must go through an exhaustive safety assessment by the European Food Safety Authority (EFSA). Before EFSA was established the EU Scientific Committee on Food (SCF) carried out this function. The manufacturer of the potential new additive must not only produce evidence that there is a real need for the substance, but must also commission research into that substance. The research must include toxicological tests (tests to determine whether a substance is harmful) including tests to assess the mutagenic potential of the compound, that is the ability to interfere with genetic material in the body which could lead to the development of cancer or adverse effects in future generations. Following evaluation of a particular additive, it is placed on the EU 'positive list' of approved additives. If there is any doubt about the safety of an additive, then that substance would not be approved. The colours, you have mentioned in your e-mail below i.e. Quinoline Yellow and also Brilliant Blue have both undergone this approval process and are therefore approved colorants for use in accordance with Directive 94/36/EC, throughout the EU.

The maximum levels at which additives such as these colours may be used, and also the specific foodstuffs in which they may be used, are also established by the EU (and corresponding Irish) legislation. These levels are set at values which ensure that a person consuming a typical diet would not exceed the Acceptable Daily Intake (ADI) established for the additive in question. Both Quinoline Yellow and Brilliant Blue have ADI's established i.e. 10mg/kg bodyweight and 12.5mg.kg body weight respectively.

ADI - If an additive is deemed acceptable for food use, an Acceptable Daily Intake (ADI) is normally set. The concept of the ADI was established by the Joint Expert Committee on Food Additives (JECFA) and is defined as: "an estimate of the amount of food additive, expressed on a body weight basis that can be ingested daily over a lifetime without appreciable health risk."

All approvals of food additives are kept under review by the European Commission and the European Parliament in addition to expert bodies in individual Member States, as and when scientific and medical information becomes available on possible adverse effects, not previously recognised or reported. It should also be noted that EFSA has carried out a literature review of all the colours and will commence a safety review of the colours in the coming months. It is anticipated that as a starting point they will review 10 synthetic colours and 10 natural colours (the identity of which to be decided in the forthcoming weeks).

Although food additives are rigorously assessed before approval, their possible health risks continue to be a matter of some controversy. Adverse reactions to food additives do occur in a small proportion of the population, and some scientists have linked consumption of additives to health conditions such as allergies, migraines and hyperactivity in children. In relation to the latter the evidence is anecdotal. A number of well-controlled studies have been unable to show a significant effect of colouring and preservative free diet on behaviour in children with true attention deficit disorder, although there is some evidence that an additive-free diet may have a small effect in a small subset of pre-school aged children. If parents notice that consumption of certain foods appear to be linked to hyperactivity in their child, they should remove the food or foods from the diet and in general try to limit the child's intake of additive-containing products. The same applies to anybody who suspects they have had a reaction to an additive-containing food.

The Committee on Toxicity of chemicals in food, consumer products and the environment (COT) reported in October 2005 on an examination of 12 additives of which E104 and E133 were two. They found overall that the data on the 12 additives under consideration do not give rise to any concerns regarding developmental neurotoxicity at levels likely to be encountered via the diet. Please find a link to the report http://www.food.gov.uk/multimedia/pdfs/TOX-2005-23.pdf. In January 2006, The COT released a statement on food additives and developmental toxicity. Quinoline Yellow and Brilliant Blue were two of the additives considered. The conclusion of which was that for no agents was there any evidence suggesting the potential for developmental neurotoxicity at current acceptable daily intakes. Therefore available data did not suggest that further investigations of any of these agents would be a priority given current dietary intakes.

Ireland over all tends to be guided by European legislation as we are part of the E.U. It is only in specific cases of public health concerns for Ireland, that deviations from the European legislation are taken. To date, the E.U. has not discovered sufficient evidence to remove such additives from use in foods but is vigilant for any additional information available on any food ingredient and will take corrective actions as appropriate. Please refer to the following link for the food additives report published in 2001 by the FSAI for more information "Legislation, intake and use of food additives in Ireland": http://www.fsai.ie/publications/reports/Legislation_Food_Additives.pdf

I trust this will answer your query but should you require any further information please do not hesitate to contact me

Yours Sincerely

Margot Brennan Public Relations Officer INDI 087 9503659