Regarding a Petition to FDA to Ban Eight Food Additives

We have received a number of questions regarding a petition to the FDA by seven primarily environmental advocacy groups seeking to ban eight food additives, so we wanted to help put it into context. The substances are benzophenone, ethyl acrylate, eugenyl methyl ether, myrcene, pulegone, pyridine, styrene, and trans-2,4-hexadienal. 

We reached out to Dr. Henry Chin, an independent expert in food safety, food chemistry and composition, crisis management and risk management, for his views:

The petition is as much about the application of the Delaney Amendment, and the legal definition of a “carcinogen”, as it is about science.

Even more significant is the argument at the end of the petition that FDA should not do its own evaluations on these chemicals and instead defer to IARC, NTP, and Prop 65 listings and basically ban chemicals if these organizations find them to be carcinogens.  The obvious problem is that those organizations are not focused on food safety or the safety of chemicals in food and diet, but on the more esoteric question of whether a chemical under some circumstances could be a carcinogen.

The question is further complicated by the fact that at least three of these chemicals, methyl eugenol, myrcene and pulegone, are found in commonly consumed foods. The primary use of styrene is as the starting material for polystyrene plastics, and usually any styrene found in foods results from the very small amount of migration of residual monomer. I believe that FDA has recently looked at styrene in such situations and found it not to be an issue.

While these chemicals may or may not cause cancer in animals, there are real questions whether the doses and results from those studies are relevant to human exposures from food.  Experience with the presence of some these chemicals as natural components of food would suggest that at least some of those studies are not relevant to human health.
 
This is another example of organizations being chemophobic as opposed to looking at the entirety of the diet.  Taken literally, the petition would ban foods such as thyme, parsley, hops, oranges, bananas, cloves, and peppermint, since these foods contain myrcene, methyl eugenol, or pulegone, and there is no difference between the naturally occurring chemical and that synthetically manufactured.
 
There are much more significant food safety and security issues than these chemicals in food.