Discussion about this post

User's avatar
Tom Neltner's avatar

Great post, Bruce! For what it is worth, since 1958, Congress has required FDA and the food additive industry to consider the cumulative effect of chemically and biologically related substances in the diet, a major part of the cocktail. Not one by one. And not just additives but everything in the diet. FDA adopted rules in March 1959 explaining how that is to be done.

Coupled with the reasonable certainty of no harm standard, we have a safety standard that is stronger than EU's precautionary principle. At least in theory.

Unfortunately, the FDA and industry have ignored the requirement and its own rules. Dr. Maricel Maffini and I reviewed thousands of decisions and found no instances where FDA followed the law. We documented in study after study.

In September 2020, we and other public health advocates submitted a citizen petition demanding the agency fix the problem and that it start by telling industry they needed to address it - not ignore it. FDA has ignored that request too.

FDA's failure to consider cumulative effects is, I think, one of the root causes of the ultraprocessed food problem that is not coming to the forefront.

Tom Neltner

Expand full comment
1 more comment...

No posts