Editor’s note: This op-ed was written by Frederick vom Saal and 15 co-authors. The full list of co-authors, their affiliations, and their contact information is included below.
As senior environmental health researchers and physicians, we are united in our concern about the escalating prevalence of chronic diseases in the United States. To stop the increase of these chronic disease epidemics, it is essential to change the U.S. Food and Drug Administration’s current lack of regulatory oversight of toxic chemicals in food.
There is consensus among the scientific and medical communities — including the American Academy of Pediatrics, the Endocrine Society, the United Nations Environment Program, the World Health Organization, and U.S. Department of Health and Human Services, among others — that the health of Americans is at a crisis point.
Regulatory inaction has increased while Americans are becoming progressively sicker with chronic diseases, including cancer, cardiovascular disease, obesity, diabetes, immune disorders, and declining fertility. Six in 10 Americans suffer from at least one chronic disease, and four in 10 have two or more. Of additional concern is the increasing incidence of altered brain function, including learning disabilities, autism, ADHD, dementia, and Parkinson’s disease.
The consumption by Americans of non-nutritious, highly processed food clearly contributes to these chronic disease epidemics. And microplastics from food, food packaging sources, and elsewhere have become a major concern now that they have been identified in the tissues of virtually all humans. These food-related issues must also be addressed.
However, the science is clear that we will not correct these chronic disease epidemics if the FDA and other regulatory agencies continue to ignore the hazards to health posed by the thousands of toxic chemical contaminants in our water, air, personal care products, and, our focus here, in our food.
Toxic chemicals in food are raising chronic disease rates
The increase in incidence of chronic diseases to epidemic levels has occurred over the last 50 years in parallel with the dramatic increase in the production and use of human-made chemicals, most made from petroleum. These chemicals are used in household products, food, and food packaging.
There is either no pre-market testing or limited, inappropriate testing for safety of chemicals such as artificial flavorings, dyes, emulsifiers, thickeners, preservatives, and other additives. Exposure is ubiquitous because chemicals that make their way into our food are frequently not identified, and thus cannot realistically be avoided. The result is that unavoidable toxic chemicals are contributing to chronic diseases.
Critically, the FDA today does not require corporations to even inform them of many of the chemicals being added to our food, and corporations have been allowed to staff regulatory panels that determine whether the human-made chemicals they add to food and food packaging are safe. The FDA blatantly disregarded this abuse of federal conflict-of-interest standards, which resulted in thousands of untested chemicals being designated as “Generally Recognized As Safe” (GRAS).
The GRAS list was instituted when food safety regulations were being developed in the late 1950s but only included a few chemicals already common in food for centuries, such as salt and vinegar. Unfortunately, the GRAS exemption is now a huge regulatory loophole.
We support the recent proposal to revise the GRAS exemption program at the FDA. This is needed to ensure that chemicals accepted as safe by the FDA have actually been adequately tested for safety and that any voluntary changes agreed to by corporations are adhered to. But voluntary changes in corporate behavior alone are not sufficient. Regulatory changes that address specific critical agency deficiencies are needed, in contrast to indiscriminate reductions in federal funding for critical public health protections and research at federal agencies.
Protecting children during critical stages of development
We are especially concerned about the role played by the many GRAS-exempted endocrine disrupting chemicals (EDCs) in the chronic disease epidemics. Over 1,000 EDCs have been identified as contaminating our air, water, and food, although we predict that this is only the tip of the iceberg due to inadequate funding. Of great concern is that EDCs interfere with hormone signaling that is essential for healthy development. There is extensive evidence that when development in fetuses, children, and adolescents is disrupted by EDCs, there are life-long health consequences, such as chronic diseases including cancer.
Critically, if toxic EDC exposure occurs when the brain, liver and other organ systems are still developing in babies and children, the detoxification systems that are activated in adults in response to toxic chemical exposures have not yet developed, and those exposed are defenseless. This is precisely why pediatrics exists as a separate medical field: Babies, children, and adolescents are not little adults. The FDA has not recognized the high vulnerability to endocrine disruption during development as a priority.
Even in adults, chronic exposure to very low levels of EDCs can elicit serious adverse health effects. Toxic EDC exposures cause permanent harm because these chemicals interfere with hormones that regulate physiological systems essential for good health throughout life.
Elimination of the FDA’s GRAS loophole is required as an essential initial reform. But beyond that, creation of a coherent food regulation system in the US is needed so that the current generation of babies, and future generations, have access to food throughout life that does not contain toxic chemicals.
