The International Hydrolyzed Protein Council (IHPC) conducted annual surveys on the levels of carcinogenic 3-MCPD in acid-hydrolyzed vegetable proteins (HVPs) and shared their Codex Alimentarius Commission (CAC) results with the FDA.
The CAC was created in 1963 by the Food and Agriculture Organization of the United Nations (FAO) and the World Health Organization (WHO) to develop food standards, guidelines, and related texts such as codes of practice under the Joint FAO/WHO Food Standards Program.
In the CAC report referred to above, the FDA also reported that it conducted a formal quantitative risk assessment of 3-MCPD in 2000 and concluded that 3-MCPD was carcinogenic and genotoxic (damaging to DNA). There is some disagreement regarding the genotoxicity of 3-MCPD.
On March 31, 2008, the FDA did publish an article in the Federal Register announcing the availability of Compliance Policy Guide No. 500.500, which sets “guidance levels” for 3-MCPD in acid-hydrolyzed proteins and Asian-style sauces.
However, a guidance level is not binding on the FDA or on industry and cannot serve as the direct legal basis for an enforcement action. A similar article appeared in the Federal Register in October 2007.
The CAC stated, “Chloropropanol contamination is a food safety issue that has international implications, and a number of countries have introduced maximum levels for chloropropanols.”
Beginning in 2001, the U.K. food regulatory agency began to remove certain products from grocers’ shelves due to what they believed to be excessive levels of carcinogens.
The cause was found to be the presence of propanols due to acid HVPs. Thailand has established a limit of 3-MCPD in seasoning products, and during 2001, Australia and New Zealand introduced emergency measures to establish maximum levels of chloropropanols. Other countries, like the United States, are studying the problem.
If the food industry were not so interested in adding MSG to our processed foods in order to enhance flavor without going to the expense of using high-quality, healthful ingredients, the HVP issue would not be the problem it is.
In the opinion of this writer, the HVP issue is an example of how our regulatory agencies fail to fulfill their responsibility to protect the health of citizens with healthy food, a responsibility that has become increasingly important with a national health care program.
If we are to reduce health care costs, we must reduce the growing incidence of numerous, serious medical conditions in our country. This will require navigating a new direction at such federal agencies as the FDA, the USDA, and the EPA to better protect the safety of consumers.
The FDA might start by protecting the 25 to 43 percent of our population that experienced adverse reactions to monosodium glutamate in studies conducted in the 1970s.
This could be easily accomplished by requiring that all existing processed foods, dietary supplements, and pharmaceuticals be analyzed for “free glutamic acid.”
Subsequently, when a new product is introduced or a formulation is changed, the product must be analyzed for free glutamic acid. If free glutamic acid is present in a product, it must be disclosed as “MSG,” with the amount stated in milligrams on the labels of processed foods and dietary supplements and on the product inserts of pharmaceuticals.
Reduced Salt, More Chemicals
Recently, a number of food companies have announced that they will be reducing the salt content of their products by 20 percent. This includes many food giants, such as Kraft Foods and Nestlé.
We now have a similar announcement from Frito-Lay regarding their salted potato chips. Meanwhile, the FDA appears to support the reduction of salt in processed foods, but has not issued any regulations on the subject.
According to the Frito-Lay announcement, the reduction in salt content will be achieved by changing the shape of salt crystals, affecting how they will be used in the body. The change in shape of salt crystals would not appear to be detrimental to humans, but of course, we do not know the process that will be used, nor do we know whether any chemicals will be used.
Of real concern is the fact that the announcement about salt reduction just happens to have occurred shortly after a new salt substitute, Senomyx, entered the marketplace.
The Senomyx salt substitute is clearly a chemical product that works in the body as a neurological agent, causing an individual to perceive a salty taste. It would seem to be nothing more or less than a neurotrophic drug.
Because the maker of the Senomyx product calls it a food, it does not require the extensive testing that would be required by the FDA if it were called a pharmaceutical.
To our knowledge, there has been no testing of the Senomyx salt substitute for safety, and it is so potent that the amount needed in food is below the amount requiring FDA approval.
Furthermore, it will never be disclosed on food labels as Senomyx. It can be used in foods without being on the label, or it can be labeled as “artificial flavor.”