On a food label, “zero” and “none” are not equivalent.

“Zero” can still cause effects.

When an ingredient falls below the Threshold of Regulation (TOR) it doesn’t have to appear on a label.

But that doesn't guarantee there is too little to do harm.

The FDA maintains a list of "Everything Added to Food in the United States" (EAFUS).

The online list of 3000 chemicals does not reveal specifically which products contain these ingredients.

Many substances are not considered “ingredients”.

Because they are not considered part of a “food”.

But these “indirect” additives are still consumed when the food is eaten.

The FDA maintains a list of Indirect Additives Used in Food Contact Substances.

These are chemicals that wind up in food as a result of processing, packaging, and handling.

There are 3000 chemicals listed and many are known toxicants.

Products using "indirect" additives are not specifically identified in the FDA list.

The "indirect" additives are more toxic than EAFUS additives.

But “indirect” additives receive less regulatory scrutiny and oversight.


Because the FDA believes toxic effects usually occur within predictable ranges of dietary exposure.

And the the amount of "indirect" additives fall outside these ranges.

In other words, the policy is based on “the dose makes the poison".

That approach is inadequate due to new body burden research, better understanding of synergistic toxicity, and hormesis.

Many food ingredients are deemed Generally Recognized As Safe (GRAS).

That does not guarantee they are actually safe, especially when combined with other chemicals.

Hundreds of substances were automatically "grandfathered in" to GRAS status based on their widespread use prior to 1958.

No review, no modern safety testing.

In the 1970's concern grew over the true safety of GRAS substances.

The FDA implemented a process for reviewing safety based on newer data.

If the substance's use was still considered generally safe its GRAS status was 'affirmed'.

People could petition to have a GRAS substance added to the review process.

Beginning in 1997 the FDA sought to discontinue its voluntary review of substances.

Although the petition process has not been officially abolished, there is no staffing for it.

A new procedure was introduced.

Tell FDA that the use of a substance is GRAS.

That means the maker can decide whether it is safe.

There is an inherent conflict of interest.

See these lists for a partial glimpse of food ingredients considered GRAS.

This list summarizes all GRAS notices received since 1998.

Several GRAS substances have been identified as excitotoxins or to have other toxic qualities.

Read about excitotoxins and vaccines.

Then read this update to the Federal Register concerning rules for the National Organic Program.

You discover that vaccines and various excitotoxins are allowed in the use of organic food production.

The EPA's List 4 — Inerts of Minimal Concern is also allowed in organic production.

It includes a long list of chemicals that are contrary to the principle of chemical-free production.

The U.S. Department of Agriculture (USDA) keeps the National List of substances permitted for use in organic food products.

It is proposing to add 38 additional ingredients.

The additions are based on petitions made by industry.

Among the proposed non-organic ingredients are

Petition Use
Fish oil unpurified of heavy metals, dioxin and PCBs To elevate the omega-3 fatty acid content of "organic" baked goods, cereals, cheese and soups
Intestinal casings of factory farmed animals raised on chemically grown feed, synthetic hormones, and antibiotics For "organic" sausages and other meat products
Hydrolyzed additives such as gelatin, inulin, and whey protein concentrate For various purposes in "organic" foods and products
Extracts from certain fruits and vegetables farmed using synthetic pesticides and chemically tainted fertilizers To be used as colorings in "organic" foods and products
Hops grown with synthetic pesticides and fertilizers For "organic" beer
Other inorganically grown ingredients such as shellac, lemongrass, chipotle chile peppers, seaweed, and several starches For various purposes in "organic" foods and products

According to the USDA, these substances have already been used

• in organic food production by producers who

• believed that any non-organic agricultural substance could be used if

• an organic form was unavailable.

Effective June 2007 a rule went into effect clarifying that only ingredients appearing in the National List are permitted.

No final decision has been published as of of December 2010.

Check for updates by going to and searching for AMS-TM-07-0062 in the search box.

The American Academy of Pediatrics (AAP) finally agreed in February 2008 that parents and researchers have been right.

Food additives really do affect behavior.

Trying a preservative-free, food coloring–free diet is a reasonable approach to reducing a child's behavioral problems.

Foods can be intensely irradiated in an attempt to kill pathogens.

Irradiating foods that contain fats (meats, eggs, seeds, nuts) produces radiolytic byproducts named 2-alkylcyclobutanones (2-ACBs).

2-ACBs have been observed to cause colon cancer.

In some cases the level of 2-ACBs increases the longer a food stays packaged.

Foods are irradiated as a convenience in production and distribution.

• Produce may ripen while in distribution.

    Irradiation can delay ripening.

• Irradiation can extend the shelf life of meat.

• Low hygiene and filth during production lead to higher pathogen levels.

    Intense irradiation at the end is less expensive than tight sanitary controls from start to finish.


It is illegal in the U.S. to sell meat contaminated by pathogens above a certain level.

But it is legal to store the contaminated meat and irradiate it — then sell it to the public.

Irradiating meat is illegal in Europe.

A non-irradiated food can have irradiated ingredients.

The label does not have to indicate the presence of irradiated ingredients.

There is a proposal in progress that seeks to change the way irradiated foods are labelled.

• No labelling if consumers can't detect a "material change" at purchase time.

• If labels are required, allow words like "cold pasteurized” or “electronic pasteurization”.

Either way, consumers will find it harder to identify irradiated foods.

As of December 2010 no ruling had been published.

For an update try going to the FDA search site and entering 2005N–0272.

Here is a Living On Earth segment discussing the proposal.

Beginning September 2007 a rule went into effect that requires all California almonds to undergo "pasteurization".

What this really means is fumigation with propylene oxide and heat processing.

Essentially 100% of commercial almonds produced in the U.S. and Canada are no longer natural, whole foods.

"Raw" and "organic" almonds are not exempt.

But those chemically processed and cooked almonds can be misleadingly labelled as "raw" and "organic".

Explore the topic further starting with this search.