When it comes to product ingredient labeling, 'zero' does not equal 'none'.








A substance can fall below the Threshold of Regulation but that doesn't guarantee there is too little to do harm, especially in light of body burden synergies.

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.

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Many substances that are not considered "ingredients" -- in other words, not considered part of a food -- 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. Specific product exposures are not identified. There are 3000 chemicals listed and many have been identified as toxic.

The "indirect" food additives are more toxic than EAFUS additives, but "indirect" food additives receive less regulatory scrutiny and oversight. This is based on data claiming that toxic effects usually occur within predictable ranges of dietary exposure, and that the amount of "indirect" additives fall outside these ranges.

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

That view is shattered by new body burden research, better understanding of synergistic toxicity, and hormesis.

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Many food ingredients are deemed Generally Recognized As Safe (GRAS). That does not guarantee they are actually safe when combined with other chemicals.

A great number of substances used in foods prior to 1958 were automatically "grandfathered in" to GRAS status based on widespread use. In the 1970's concern began to grow over the actual 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 whereby individuals inform the FDA that the use of a substance is GRAS.


In other words, industry decides what 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 of these substances have been identified as excitotoxins or to have other toxic qualities.

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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.

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The U.S. Department of Agriculture (USDA) is proposing to add 38 additional ingredients to the current National List of substances permitted for use in organic food products. The additions are based on petitions made by industry.

Among the proposed non-organic ingredients are


• 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 had been published regarding the new exceptions as of of February 2008. Check for updates by going to Regulations.gov and searching for AMS-TM-07-0062 in the Search box.

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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.

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

Irradiating foods that contain fats (such as meats, eggs, seeds and 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.

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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 controls from start to finish.


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

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

Irradiating meat is illegal in Europe.


If a food is not irradiated but contains an ingredient that has been irradiated, the food label does not have to indicate the presence of irradiated ingredients.

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


• If consumers can't detect a "material change" in the food at the point of purchase then labeling will not be required.

• In cases where labeling is still required, labelers will be allowed to use words like "cold pasteurized” or “electronic pasteurization”.


Either way, consumers will no longer be able to identify irradiated foods.

As of February 2008 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.

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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 almonds for purchase in the U.S. and Canada are no longer natural, whole foods for consumption.


"Raw" and "organic" almonds are not exempt, but these chemically processed and cooked almonds can be misleadingly labelled as "raw" and "organic".

Explore the topic further starting with this search.