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The problem with that premise is that almost every substance has a remote chance of causing cancer in some way or another. Just ask the state of California. So you would have to ban everything if that is really your stance.

The correct (and scientifically valid) thing to do is to only take action when there is actual evidence and proof of harm being done. Otherwise, anyone can simply say X is harmful and pass regulations to get their pet bogeyman pulled off the market, and that is basically what is happening here.






> only take action when there is actual evidence and proof of harm being done

I agree with most of what you are saying. However, I think it's valid to also apply heavy scrutiny on new chemicals being added to the food chain. The default being to not allow it if it's not proven safe.

Red dye 3 probably shouldn't have been added to the food supply chain with that criteria but since it's already been there for decades with no strong link to negative outcomes there's little reason to ban it now.


You really don't want to know about GRAS (Generally recognized as safe) then. 700 food substances were grandfathered into the food supply chain and most new things are self-affirmed by the company selling them.

This is like the whole bugs in food thing.

Sometimes no bugs are allowed at all, people be getting upset if their pop tarts have bugs in them.

Sometimes it's like some bugs are allowed and just part of it like when I buy organic broccoli at the farmers market and need to soak it to get whatever those things are in there out. Or when I get those little mummified bugs in the bottom of oatmeal tins.

Sometimes it's like the food is literally coated in bugs like all that stuff that's coated on schellac. Which, finally to bring it back to a callback to your point, is both GRAS and also made of bugs.


Shellac isn't made of bugs - it's made by bugs. Specifically, it's the resin secreted by a female lac beetle onto the branch of the trees that they live and feed on.

Yes, thank you.

I also learned today that the harvesting process kills the lac beetles.


I don't disagree with you, but we don't have heavy scrutiny on the existing and natural chemicals that are in the food chain from all of the plants that we eat.

You could build a heuristic risk score against each molecule:

- What functional groups does it have?

- How many functional groups does it have?

- How much electron delocalization does it have?

- How much of that electron delocalization is PAHs?

- Does the molecule participate in redox reactions?

Etc.

Basically check to see which molecules can generate free radicals, strip DNA, convert to dangerous metabolites, etc.


It's call QSAR https://en.wikipedia.org/wiki/Quantitative_structure%E2%80%9... They may use a hundred of properties to guess the effect of the molecule.

Once you have that trained, you'll be able to publish it and dramatically improve the current SoTA!

I wish it was as easy as this - while there are known toxicophores/no-go functional groups in medchem, there is going to be a big dearth of data on non-acute (e.g. not hERG, hepatotoxicity, etc) toxicity, which is really what the question is here: what are the marginal risks/rewards from eating existing food X (since we know it's probably not acutely toxic).


> The correct (and scientifically valid) thing to do is to only take action when there is actual evidence and proof of harm being done.

Because we're talking about food I would actually like to see the opposite. Provide peer reviewed, gold standard studies showing that what you want to put in food is in fact safe.


There is no such thing as proving something "safe". Go back and re-read the parent comment. The important point you are missing is that basically anything can be "linked" to cancer, and if you adopt the argument you are making, there would be nothing left.

Proving something safe is logically equivalent to proving that it is not unsafe, which is the same thing as proving a negative, which cannot be done. I cannot prove there is not a teapot circling Mars, and I cannot prove that even the most inert ingredient, at some dose, will not harm you.

Anyone who has lived in California knows this absurdity more intuitively than most people, because California's stupid laws adopt the logic you are proposing, and basically everything in daily life is labeled as cancer-causing.


A lot of folks in child comments are echoing your sentiment that something “cannot be proved safe”. Your argument that proving something is “not unsafe” is proving a negative is fallacious; the same can literally be said about anything (proving something is X is the same as proving it is not not-X). Proving drugs are safe and effective is literally one of the jobs of the FDA. If you do not believe that is possible, then we may as well tear down the entire drug regulatory apparatus. I imagine you and many other commenters will sing a different tune when posed with that suggestion.

So, let’s stop pretending it’s not possible. We require drug companies show their products are safe and efficacious, and there is both a scientific and a legal framework by which we do this. Let’s debate whether or not the same framework should be applied to food additives (I would argue it should) rather than claim it is not possible.


We require drug companies show their products are safe and efficacious, and there is both a scientific and a legal framework by which we do this.

We don’t do this.

What the FDA requires is acceptable safety in light of the benefit provided.

The FDA approves highly toxic drugs all the time. Including ones with the risk of death. I don’t think anyone would call chemotherapy “safe”.


"Safe" for the FDA means the benefits outweigh the potential risks, not safe in absolute terms.

If the FDA actually required every drug to be proven safe at any dose for everyone, we'd have no modern drugs.


> There is no such thing as proving something "safe".

Is that not what NCAP does?

Or what NTSB and FAA do with aviation?

You can prove that some things are safe. Does not mean infallible, means safe.


>There is no such thing as proving something "safe". Go back and re-read the parent comment. The important point you are missing is that basically anything can be "linked" to cancer, and if you adopt the argument you are making, there would be nothing left.

Really? You have some studies linking wheat and whole grains to cancer? And I don't mean wheat crops sprayed with glyphosate, just straight up wheat? Raspberries? Strawberries?

The reality is, very little of the actual natural food in our food chain is directly linked to cancer. All the additives we pile on top, on the other hand, are.

I would argue if we can't show a direct benefit to the consumer, it shouldn't be in the food chain. So, what is the direct benefit to a human consuming red-5? "It looks better on store shelves" isn't a direct benefit.

A shelf stabilizer? Sure, plenty of instances that makes a lot of sense. Food coloring that happens to be cheaper than natural alternatives? Just... no.


Yes, whole grains cause cancer if you make them into bread and toast the bread. The evidence is much stronger than for Red dye No. 3.

https://www.fda.gov/food/process-contaminants-food/acrylamid...

Strawberries are also linked to cancer, because they contain sugar.

https://aacrjournals.org/cancerres/article/62/15/4339/508983...

Almost all natural foods are linked to cancer. The important question is, how large is the risk?

Dark toast is obviously much riskier than Red dye No. 3. We should think about that when we consider what to ban.


Food isn't sold burnt from store shelves. Of course people may 'toast' it to unsafe levels. That's an educational issue.

Untrue, you can buy burnt bread at most grocery stores. Go to the bakery, look at the ends. Many will have burnt tips.

Also: I've never bought this, but I just found this premade product, which is sold in my grocery store and is known to the state of California to cause cancer.

https://www.safeway.com/shop/product-details.197151007.html?...


A good example is the cancer causing aflatoxin on peanuts.

https://www.fda.gov/regulatory-information/search-fda-guidan...

You could be enjoying some all natural peanuts and be exposing yourself to a highly carcinogenic byproduct of a fungus that grows on them.

Hell, people were doing that for millennia until some scientists actually discovered it.


Acrylamide is in all baked bread. It's formed during high temperature cooking - like baking.

Toasting just increases the amount present.


I sure can get it in a restaurant.

> The reality is, very little of the actual natural food in our food chain is directly linked to cancer.

Natural things aren't inherently safer. Are alcohol and red meat both considered natural? Alcohol is a group 1 carcinogen (same as tobacco and asbestos) and red meat is group 2A (probably linked to cancer). A cursory search shows some studies linking fish consumption to cancer, though I have no idea how accurate those studies are.


Fun fact - some things that cause cancer can help prevent cancer. Several studies have concluded that marinading meat in beer significantly reduces the carcinogenic compounds developed by frying or grilling meat.

> Natural things aren't inherently safer.

Yes they are.

We have been exposed to, and made adjustments for, things in our environments.

Novel chemicals have novel effects.

There are plenty of dangerous natural things, and there are safe artificial things (I suppose).

But there is a clear basis for eating food that your great grandparents would recognise.

There is also a slowly mounting volume of evidence that there is something wrong with ultra processed foods, hard to say what, but it is becoming clear they are bad for us.

So natural things are inherently safer, all else equal


Ultra processed foods are usually unhealthy because of the relative high amount of additives that are 'needed' to proloung their conservation. Those additives can be natural, like sugar and salt, but still are unhealthy in large quantities. Also heating, which can be seen as natural, can proloung conservation, but often have the side effect of chemical reactions into unhealthy molecules.

The better alternative is to eat non processed food, but only early after reaping. Otherwise the natural (!) chemical reactions like oxidation makes them unhealthy.

The plants in my garden are all natural. I don't use chemicals. Still half of them contain poison like blueacid.

Just to say, natural doesn't mean healthy. Processed doesn't mean unhealthy.


> But there is a clear basis for eating food that your great grandparents would recognise.

I’m quite confident every health metric is better for the Red-3-eating cohort than the great grandparent cohort. Being a great grandparent is associated with cancer, dementia, and near-unity death rate.


Sugar and simple carbs are natural, but are probably the cause of the majority of the world’s healthcare problems.

Sugar is a highly refined product. It is "natural" for a not very useful definition of natural.

Also I agree that not every thing natural is good. It is a rule of thumb, not a strict rule.

Mēh! The hippies were right (again): Eat food. Mostly plants. As unprocessed as you can.


I’ll ignore for a second you completely avoided the point to move the goal posts.

Alcohol isn’t a natural food, it’s a result of food rotting. Much like rotten meat, you can naturally assume negative side effects

Red meat has positive benefits from its consumption, as does fish.

What is the benefit of red5? If aren’t going to address that, I’ll assume you aren’t interested in anything but whataboutism and aren’t actually engaging in a good faith discussion.


> I’ll ignore for a second you completely avoided the point to move the goal posts.

Which goal posts did I move? Directly addressing a foundational claim isn't moving goal posts. You said that very few natural foods are directly linked to cancer. That's demonstrably false, as red meat almost certainly is. To your next point:

> Alcohol isn’t a natural food, it’s a result of food rotting.

I genuinely have no idea what you mean by natural then. At what point does something become unnatural? Alcohol certainly occurs in nature quite a bit, and I don't know that I'd call all the instances "rotting". Leavening bread with yeast produces noticeable amounts of alcohol. Orange juice famously contains a surprisingly high level of alcohol.

> Red meat has positive benefits from its consumption, as does fish.

Of course they do and that's why I never claimed they didn't. I would assume all foods have health benefits (beyond the obvious one of course). However, you claimed that most natural foods don't have links to cancer in particular.

> What is the benefit of red5?

I only just realized you said "red 5" earlier. I assume you're referring to red 3 (erythrosine), though I don't think the specific dye matters here.

> If aren’t going to address that, I’ll assume you aren’t interested in anything but whataboutism and aren’t actually engaging in a good faith discussion.

I'm not an expert on the dye in question and know little about it so I purposely didn't comment on it. I don't think I need to do so in order to address your central claim, which seems to be--and correct me if I'm wrong--that to lower our cancer risk we shouldn't add things to our food chain which aren't naturally in our food chain. That claim relies on 1) being able to distinguish what is natural to our food chain, and 2) for natural things being less likely to cause cancer than unnatural things. I believe 2 is flawed for the reasons I already gave. 1 is a famously thorny subject. Even pre-history human diets were varied enough for adaptations for different regions to evolve.

Anyway, I'm an idiot on the subject of dyes but if you want my argument: adding regulations isn't a zero-cost thing. We shouldn't add them without solid justification. I don't have enough knowledge about this subject to know whether or not such justification exists for the red dye in question here. However, your proposed alternative doesn't sound well-defined enough to be argued without you being clearer about what you mean.



There is no way to establish a food as "safe".

Health outcomes are noisy, especially if taken over a long time. Peer reviewed studies are often flawed in various ways and most scientific studies lack the statistical power to be inconclusive.

The fear based approach to human diets can not work. We have to accept risks in our lives if we want to eat at all.


"lack the statistical power to be inconclusive" is that right?

Natural food is not safe. Many natural foods that people eat, specifically plants, contain natural toxins and carcinogens that would probably not pass your threshold for "safe".[1]

[1] https://pubmed.ncbi.nlm.nih.gov/2217210/


I don't know about "peer-reviewed gold-standard studies," but what you've described is basically how the EU does it – what goes in food must be proven safe.

It's the opposite of the US approach, which is to ban (only) proven-harmful ingredients.

I don't expect US food-safety laws to become more strict in the next four years, but who knows, maybe the dead-worm guy will surprise us.


It’s impossible to prove a negative.

and that's also completely and totally irrelevant to the problem at hand.

Proofs don't apply in biology. Nothing in biology is a truly logical system that can be proved or disproved. That's true for chemistry and physics too- the only system where anything can be proved is math.

In science, instead we gather evidence and evaluate it, and often come to the conclusion that it is so unlikely something is dangerous (given the data) that we presume it's safe. People use the term "scientific proof", but I'm not aware of any in biology that would truly be classified as proof.


Why wouldn't you be able to prove a negative link?

It is logically and practically impossible to prove things to be untrue. We can only prove things that are true.

The thing we could prove is “no detectable increase versus control, in our test data”. There is no way to prove “x does not cause cancer” any more than there is a way to prove “x does not cause meteors” or “x does not cause spontaneous human resurrections” or “x does not cause humans to turn into unicorns”.


There is no distinction in logic between a positive statement and a negative statement. Every proof of a proposition P is also a proof of !Q where Q = !P.

Proof by contradiction is just that, assume P -> get contradiction, therefore proof that !P.

People really need to retire this canard.


Practically impossible, not logically impossible. "For all" proofs do exist in mathematics, but obviously it's very unlikely that you could do such a proof for physical reality.

How does “no detectable increase versus control, in our test data” not prove there is no connection (errors in the study aside). And why does that not prove anything, but "yes detectable increase versus control, in our test data” does?

Because, sure there can be errors either way. But a study produces new knowledge, not just knowledge or "just as much a mystery"


It is certainly possible to show that there is no positive correlation with a certain statistical significance. Pretending we're talking about such high standards as "no human future or presently alive could ever be harmed by any quantity of x" completely misses the point and borders on bad faith.

Let's set workable standards for when something can be called safe and enforce them.


No, you assign a risk score as well as a cost score to all the industrial inputs that you can use. In this case, there are readily available red food dyes (eg cochineal from industrially farmed insects) that have much lower risk scores (as they are from plant and animal sources) and not significantly different cost scores.

You also need to ask, what is the cost of not having this substance? In this case, the cost would be - you have food that isn't red. Is that a substantial problem for society?

To treat these as irrelevant and boil it down to "prove it is harmful or shut up" is needlessly reductive.


Have those other been proven safe? Is it possible they too cause cancer?

I'd like to point out that eating charred meat has a clear link with colon cancer, so we can't simply appeal to nature for safety.


> that have much lower risk scores (as they are from plant and animal sources)

This is a fallacy. If anything, there's more reason to expect that a substance evolved to serve a biological function (that happens to be red) would have biological effects in humans than a substance developed specifically to be red and be biologically inert.


You didn't address the part that it adds nothing useful to the food other than color.

That's an argument against all food dyes including natural ones.

Given color improves the enjoyment of food, I'd argue it is useful though.


So let's ban all artificial food dyes. Natural ones work fine. Artificial dyes lead to a race of food manufacturers adding more dye to make their junk food products more appealing.

"Presentation of food" is not "nothing useful". People who see basically eat with eyes. Like plate/food ratio can make you overeat. Or some food can be totally fine, but if it is just made to look bad for example rotten/expired it can be vomit inducing. Just like if someone says you just ate something bad, if you think what you eat is harmful the body will react

If there is no food coloring at all would we eat better? I bet yes. But we can't get there now. It will not pass any vote


Color is important for appeal and flavor. Otherwise we would never color food.

No you would only have to ban things with no nutritional benefit. The comment you replied to specified the case in question: it only lends the food a color.

I'm not really pro-bureaucrat, but perhaps the standard for food should be slightly different. Just maybe, (novel) food (additives/preservatives/ingredients) should first be proven safe, rather than waiting until they're proven unsafe to prohibit them. It's not as if this was a substance humans regularly ingested for centuries and people are only now wigging out... look at the wikipedia entry for this. The only halogen that's not part of this thing is apparently bromine, the IUPAC name for the chemical's about as long as my comment here.

Proven safe against what though?

I'm a big proponent of food safety regulation, but we have to acknowledge that there's no way to prove something is safe against all possible harms it might do. There will always be a risk in food. The question is how much risk will we tolerate?


Proof can take a while to get together.

I prefer the EUs precautionary principle that enables action to be taken when there is uncertainty over something.


Well, I guess you should start by banning all fruits and vegetables, because there's evidence that they contain toxins and carcinogens, and we're not sure if they're "safe"[1].

[1] https://pubmed.ncbi.nlm.nih.gov/2217210/


That is not how precautions work. If unsure, you ban the mostly unnecessary things.

"Hmm, there is an unknown risk with it, do I really need this unhealthy candy" no

"Do i really need this vegetable" yes

For an analogy, if your neighborhood is unsafe, you don't stop going to school altogether, you probably just won't go out for a night stroll.

This kind of absolute logical statement is very stupid.

Also, consider that when faced with unsure studies, the fact that fruits and vegetables are part of healthy human diet for centuries longer than a dye has been, is a major factor.


> That is not how precautions work. If unsure, you ban the mostly unnecessary things.

Yes - which includes vegetables. Humans can generally survive indefinitely on an all-meat diet.

> "Do i really need this vegetable" yes

No.

So, your general statement is correct, but you missed the basic fact that vegetables also fall into the category of "mostly unnecessary" things - so, my point stands.


You're just being obtuse now. Surely you understand the dietary difference between a vegetable and a dye that exists purely for aesthetic purposes? If not, there is no point continuing this.

I think you need to familiarize yourself with the precautionary principle, since i believe it applies here

PP Paper :

https://fooledbyrandomness.com/pp2.pdf


> The problem with that premise is that almost every substance has a remote chance of causing cancer in some way or another.

What is the scientific basis of this claim ?

It's pretty extraordinary that every single thing we eat is carcinogenic.


It's not extraordinary to state that every single thing we eat[0] can have a study designed around it to show that it might cause cancer -- that is how studies and chemicals (things we eat) work.

[0]Except water, maybe. I'd bet if you shoved enough water into a rat at minimum you could observe an increase in tumor growth rate though.


Sorry, IARC already labeled hot water a “possible carcinogen” a decade ago [0]. That puts water into the same risk category as RoundUp

[0] https://www.science.org/content/article/panel-s-advice-cance...


But isn’t it true. As in it’s not the chemicals in tea that causes throat cancer but the hot water.

This provides useful insight in that you should cool down tea/coffee before drinking


It's a strawman argument often brought up to argue against banning potentially cancer causing foods.

It's also not true, since many foods - most vegetables, for example, or many types of fiber - do the complete opposite, and reduce your risk of cancer.


> The correct (and scientifically valid) thing to do is to only take action when there is actual evidence and proof of harm being done.

How about only put things in food that are contributing to the actual food? It's not just nutritional value, it's absolutely taste and texture as well. But visuals? Surely you can agree the balance of "is it worth it" is different for the color of a fruity loop than for nutritional value and taste.

You're correct that the "acceptable" line needs to be somewhere because risk isn't absolute, but that line can be in different places for different purposes. (And you can't just write off all cancer concerns because some of them probably aren't legitimate.)


I'm not sure why you're getting downvotes for this because it seems to me a highly valid stance. Why do we allow mostly unchecked, highly processed junk food in our society, only banning items that have a high level of risk of being poisonous, if at all? Especially since the main target of a lot of it is children.

Shouldn't we take the opposite approach? Make it very hard to use highly processed unnatural products, to the point where it's cheaper and easier for companies to fall back on less processed "clean label" ingredients.

I work in (well, adjacent to) the F&B sector and I can tell you that every large company knows exactly what clean food means, why it's healthier, and where to source the ingredients, and that they have equivalent food products using these either already on shelves, or waiting to be produced if there's a shift in consumer desires.

The reason that they don't already use them - the reason you mostly only see advertising for processed foods - is because the more highly processed a food is, the higher the profit margins for companies. I've seen it stated as a rule that every level of processing gives a 2x profit margin. So if you can process an item 3 times, you'll 6x your profit margins (obviously a rule of thumb rather than law).


> Just ask the state of California

I've see the labels at Starbucks, by the chocolate at the grocery store, and by the balsamic vinegar.


In my experience if something is even slightly enjoyable it has a chance of causing cancer.

Anyone can say X is harmful, just not on X…

I would rather go other direction. When introducing new chemical or additive it has to be proven that is not harmful to humans before using it

> only take action when there is actual evidence and proof of harm being done.

Sounds like a good way to kill a lot of people




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