A Case of Misguided Activism
Just in time for fall, Starbucks announced a recipe change to their beloved Pumpkin Spice Latte recipe: it is removing the caramel coloring and adding real pumpkin.
Why? It’s the result of a misguided campaign, to make a 400-calorie beverage appear “healthier”, led by consumer groups, like the Center for Science in the Public Interest and self-proclaimed food activists like the “Food Babe” Vani Hari.
These groups have demonized the caramel coloring, which contains the chemical 4-methylimidazole (4-MEI). It is a natural byproduct of roasting coffee beans and other processes that involve high temperatures, including the production of certain caramel colors (see: Maillard reaction). The concern does not seem to be based on science. Regulatory authorities in the U.S., Canada, Europe and Hong Kong have determined that that there is no immediate or short-term risk from 4-MEI levels typically encountered in food as a result of the addition of caramel coloring.
These groups claim that 4-MEI is a known carcinogen, ignoring the fact that the dose required to cause cancer in lab mice is over 80 milligrams per kilogram of body weight everyday for 106 weeks. This means the average adult male in the U.S., weighing about 195.5 pounds, would need to consume over 7 grams of 4-MEI every day for over two years. They also don’t seem particularly concerned about “natural” 4-MEI in their coffee, soy sauce, beer or bread, but people are very worried about the exact same chemical when it is added in artificial coloring. Because PSLs are, for most people, not a dietary staple and only available for a short time of year, the amount of 4-MEI exposure from pumpkin spice lattes is likely a tiny fraction of one’s total exposure to 4-MEI.
Is this decision designed to treat us to a safer beverage or trick us through marketing to make us think we are consuming a safer treat? I’m gonna go with trick and brilliant marketing.
Because the uproar is only about the artificial 4-MEI, and no one is talking about all the naturally formed 4-MEI we are exposed to (even in the same drink), all I can conclude is that Starbucks made these changes, not based on scientific evidence regarding potentially dangerous exposure limits and the toxicity of 4-MEI, but rather on market research in response to rising consumer fears propagated by so-called “food activists”.
As someone involved in toxicology research, I am all in favor of reducing toxic exposures. This is a noble goal. Unfortunately, targeting the food villain of the month is a largely ineffective way to accomplish this. Consumers and journalists have an important role to play, but that all depends on having access to accurate, current information and working with scientists and regulators to work towards this goal.
These campaigns against single chemicals lead companies like Starbucks to change their recipes not based on science, but because activists like Vani Hari and Michael Pollan, who won’t buy their food anyway, can’t pronounce their ingredients. These campaigns usually do not reduce toxic exposures overall and they do not educate or empower consumers.
The tale of the pumpkin spice latte is a perfect example of how these campaigns are based on fear and a fallacious appeal to Nature, with little regard for the scientific data. Even when there are data to suggest that there might be some toxicity, these campaigns are rarely evidence-based. There is a crying wolf factor as well; the scientific illiteracy of many of these activists makes it easier to dismiss all concerns about toxic exposures, even the valid ones, as unfounded chemophobia.
These misguided campaigns are often counterproductive for reducing toxic exposures and effecting positive change.
Bisphenol A and regrettable substitutions
The campaigns against specific chemicals often overlook the big picture resulting in what has been dubbed “regrettable substitutions”. This refers to the removal of a chemical without considering the alternatives that might replace it. A now classic example of regrettable substitutions concerns Bisphenol A (BPA). Bisphenol A is thought to be an endocrine disrupting chemical that scientists have studied and continue to study extensively. Although there is still disagreement about the effects of BPA in humans, for sake of argument, let’s assume there is no question about whether BPA is toxic at real life exposure levels.
When consumer groups bypassed scientists and regulators and convinced companies to remove BPA, it was replaced with Bisphenol F and Bisphenol S. Their main virtue was that they had been studied far less than BPA and were not in the crosshairs of activists and so they were easily substitutable. But in fact studies show they have similar activity and potency as BPA in cellular and animal models and similar biological effects in humans as BPA. Thus, while these campaigns reduced exposure to BPA specifically, they did not reduce exposure overall to phenols, which have similar effects. They may even have made it more difficult to make regulatory changes since there is less research on BPF and BPS.
There is real science behind how to choose safe alternatives when phasing out a chemical. These campaigns bypass that process completely and would likely be better able to reduce toxic exposures by pushing for adoption of adequate chemical alternatives assessment.
Antibiotic resistance and false evidence
Last week, Subway announced that they will only be serving meat from animals that have never been treated with any antibiotics, even to treat a sick animal.
The brand recently communicated a commitment to transition to only serving chicken raised without antibiotics important to human medicine. Today, the brand confirmed that it is beginning to transition to serving only protein from animals that have never received antibiotics across all of its 27,000+ U.S. restaurants in early 2016.
This announcement came as an effort to address concerns by activists about antibiotic resistance. They motivated people to join the campaign by scaring them about toxic antibiotic residues in meat products. Food activists all over the Internet are commending Subway for this decision. Vani Hari gushed on her blog:
I had my bags packed and ready to go to deliver over 250,000 petition signatures with several consumer advocacy groups to Subway headquarters this week but all my plans came to an abrupt halt.
Subway just announced that they have committed to eliminating the use of antibiotics in ALL of their meat in the U.S. – and they also provided a timeline. It’s never felt so good to cancel my plans!
Farmers, on the other hand, are dismayed that this policy did not even allow for treating sick animals even if the antibiotics are not used in human medicine and completely ignored that there are very strict regulations and testing to ensure that there are no antibiotic residues in dairy, meat, poultry and egg products. In other words, the campaign did more to fuel mistrust of farmers than educate the consumer.
To be clear, antibiotic resistance is a looming problem. However, antibiotic residues in our meat are not a factor in this. The actual concerns about antibiotic resistance have nothing to do with drug residues in your meat; they are less about the treatment of sick animals and more about the use of antibiotics for growth promotion and prevention of disease (prophylaxis). Subway’s marketing decision may make food activists happy. However, actual policy only requires farmers to follow existing laws and the new voluntary FDA regulations that were announced in June of this year, before these groups launched their campaigns against Subway. In reality, this ‘victory’ will accomplish little in the very important battle against antibiotic resistance.
Antibiotic resistance is a serious enough problem we should all worry about that there is no need to make up problems about exposure to antibiotic residues to justify taking action. Activists are motivating by misleading people and, as a result, it makes it easier for people to dismiss all concerns, even the valid ones, about antibiotic resistance.
These examples demonstrate how chemophobic hysteria detracts from the message when there are actual issues of concern, making it more difficult for valid concerns to be taken seriously. Organizations like the Environmental Working Group, The Campaign for Safe Cosmetics, and people like Vani Hari and Michael Pollan, seem to completely disregard the basic principles of toxicology and science to promote the idea that there is no acceptable level of any synthetic chemical, ever.
Many scientists and skeptics remain doubtful about suspected endocrine disrupting chemicals and issues of antibiotic resistance, partly because the groups speaking out most loudly about these concerns have shown a lack of scientific credibility on other issues. For example, this past weekend, The Huffington Post ran an article about endocrine disrupting chemicals, but had to throw in some nonsense about glyphosate causing birth defects, even though it is neither teratogenic nor endocrine disrupting. Because they continue to misrepresent facts, to draw inflammatory conclusions, or to seemingly just make things up, these campaigns are, ironically, counterproductive in the long term for the goal of reducing toxic exposures.
For consumers who are concerned about chemicals, there is a lot of science-based information and it’s publicly available!
None of this is meant to say that toxic exposures aren’t an issue. But not all chemicals are toxic in the doses that we are typically exposed to. There is a lot of publicly available information about our exposures and the associated health effects. The Centers for Disease Control (CDC), the Department of Health and Human Services, and National Institute of Environmental Health Sciences (NIEHS) all maintain databases and websites meant for the public to find the most up-to-date scientific information.
- The National Health and Nutrition Examination Survey (NHANES) at the CDC has collected enormous amount of demographic, socioeconomic, dietary, and health-related data about the U.S. population. Data from NHANES is used to generate the CDC growth charts for kids that many of us are familiar with. The data is also used to calculate the prevalence of diseases and risk factors for disease, in epidemiological studies and to identify areas of concern that need to be addressed by public health officials. Much of the data collected as a part of the survey and the analysis of this data is available on the CDC website. Data on chemical exposures is included in this survey and that data is compiled into tables that are published on the CDC website as well.
- The National Biomonitoring Program, also run by the CDC, assesses over 300 environmental chemicals in human tissues and fluids and the nutritional measures in the US population. This data are used to figure out which chemicals get into our bodies and where they go within the body (blood, urine, saliva, breast milk), to monitor how many people are exposed above known toxicity levels and to track trends over time. The most recent assessment of exposures, the National Report on Human Exposure to Environmental Chemicals, in the U.S. was published earlier this year. This document contains all the data about how much of each chemical was detected and links to summary information about what these numbers mean and a chemical fact sheet on each chemical. NBP also publishes the National Report on Biochemical Indicators of Diet and Nutrition in the U.S.
- NIEHS also funds exposure assessments, especially as it relates to children’s health. They recently launched an expanded program, the Children’s Health Exposure Analysis Resource, to help researchers add or expand the environmental exposures studied.
- NIEHS also publishes chemical fact sheets and information about current areas of concern in environmental health sciences.
- The Household Products Database is maintained by the U.S. Department of Health and Human Services. The database, which was started in 1995 and is updated twice a year, contains information about the most common non-food and non-pharmaceutical consumer products. It provides the ingredients for a huge number of products and links out to databases like ToxNet that contain the toxicology data on those ingredients. Information about food-related and pharmaceutical products are available on the FDA website.
- Paula’s Choice maintains an ingredient dictionary that is much more in line with current toxicology data that EWG’s database. Their ratings take into account dose, mode of exposure and formulation; all things that EWG seems to ignore in their assessments.
What are effective strategies for reducing toxic exposures at a public health level?
First and foremost, be skeptical and apply reasoning and critical thinking when you read a claim. Educate yourself with accurate, science-based evidence. This means information from reputable, peer-reviewed scientific journals. If you are not familiar enough with a field to assess whether a journal is reputable, find science communicators with established reputations for reporting science accurately. Take advantage of the publicly available resources, including those listed above.
Remember that no exposure occurs in isolation and that exposure to a chemical does not necessarily mean there is an ill effect. Even with these toxic exposures, toxicologists are often talking about small effects that can often be counteracted through positive exposures. Dr. Robin Whyatt, Deputy Director of the Columbia Center for Children’s Environmental Health said the following on an NIEHS podcast about phthalates that captures this idea (emphasis mine).
People are exposed to a lot of different compounds but we know that eating a really good diet during pregnancy is absolutely critical and has enormous beneficial effects, that taking prenatal vitamins is very beneficial and probably the key thing in terms of a child’s development is stimulation of the child. Read to your child. Play with your child. Talk to your child. All those things are just incredibly important and probably have much more effect, positive effect than these chemicals are having negative effects. So it’s really important to keep this in perspective. This is one exposure. It’s worth trying to avoid, but you can do a whole lot to help your child by the way you eat and by how you play with your child.
Encourage funding of research to fill the gaps in our knowledge. Toxicology and exposure science are making huge methodological and technical advances. Today, we can do so much more than screen just one compound at a time for mutagenicity and for whether it causes cancer. Regulators can only make decisions based on the evidence. Help them have more evidence by campaigning for increased funding for toxicology research. This funding must come from both public agencies and industry. Yes, I wrote industry. As those who stand to profit from this research, industry needs to bear some of the cost burden of this research, just as pharmaceutical companies contribute to clinical trials. Taxpayers should not bear this burden alone.
Learn about the different regulatory mechanisms for different classes of chemicals. Chemicals are regulated based on how they are used. Pesticides are regulated differently than food additives, differently than cosmetics, differently than drugs, and differently than consumer products. Each class requires different levels of pre-market testing, different types of monitor and different procedures for handling violations. Multiple agencies play different roles in these regulatory processes. Without understanding how these processes work and how they are different, it is not possible to encourage effective reforms.
Above all, avoid inflammatory rhetoric and hysterical chemophobia; stick to the facts and the evidence.
Alison Bernstein a neuroscientist studying the role of epigenetics in neurodegenerative diseases and toxic exposures. She lives in Atlanta with her husband, 2 kids, and 2 cats. You can follow her on Facebook and G+, where she writes as “Mommy PhD”, and on Twitter @mommyphd2.