Are There Chemicals in My Food?

By Gary C. Smith and Keith E. Belk, Colorado State University 

You bet there are! All of our food – like everything in the world – is made up of “chemicals” (i.e., all things consist of one or more – like carbon, hydrogen, oxygen, etc. – of the 118 elements on the Periodic Table).¹ Proteins, carbohydrates, lipids, micronutrients, vitamins, minerals, even water – they’re all chemicals or comprised of chemicals.² If we don’t want to consume any chemicals, we’ll have nothing to eat or drink.³

Chemicals and Consumer Perceptions

Most chemicals have potential to be harmful if consumed at an unsafe level.² Nevertheless, a global consumer poll in 2017 concluded that the Top Perceived “Most Important Food Issue Today” is “Chemicals In Foods”.⁴ An article in Reader’s Digest claimed that the word “chemical” is often used as a synonym for “toxin” or “poison”, and that government regulators say it’s okay to label food as “Chemical-Free” because consumers clearly understand that the term really means “Free Of Synthetic Chemicals”.⁵ If that’s true, both consumers and regulators are misinformed.⁶

The Early Days of U.S. Food Regulation

Since 1906, our first line of defense against toxic chemicals being included in U.S. food has been embodied in federal regulations. In response to Upton Sinclair’s book “The Jungle”, Theodore Roosevelt forced passage by the U.S. Congress of the Meat Inspection Act and the Food and Drug Act.⁷ Food Safety and Inspection Services (FSIS) and the Food and Drug Administration share responsibility for the safety of our food.^8,9

Between 1906 and 1938, a few pesticides (e.g., arsenic, rotenone) were being used on farms/ranches and during storage of grain, fruits, and vegetables, while some processing aids (e.g., nitrate, colorants, preservatives) were being used by food manufacturers.¹⁰ Both Agencies were testing for presence or excesses of those chemicals in food, but it was largely being done by FSIS to detect “economic adulteration” (commonly known as “food fraud“) of the products that FSIS is responsible for (e.g., dyes, antioxidants, and excessive amounts of water, fat, or fillers).¹¹

Expansion of Regulation: The Delaney Clause             

In 1938, the U.S. Congress inserted “Cosmetic” into the new Food, Drug, and Cosmetic Act. Later, Congress included an amendment by way of the Food Additive amendment of 1958 and the Color Additives Amendment of 1960. The amendments were called the “Delaney Clause” and stated, “If a synthetic, but not natural, chemical – at any dose – can be shown to cause cancer in laboratory animals, the chemical must be banned.¹²

The Clause wasn’t used much by the Agencies during the next few years. The lingering impacts of the Great Depression, World War II, and its aftermath, caused our government to focus on getting as much food as possible on people’s plates.

After World War II ended, many U.S. companies that had produced munitions and other war-related chemicals pivoted, beginning to manufacture synthetic chemicals designed to increase agricultural productivity by improving the health of livestock and crops, as well as to improve the quality, consistency, shelf-life, and nutrient content of processed food.¹³

The Cranberry Crisis and Aminotriazole

In 1958, the Agencies (FDA and USDA) were trudging along doing what they thought was best to protect public health. People weren’t “dying in the street” (and never have been) because of toxic chemicals in their food.

Suddenly, on Sept. 6, 1958, it became publicly known that a common weed-killer – aminotriazole – did not pass the requirements of the Delaney Clause (i.e., it flunked the “Ames Test”, which is now sometimes criticized with respect to the Delaney Clause because there are more robust methods available today). Aminotriazole was being used commercially in the growing of cranberries.¹⁴ No one had gotten sick or died after eating them, but sales of cranberries suffered a disastrous plummet.¹⁴

Modern Oversight of Chemical Safety

By 1991…

1. About half of the tens of thousands of the pesticides, food additives, and industrial chemicals examined were found to have induced cancer in humans or animals (via the Ames Test) and were banned by the FDA.¹⁴
2. Dr. Ames was the biggest critic of the government’s use of his test to determine a chemical’s safety.¹⁵
3. The U.S. Congress required the FDA to no longer use the Ames Test to test for, or regulate, carcinogenicity of synthetic chemicals.¹⁶

Both Agencies (FDA and FSIS) ramped up their chemical testing protocols, in cooperation with the Environmental Protection Agency (EPA), working jointly to oversee prevalence/quantity of toxic chemicals in U.S. foods from domestic/foreign sources.

What Does “Adulterated” Mean?

Such oversight starts with a definition of “adulterated” – which means “made impure by mixing in a foreign or inferior substance”.¹⁷

From a regulatory perspective, both the FDA and FSIS basically define “adulterated” as: “Food products that are rendered unsafe, unwholesome, or otherwise unfit for human consumption.”

A food is “chemically adulterated” (and thereby “legally inedible” by FSIS and the FDA) if…

1. The raw material contains a toxic, dangerous, or hazardous amount of a poisonous, deleterious, or injurious substance, or…
2. If such substance is added during production, processing, or preparation of the food product.¹⁸

Oversight for control of chemical adulteration consists of: (A) Limit Setting; (B) Enforcement; and (C) Monitoring.¹⁹

(A) Limit Setting

The EPA registers pesticides and sets “Tolerances” for residue concentrations of pesticides in all foods.²⁰ The FDA sets Tolerances for all other chemical adulterants in both FDA-regulated and USDA-regulated foods, determining safe levels of chemicals that…

• Occur naturally in raw materials
• Are added to food
• Are contaminants from the environment
• Are used in packaging
• Can form when raw foods are cooked and/or processed^21,22

Two key elements important for determining safe levels of chemicals are…

1. Acceptable Daily Intake (ADI) – the amount of a chemical that can be ingested by a person on a daily basis over a lifetime without any appreciable health risk (plus a safety factor).
2. Maximum Residue Level (MRL) – the maximum concentration of a chemical residue in a food that is acceptable for consumption.^23,24

The “violative level” set as a “tolerance level” uses a 10-fold to 1,000-fold safety factor (i.e., 10 to 1,000 times the level at which the chemical endangers human health) to protect consumers (and animals) from the harmful effects of too much of any chemical.^25,26 If a U.S. “tolerance level” for a particular pesticide or food additive has not been established, any amount detected is considered violative.^9,27

Any substance intended for use as a food additive must…

• Be approved as “Generally Recognized As Safe” (GRAS) by qualified experts, or…
• Meet a listed exception to the “Food Additive” definition in the Food, Drug, and Cosmetic Act.²⁸

Otherwise, the food additive is unsafe and the food is adulterated.²⁸ The FDA regulatory platform includes a GRAS list for certain chemicals that may be used as ingredients or processing aids for foods, while FSIS regulations reference the GRAS list and include a “Safe & Suitable Directive” list of compounds that may be used as processing aids (e.g., things like “Use of 2.5% to 5.0% lactic acid on beef subprimals and trimmings”).^9,19

(B) Enforcement

FSIS regulates meat, poultry, egg products, and catfish via the Pathogen Reduction; Hazard Analysis and Critical Control Points Systems (HACCP);⁸ FDA regulates all other foods via HACCP (for fish and juices) or Preventive Controls For Human Foods (PCHF).⁹

A HACCP protocol describes the types of chemical hazards as that can occur, including…

Contains:

1. In raw materials (e.g., toxins, mycotoxins, veterinary drugs, heavy metals, allergens, antibiotics, hormones, pesticides, and environmental contaminants).
2. Direct processing additives (e.g., flavor enhancers, color additives, thickeners, curing ingredients, allergens, stabilizers, antioxidants, mold inhibitors, and microbiological processing aids).
3. In packaging materials (e.g., PFAS and at least 9,900 or more other chemicals.^29,30  

Inadvertent Additions:

1. Indirect processing additives (e.g., boiler water additives, peeling aids, and defoaming agents).
2. Building and equipment maintenance chemicals (e.g., lubricants, paints, and coatings).
3. Cleaning/sanitizing, pest-control chemicals (e.g., cleaners, sanitizers, and pesticides).
4. Storage/shipment chemicals (e.g., cross-contamination with all kinds of chemicals).^8,19

Chemical Hazards in the Food Supply

The PCHF regulations (as well as the Preventive Controls for Animal Food) describes the types of chemical hazards as…

• Naturally Occurring: Included are food allergens, mycotoxins, and decomposition by-products.
• Used In Formulation: Examples are food additives, color additives, and preservatives.
• Unintentionally Or Incidentally Present: Included are cleaning and sanitizing chemicals, pesticides, industrial chemicals, heavy metals, drug residues, and radiologicals hazards.⁹

Far and away, the majority of inherent and dangerous chemicals in USDA-regulated foods are veterinary drugs, growth promotants, and pesticides; for FDA-regulated foods, the majority of inherent and dangerous chemicals are allergens, while the majority of extraneous and dangerous chemicals are pesticides.^31,32

Industrial and Radiological Contaminants              

The “raw material” of essentially all foods is exposed to what PCHF calls “industrial chemicals”; that is: “dioxin, furan, and polychlorinated biphenyls that are released into the air from combustion processes, such as commercial or municipal waste incineration and from burning fuels, such as wood, coal, or oil, burning of household trash, forest fires, and accidental/intentional release of transformer fluids.”⁹

Radiological hazards” (e.g., radium-226, uranium-238, and strontium-96) can be present in foods – having appeared because the radionuclides travel in soil, water, and air.⁹ Those food processors who must adhere to Global Food Safety Initiative schemes (e.g., SQF and BRCGS) or PCHF must also account for radiological hazards in the foods that they produce.^33,34 Environmental contaminants (i.e., “Industrial Chemicals” and “Radiological Hazards”) undergo the least governmental scrutiny because they occur so rarely and so sporadically.^9,35

Naturally Occurring Chemical Hazards             

Raw materials for some foods contain…

• Toxins (mushrooms, shellfish, and marine fish).
• Mycotoxins (grain, fruits, and nuts); heavy metals (fish and shellfish).
• Allergens (peanuts, tree nuts, eggs, milk/dairy products, soy, wheat, fish, shellfish, and sesame).
• Histamine (cheese).^9,19

For some raw materials, producers or intermediaries (sellers or wholesalers) must submit chemical-presence affidavits or Certificates of Analysis (COA; negative lab tests for the compounds) that ensure no contamination with unacceptable levels of toxins, mycotoxins, antibiotics, growth promotants, and pesticides.^32,36,37

Role of Food Safety Plans            

For all chemicals that are “direct processing additives” or “inadvertent additions” in HACCP, or “used in formulation” or “unintentionally or incidentally present” in PCHF, each company must depend on its Food Safety Plan to prevent “chemical adulteration”. Embodied within the Food Safety Plans for companies that manufacture food regulated by FSIS and FDA are Prerequisite Programs; HACCP or PCHF Programs; and six sets of Procedures and Practices.^8,9

If the company’s culture is such that the employees consistently follow the directives and guidance of Standard Operating Procedures (SOPs), Current Good Manufacturing Practices (GMPs; a FDA regulatory requirement), Good Agricultural Practices (GAPs), Good Sanitation Practices (GSPs), Good Hygiene Practices (GHPs), and Good Transportation Practices (GTPs),^8,9,19,31 chemical adulteration is very unlikely to occur.

(C) Monitoring

The FSIS, FDA, and EPA have monitoring programs that continuously assess the prevalence/quantity of toxic chemicals in U.S. foods from domestic/foreign sources. This allows the three Agencies to…

1. Identify trends in the use of legal extraneous chemicals.
2. Detect the use of illegal extraneous chemicals.
3. Collect information on occurrence of rare/sporadic environmental contaminants.

These surveillance programs include those by USDA:

• National Residue Program^38,39
• Residue Repeat Violators List^40,41
• Pesticide Data Program^42,43
• Special Topic Separate Reports (on Melamine, Semicarbazide, Nitrofurazone, Dioxin, and PFAS^44,45 

Those implemented by FDA:

• Total Diet Study^46,47
• National Milk Drug Residue Database⁴⁸
• Pasteurized Milk Ordinance⁴⁹

And Those implemented by EPA:

• Polycyclic Aromatic Hydrocarbons⁵⁰

REFERENCES

¹Dorland’s Illustrated Dictionary. 1988. W.B. Saunders Company. Philadelphia PA.

²FDA-USDHHS. 2024. usfda@public.govdelivery.com. Accessed on 4/3/2024.

³Smith, Gary. 2019. Texas A&M University. January 26 Issue.

⁴International Food Information Council. 2017. Press Release. December 15 Issue.

⁵Lorch, Mark, 2015. Reader’s Digest. August Edition.

⁶Gabbett, Rita. 2016. Meatingplace. July 27 Issue.

⁷Teicholz, Nina. 2014. The Big Fat Surprise. Simon and Schuster. New York NY.

⁸FSIS-USDA. 1996. Pathogen Reduction; HACCP Systems. July 25 Issue.

⁹FSPC Alliance. 2016. Preventive Controls For Human Food. First Edition.

¹⁰Smith, Gary. 2023. Colorado State University. June 18 Issue.

¹¹FSIS-USDA. 2023. FSIS Directive 80801. December 19 Issue.

¹²Campbell, Hank. 2018. Food Quality & Safety. November Edition.

¹³Smith, Gary. 2024. Texas A&M University. January 77 Issue.

¹⁴Carroll, Vincent. 1991. Rocky Mountain News. January 27 Issue.

¹⁵Ames, Bruce. 1991. University of California – Berkeley. January 27 Issue.

¹⁶Smith, Gary. 1992. Colorado State University. February 16 Issue.

¹⁷Webster’s New Explorer Dictionary. 1999. Merriam-Webster Inc., Springfield MA.

¹⁸FDA-USDHHS. 2024. usfda@public.govdelivery.com. Accessed on 4/26/2024.

¹⁹Smith. Gary. 2016. FSNS: HACCP Class. September 26 Issue.

²⁰EPA. 2024. http:www.epa.gov/safepestcontrol. Accessed on 6/23/2024.

²¹FDA. 2024. http:www.fda.gov/Food/Chemicals-Metals-Pesticides/Food/Pesticides. Accessed on 6/23/2024.

²²Schuenemann, Gustavo. 2021. Ohio State University. August 26 Issue.

²³Erpeling, Dennis. 2018. FSNS Newsletter. December Edition.

²⁴FDA-USDHHS. 2024. usfda@public.govdelivery.com. Accessed on 4/15/2024.

²⁵Johnston, Tom. 2019. Meatingplace. December 16 Issue.

²⁶FDA-USDHHS. 2024. usfda@public.govdelivery.com. Accessed on 7/8/2024.

²⁷FDA. 1980. Action Levels For Deleterious Substances In Human Food And Animal Feed. First Edition.

²⁸FDA-USDHHS. 2024. usfda@public.govdelivery.com. Accessed on 5/17/2024.

²⁹Parker, Laura. 2023. National Geographic. May 13 Issue.

³⁰Tilley, Caitlin. 2024 Dailymail.com. April 26 Issue.

³¹Smith. Gary. 2018. FSNS: HACCP Compared to PCHF Class. March Edition.

³²Heter, Katia. 2024. CNN. May 11 Issue.

³³Safe Quality Foods. 2014. SQF Code Edition 7.2.

³⁴British Retail Consortium. 2015. Global Standard For Food Safety. Issue 7.

³⁵FDA-USDHHS. 2024. usfda@public.govdelivery.com. Accessed on 4/3/2024.

³⁶JBS-USA. 2011. Producer Affidavit. September 30 Issue.

³⁷JBS-USA. 2017. Antimicrobial Drug Testing Protocol. August 17 Issue.

³⁸FSIS-USDA. 2023. USDA National Residue Sampling Report. October Edition.

³⁹FSIS-USDA. 2024. usfsis@public.govdelivery.com. Accessed on 2/13/2024.

⁴⁰FSIS-USDA. 2024. fsis.usda.gov. Accessed on 6/6/2024.

⁴¹FSIS-USDA. 2024. usfsis@public.govdelivery.com. Accessed on 2/1/2024.

⁴²AMS-USDA. 2024. ams.usda.gov. Accessed on 1/30/2024.

⁴³AMS-USDA. 2024. Food Safety Magazine. February 6 Issue.

⁴⁴FSIS-USDA. 2020. usfsis@public.govdelivery.com. Accessed on 11/17/2020.

⁴⁵FSIS-USDA. 2024. usfsis@public.govdelivery.com. Accessed on 1/26/2024.

⁴⁶FDA-USDHHS. 2023. Center For Food Safety & Applied Nutrition. Accessed on 12/8/2023.

⁴⁷FDA-USDHHS. 2024. usfda@public.govdelivery.com. Accessed on 4/21/2024.

⁴⁸FDA-USDHHS. 2015. http://1.usa.gov/1DkerVl. Accessed on 4/20/2015.

⁴⁹FDA-UDSHHS. 2015. http://1.usa.gov/1Cgi8ts. Accessed on 4/20/2015.

⁵⁰Schulz, Claudia. 2012. Food Quality. March Edition.