No Artificial Colors, Please

As a child, I had not heard of the Food and Drug Administration (FDA), and if there was an Indian equivalent, I wasn’t aware of it. For me, the Indian FDA was synthesized into one person—my mother.

My mother, who had graduated from high school at a time when many women did not study beyond elementary school, worked at the General Post Office in Bombay during World War II. Throughout my childhood, she took exams for her B.A. degree, and knew by instinct many things that the FDA has proven only after decades of scientific research and analysis.

“Don’t eat Dalda,” the Indian equivalent of margarine, she would warn, “because any fat that is solid at room temperature will stick inside your body.” It turned out that she was right. The FDA concluded so only about a year or two ago. The transfats in margarine and other butter substitutes apparently do stick in your arteries and eventually cause heart disease.

“Don’t eat any preservatives or chemicals,” was my mother’s motto. She was suspicious of any store-bought prepared foods like chikki (peanut and molasses candy), or ice cream, or even yogurt.

So it was that I never actually used food coloring in cooking until I came to the United States. At home in India, even though we were rather poor, sweets were always prepared with saffron, or not colored at all. But in America, I threw all caution to the wind. In a society that thrives on orange cookies for Halloween, green cupcakes for Saint Patrick’s Day, and red candy for Valentine’s, who could avoid food coloring?

The Indian restaurants in America too, served much more opulent North Indian foods than I had ever been privileged to eat back home: bright orange tandoori chicken, biryani, colorful desserts. At first, the consumption of tandoori chicken was only restricted to occasional restaurant outings; after all, tandoori wasn’t my favorite Indian dish; what I really craved for were South Indian dishes like masala dosa, idli sambar, and dahi vada.

But then I had children. And it turned out that like most kids, my sons didn’t care much for vegetable preparations like stuffed eggplant or bitter gourd cooked with tamarind or even cauliflower and potatoes. Their favorite Indian meal became tandoori chicken with naan.

As my boys grew up, feeding them on restaurant-bought tandoori chicken became an expensive proposition. So I pulled out my cherished copy of the Madhur Jaffrey cookbook, An Invitation to Indian Cooking, and imitated the recipe for tandoori chicken. The results were astounding. So much so, that my children could hardly distinguish between my homemade version and the restaurant one.

The crucial ingredient in that recipe, alas, was the bright orange food coloring, which I began to purchase from Safeway or other grocery stores.

In fact, once, when I ran out of food coloring and prepared the chicken without the bright hues, my children refused to eat it, swearing that it wasn’t the same, even though I assured them that the color didn’t affect its taste, only its appearance. But my children, raised in California, had imbibed the notion that food not only had to taste good but also had to look attractive. So, I, who had read umpteen books on the effects of chemicals on children’s health with respect to allergies, asthmatic reactions, hyperactivity, attention disorders, and other neurological problems, threw caution to the wind.

Recently, I went a step further. While shopping at Vik’s Grocery Store in Berkeley for regular staples like garam masala, tea, and cashew nuts, I suddenly remembered that I was out of the orange color we now can’t live without. So I asked the lady at the counter for one, and she led me to a shelf with many selections. I would have grabbed just the orange bottle, but my son also wanted to try a blue one for variety. So, that evening, we ended up with tandoori chicken painted in stripes of orange and blue with an occasional blackish green where the blue had run into the orange.

I had long dismissed my mother’s edicts regarding artificial ingredients as sheer paranoia, in any case. After all, the FDA had approved these products, right? And the FDA knew more than my mother, right?

Wrong.

It turns out that my mother’s instincts were more accurate than that of the FDA.

It was when I ate the slightly unappetizing blue chicken that a warning bell rang inside my head. Could something that looked as bright as ink and as unlike any natural food as this color looked, be safe, I wondered. I couldn’t rest. I tossed the bottle into the garbage and pulled it out again. It wasn’t just the blue color that was the problem. The orange color, upon opening the little plastic jar with the push-down lid, I had discovered, was not in a liquid form, but a bright powder. It just didn’t look right.

So I did some research.

I was disappointed to find that the last time the FDA put out any sort of information about food colors was over a decade ago, in 1993. I looked at various websites. Most were funded by the food manufacturers and aimed to assure consumers that everything was safe.

Here is what I discovered in my research.
Color additives have been such an intrinsic part of human culture that archaeologists date cosmetic colors as far back as 5,000 B.C.

In the United States, the regulation of colors goes back to the year 1960, when, amendments to the Food, Drug, and Cosmetic Act of 1938 added the Delaney anti-cancer clause to the FDA’s legal mandate. Among other things, the clause prohibited marketing any color additive the agency found to cause cancer in animals or humans, regardless of amount.

Today, the FDA separates color additives used in food, medicine, and cosmetics into two categories: the ones that the agency certifies and the others that are exempted from certification because they are extracted from natural sources such as minerals, plants, or animals. The certifiable colors, on the other hand, are generally made from coal-tar and petroleum sources.

Certifiable color additives are available for use in food as either “dyes” or “lakes.” Dyes dissolve in water and are manufactured as powders, granules, liquids, or other special-purpose forms. They can be used in beverages, dry mixes, baked goods, confections, dairy products, pet foods, and a variety of other products.

Lakes are the water-insoluble form of the dye. Lakes are more stable than dyes and are ideal for coloring products containing fats and oils or items lacking sufficient moisture to dissolve dyes. Typical uses include coated tablets, cake, and donut mixes, hard candies, and chewing gums.

To market a new color additive, a manufacturer has to petition the FDA for approval. The petitioner has to provide convincing evidence such as animal studies using large doses of the color for long periods. Human studies for a color are also allowed to be submitted.

The FDA requires domestic and foreign manufacturers of certain colors to submit samples from each batch of color produced. FDA scientists test each sample of color to confirm that it is within established specifications. These certified colors are listed on labels as FD&C;, D&C;, or external D&C.; The letters F, D, and C stand for food, drugs, and cosmetics. Using uncertified versions of color additives for food, drugs, cosmetics, and medical devices that require certification is illegal.

Also, each color has its own chemical specifications that place restrictions on the level of impurities allowed in the additive. In some cases, these limitations are designed to ensure that the color contains no cancer-causing substances. Using chromatography and other sophisticated techniques, FDA scientists probe sample compositions to confirm that each batch is within these limitations. The scientists have to test every batch of color manufactured because every batch is a little different from the one before it and because complex organic chemical reactions during manufacturing can change the composition of the color. If a batch does not pass the FDA test, the entire lot is rejected and has to be discarded.

The FDA rejects about 10 percent of colors submitted to it for approval.

The FDA allegedly considers the composition and properties of the substance, the amount likely to be consumed, its probable long-term effects and various safety factors. Absolute safety of any substance can never be proven, the FDA says. Therefore, the FDA decides if there is a “reasonable certainty” that no harm will result from the color under its proposed conditions of use.

If the agency approves the color, it issues regulations that may include the type of foods in which it can be used, the maximum amounts to be used and how it should be identified on food labels. Colors that are used in meat and poultry have to receive approval from the United States Department of Agriculture (USDA).

The FDA also allegedly monitors the extent of Americans’ consumption of the new color additive and results of any new research on its safety. But it is not quite clear how the FDA is able to do it without extensive statistical and market research.

The agency claims to operate an Adverse Reaction Monitoring System (ARMS) to help serve as an ongoing safety check on all activities. The system monitors and investigates all complaints by individuals or their physicians that are believed to be related to food and color additives, specific foods, or vitamin and mineral supplements. The ARMS computerized database helps officials decide whether reported adverse reactions represent a real public health hazard, so that appropriate action can be taken.

The problem is that most consumers are not aware of the ARMS system, nor do they visit the FDA website (www.fda.gov) regularly.

Besides, most consumers don’t know the distinction between “certifiable” and “certified” colors. Just because a food product labels as ingredient a color that is “certifiable” does not mean that it is safe. “Certifiable” simply means that it is made from artificial ingredients and therefore must be tested before use. Only “certified” colors, on the other hand, are approved by the FDA.

The other problem is that the FDA continually changes its mind.

The biggest evidence that the FDA is continually changing its mind came in the 1970s, when Russian studies raised questions about the safety of Red Dye No. 2. Bowing to public pressure, the FDA evaluated biological data and concluded that feeding FD&C; Red No. 2 at high dosages results in a statistically significant increase in malignant tumors in female rats. Just to be cautious, the FDA banned the color.
The Red Dye No. 2 ban had a profound effect on consumer attitudes in America. Food retailers removed red products from their shelves for fear of backlash.

Consumers felt safe, at least for a while, until the Red Dye No. 3 scare came about. In 1990, the FDA applied the Delaney clause again to outlaw several uses of the strawberry-toned FD&C; Red Dye No. 3. The banned uses included cosmetics and externally applied drugs, as well as uses of the color’s no-water-soluble lake. The FDA only did so after research showed that large amounts of the color cause thyroid tumors in male rats.

But there was pressure from manufacturers to continue using the color because it is hard to imitate with natural ingredients. So the FDA did not completely ban Red Dye No. 3, but allowed its use in certain foods, as a dye.

And the fact is that all the time, the color has been available in Canada and Europe, which means it is probably present in all sorts of imported foods.

When I checked the ingredients listed on the container of imported tandoori orange color I had purchased from Vik’s, I found a substance called Carmoisine listed on the bottle. A web search informed me that this color was definitely not allowed as a food ingredient in America. So how did it get imported from India into the United States and onto the shelf of my favorite Indian grocery store?

It turns out that when it comes to imported food products, the picture becomes much more confusing. The FDA website declares that imported food products must comply with all provisions of the Federal Food Drug & Cosmetic Act. The import program allegedly collects samples of imported foods and examines imported foods for unsafe additives. Also, the FDA requires labeling of all “certifiable” food additives.

So how was it that an illegal color made its way onto the shelves here?

Probably because there are many exceptions to the FDA’s rules and also because the FDA’s monitoring system is based on voluntary compliance and random checks rather than mandatory enforcement. The FDA will test samples of imported colors if they are submitted. But many importers do not submit such samples and shiploads of imports nevertheless make it into the United States without proper scrutiny.

Besides, if a dye or a lake is used in food ingredients, the FDA has no way of ensuring that it is safe because it has no way to study the color except in random testing done only on a certain percent of the imported foods.

The other color I had purchased from Vik’s listed Brilliant Blue as an ingredient.

Some research revealed that the history of Brilliant Blue, which is also known as FD&C; Blue No. 1, is as checkered as that of Red Dye No. 3. Because colors like Brilliant Blue, Red Dye No. 3, and Yellow No. 5 were permanently listed for use in ingested drugs and foods in 1969, it turns out that it is hard to ban them now. So the FDA continues to allow their use in foods, although the FDA website itself warns in bold headings, “Yellow Means Caution.” It turns out that Yellow No. 5 can cause severe allergies and many health websites list Brilliant Blue, the ingredient listed on my bottle of blue, as a trigger for hyperactivity in children.

I did a web search of import alerts on the FDA website and discovered several related to food products containing “uncertified” Brilliant Blue, Yellow No. 5, as well as Carmoisine. The reason these were listed was because Carmoisine is banned in the United States, while the particular batches of Brilliant Blue or Yellow No.5 had not been approved by the FDA.

All this made me so furious that I threw the blue and orange colors from my cupboard into the garbage again, only to retrieve them again, for safekeeping as proof that the food certification system has broken down in this country.
But the next time I went to Berkeley Bowl, I purchased a vial of
saffron. And the next time I cooked tandoori chicken, I gave my children a long lecture as to why the pale orange color of natural saffron was preferable to the bright orange of artificial colors. And I thanked my mother silently for always knowing better.

Sarita Sarvate writes commentaries for Pacific News Service and KQED.



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