Janet McKenzie
Food Labelling and Marketing Terms Branch
Labelling, Standards and Allergy Division
Food Standards Agency
Room 115B, Aviation House
125 Kingsway
London WC2B 6NH

Dear Ms McKenzie,

I write first as a consumer and former farm manager whose family members are involved in catering and in food retail businesses with interests in the correct labelling of food.
Many of the issues raised in these comments have already been reported to the Food Standards Agency and other government bodies but the seriousness of the situation appears to have been overlooked.

The problem with food labels appears to be ever more complex and I am not at all sure that consumers have the time to read through the mass of information and quality standard logos. I know that my wife has considerable difficulty trying to compare products in attempts to control her diabetes and to avoid those additives that we know should be avoided. Some, like aspartame, have been reported to be linked to serious adverse health effects but are often hidden in the ingredients list and disguised as e-numbers.
It is my considered view that the FSA should be ensuring that harmful products are NOT permitted in our food, or that intended for our children, rather than its current plan of insisting that the inclusion of such products are reported on the labels. It is wrong to rely on the consumers, who may not be aware of the science or the risks, to make such decisions when they are effectively “blindfolded” to the dangers.

We have recently seen that scientists, who are aware of the potential long-term harm that may result in those who consume too much, have condemned suggestions that folic acid be added to flour.
There have also been FSA campaigns about salt levels and confusing advice to consumers by scientists who have then stated that the risk from excess salt intake has been exaggerated.
Fat content must be declared on food and sugar too for obvious health reasons.
Perhaps the most important change in recent decades has been the requirement to declare the presence or possibility of contamination with nuts or nut oils in attempts to protect vulnerable individuals from potentially lethal adverse reactions.

My concern then is once again in regard to the determination by the authorities in their refusal to even consider the request that all insecticide additions to food should be declared on the labels in order to protect those of us who have already been poisoned by the accumulation of the exposure to the toxins and their effects. Such individuals also have to avoid the additional ingestion of the toxins wherever possible and yet pesticides appear to escape the regulations regarding the adulteration of food with dangerous chemicals simply because they are pesticides.
This attitude is not only irresponsible but it is also illogical and is based on the false assumption that all the data supplied by the manufacturer is accurate and reliable. As reported to the authorities this is most certainly not the case and in my research I have discovered that not only do the authorities not ensure that the data supplied is independently verified but also much of the information is wildly inaccurate.
It is of interest to note that the EU has had to order the withdrawal of numerous classes of pesticide for this very reason and even the much-maligned China has recently seen fit to ban several organophosphorus chemicals when the danger was realised. Even in the USA as long ago as 1997 scientists called for an immediate ban on all OP compounds because of the serious danger to children presented by the residues of pesticides used in the field. (See “Overexposed – organophosphate insecticides in children’s food”)
My concern is not so much in regard to those residues,
although they are obviously important, but of the greater risk presented by the chemicals that are admixed with food after it leaves the field. The approved methods of application used simply cannot be relied upon to prevent serious
over-application but there are greater risks than over-dose. The very basis of the calculations that permit this adulteration is entirely reliant on the claim that the chemicals do not persist either in the environment or the body but there is ample evidence that neither assumption is based on the reality of the actual formulations and mixtures used or created by that use. Sadly, even when scientific analysis proving that the accepted data is flawed has been presented to the authorities no attempt has been made to check that data for accuracy.
As a result the approvals continue and the risk to human health remains.
One such approval concerns the recent one of a mixture of malathion and bifenthrin which was cleared for use as an insecticide admixed with grain. This approval was made despite considerable concern about the adverse health effects known to be triggered by malathion and the unpredictable nature of combined exposures. Perhaps unsurprisingly within a very short time the EU withdrew all pesticides containing malathion on safety grounds and this alone must put serious doubt over the claims that our health is protected by the regulatory process.

There are similar problems with produce from or created by genetic modification and it is a complete disgrace that our food supply has been allowed to be contaminated when assurances were made by the industry that this would never happen. The polluter pays is the mantra of government and so the industry should be forced not only to remove the contamination but also to pay for the clean up and compensate all those who had had to cover the costs of testing and labelling conditions. Perhaps it is no surprise that the industry has fought so hard to persuade the regulators to allow them to escape enforced declaration on the food labels.

Too much of this cost is being borne not by the polluters but by the innocent retailers and consumers who have demonstrated countless times that they oppose the introduction of genetically modified crops but this assault on the consumer’s rights is mad worse by the failure to ensure that all products that have resulted from these processes are declared on the labels.
Once again it is left to the consumer to take active steps to avoid the produce when it should be the responsibility of the authorities to enable the consumer to easily avoid unwanted contaminants that may well prove to have adverse effects at some point in the future. It is not known at this point if consuming modified products may trigger delayed adverse health effects and, since the BSE debacle, the Food Standards Agency was established to ensure that consumers are not put at risk.

Prevention is better and far cheaper than what are usually only partial “cures” when biological, metabolic and chemical toxins and imbalances are involved and so it is very difficult to understand the reluctance of the Food Standards Agency to either warn of the obvious dangers or to take action to protect consumers.
It seems that no expense or time is spared to flag up the potential risks posed by natural substances with which the human race has survived for thousands of years and yet there is an equally determined reluctance to even consider the possibility of harm from man-made products which have been available only for a few decades, or even less in some instances.
Full labelling might help the consumer but the easiest, most efficient, and safest way to deal with hazards is to tackle them at source. Reliance on labels is simply an escape mechanism designed to avoid having to take difficult decisions. It is akin to blaming a child for failing to read the warnings about a loose dangerous dog. By then it is too late.
The risk posed by labelling is similar in that labels are all but useless to the blind or to those who cannot understand them – as was seen in the first Gulf War when those using pesticides were unable to understand the language used on the label instructions.

As with pesticides consumers assume that what they are able to buy is not going to present a risk to their health but the Food Standards Agency’s own campaigns highlight dangers to health in foods that have always been assumed to be completely safe and part of the normal and accepted diet.
It is doubtful that most consumers would bother to spend the time to read labels unless they have a health problem and have been told to avoid certain foods or additives.
Those of us who are aware of the adverse health effects that can be triggered by certain contaminants or items of food need to know for certain what the food we purchase contains and that is why it is so important that all contaminants, especially deliberately added insecticides and other known toxins, even when their toxicity is being disputed, must be declared on the labels.
It is of interest to note that the permitted residue levels for systemic phosphoric acids such as glyphosate were raised considerably in order to allow produce from GM crops to be imported and yet there is a growing concern about the potential for these chemicals to induce health problems such as cancer.

Sadly vested interests have managed so far to suppress the truth about the dangers of the organophosphorus group of chemicals but eventually the truth will escape their clutches. As Christopher Booker and Richard North reported in their book “Scared to Death”, “the government and its industry allies managed to suppress the evidence of how just one type of chemical was damaging the health of untold numbers of people. The regulatory system, supposedly designed to protect the public against these dangers was so corrupted that it did the very reverse”

That problem was supposed to have been addressed following the BSE Inquiry but it is clear that the same attitudes and failures continue to this day.
Perhaps the explanation for this sorry state of affairs is to be found in the quote from Upton Sinclair from the book “The Secret History of the War on Cancer” which seems to sum up the situation rather well.
“It is difficult to get a man to understand something, if his salary depends on his not understanding it”.

However, on the subject of the failure to declare the presence of organophosphates on food labels it is not simply a question of “understanding” but far more important is the issue of the responsibility to protect the health of the nation. At least one of the undeclared chemicals has been admitted to mutate bacteria and yet, despite the risks, it remains approved as an undeclared additive in food. Furthermore it is a proven nerve toxin that has cumulative and irreversible effects and is the only organophosphorus chemical proven in an English court of law to cause serious adverse health effects. There have been many other cases, which through deception were not heard by the courts.

There is a requirement to protect the vulnerable in our society and, just as with nut allergy as previously mentioned, those poisoned by organophosphates and who are then vulnerable to additional exposures must be given the right to know when they are consuming potentially harmful chemicals.

I urge the Food Standards Agency to take steps to ensure that all these toxins, whether present as residues or through the deliberate incorporation of chemicals, are declared on the food labels.

Yours sincerely,

Dated 01/02/2005    Updated 20/02/2016

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