On March 4, 2010, the United States Food and Drug Administration (FDA) announced a recall of hydrolyzed vegetable protein (HVP) that contained Salmonella tennessee, an organism that “can cause serious and sometimes fatal infections in young children, frail or elderly people, or others with weakened immune systems.”1 The HVP in question was produced by Basic Food Flavors, Inc., located in Las Vegas, Nevada. That evening, Brian Williams of NBC News stated on his national newscast that HVP “is potentially in thousands of food products.” The manufacturer has now recalled the affected HVP. More than one hundred fifty processed foods that contained the affected HVP were recalled by April 3, 2010.2
As reported on March 10, 2010 in The Washington Post, managers at Basic Food Flavors, Inc. learned on January 21, 2010 that samples taken a week earlier at their plant tested positive for salmonella. However, based on FDA inspection records, Basic Food Flavors, Inc. continued to ship their product to processed food producers.3
There were several surprises for this writer in the FDA recall notice. The FDA, for the first time in my memory, stated that hydrolyzed protein was “a common [food] ingredient used most frequently as a flavor enhancer.” Previously, many members of the food industry denied the fact that HVP is used to enhance flavor.
Furthermore, the FDA reverted to the ingredient name of “hydrolyzed vegetable protein,” even though the FDA, in recent years, issued a requirement that the protein source that had been hydrolyzed had to be identified, for example, hydrolyzed soy protein or hydrolyzed pea protein. Also, the FDA disclosed that hydrolyzed proteins were contained in bouillon products, dressing and dressing mix products, flavoring base and seasoning products, frozen food products, gravy mix products, prepared salad products, ready-to-eat meal products, sauce and marinade mix products, snack and snack mix products, soup/soup mix and dip/dip products, spread products, and stuffing products. In total, the FDA listed one hundred seventy-seven products, but you can be assured that the number is understated.4
The FDA recall announcement did not mention the fact that all hydrolyzed proteins are flavor enhancers because they contain the reactive component of the food ingredient “monosodium glutamate.” They are referred to by many MSG-sensitive people as “processed free glutamic acid (MSG)” because they will cause the same reactions as those caused by monosodium glutamate, providing that the sensitive individual ingests an amount that includes a level of MSG that exceeds his or her individual tolerance for MSG. The amount of MSG in a hydrolyzed protein is dependent upon the type of protein being used and the extent of the hydrolysis.
Most, if not all hydrolyzed proteins we see on food labels are hydrolyzed through the use of an acid. The process breaks down the protein into individual amino acids, including glutamic acid in the form that can cause adverse reactions in MSG-sensitive people.5 Acid hydrolysis also results in the unwanted formation of carcinogenic mono- and di-chloropropanols.6,7
Why has the FDA allowed a carcinogenic substance to be so broadly used in our food supply? Did the FDA not know that acid-hydrolyzed proteins introduce carcinogens into our food?
The fact is that this writer, representing the Truth in Labeling Campaign (www.truthinlabeling. org), verbally advised the FDA in 1993 that acid-hydrolyzed proteins introduced carcinogenic propanols into processed foods. The FDA made light of our claim. However, it was reported in an industry newsletter that in 1994 the FDA met with representatives of the flavor industry and expressed their concern about the presence of carcinogens in acid-hydrolyzed proteins. Reports revealed that the FDA raised the point that if enzymes were used rather than acid (a method that is technically referred to as enzymolysis) there would be no carcinogenic propanols produced.
Industry representatives expressed concern about using enzymolysis on the basis that the method was less efficient and more costly than acid hydrolysis. Another report indicates that FDA asked the flavor industry to reduce the presence of carcinogens in HVP, but a later survey by the International Hydrolyzed Protein Council (IHPC) indicated that nothing had been done to correct the problem.
The above reports were supported later, when the FDA stated in a 2003 report of the Codex Alimentarius Commission that the FDA met with the IHPC in the “early 1990s . . . regarding the need to control levels of 3-MCPD and 1,3-DCP in acid-HVP [chloropropanols].” The IHPC conducted annual surveys on the levels of carcinogenic 3-MCPD in acid HVPs and shared their results with the FDA.8 (The Codex Alimentarius Commission was created in 1963 by the Food and Agriculture Organization of the United Nations (FAO) and the World Health Organization (WHO) to develop food standards, guidelines and related texts such as codes of practice under the Joint FAO/WHO Food Standards Program.)
In the above referred to Codex Alimentarius Commission report, the FDA also reported that it conducted a formal quantitative risk assessment of 3-MCPD in 2000 and concluded that 3-MCPD was carcinogenic and genotoxic (damaging to DNA).9 (There is some disagreement regarding the genotoxicity of 3-MCPD.)
On March 31, 2008, the FDA did publish an article in the Federal Register announcing the availability of Compliance Policy Guide #500.500, which sets “guidance levels” for 3-MCPD in acid-hydrolyzed proteins and Asian style sauces. However, a guidance level is not binding on the FDA or on industry, and cannot serve as the direct legal basis for an enforcement action. A similar article appeared in the Federal Register in 2007.10
The Codex Alimentarius Commission stated, “Chloropropanol contamination is a food safety issue that has international implications and a number of countries have introduced maximum levels for chloropropanols.” Beginning in 2001, the United Kingdom food regulatory agency began to remove certain products from grocers’ shelves due to what they believed to be excessive levels of carcinogens. The cause was found to be the presence of propanols due to acid HVPs. Thailand has established a limit of 3-MCPD in seasoning products, and, during 2001, Australia and New Zealand introduced emergency measures to establish maximum levels of chloropropanols. Other countries, like the United States are studying the problem.11
If the food industry was not so interested in adding MSG to our processed foods in order to enhance flavor without going to the expense of using high quality, healthful ingredients, the HVP issue would not be the problem it is. In the opinion of this writer, the HVP issue is an example of how our regulatory agencies fail to fulfill their responsibility to protect the health of citizens with healthy food, a responsibility that has become increasingly important with a national healthcare program.
If we are to reduce health care costs, we must reduce the growing incidence of numerous, serious medical conditions in our country. This will require navigating a new direction at such federal agencies as the FDA, the USDA, and the EPA, to better protect the safety of consumers. The FDA might start by protecting the 25 to 43 percent of our population that experienced adverse reactions to monosodium glutamate in studies conducted in the 1970s.12,13,14 This could be easily accomplished by requiring that all existing processed foods, dietary supplements, and pharmaceuticals be analyzed for “free glutamic acid.” Subsequently, when a new product is introduced or a formulation is changed, the product must be analyzed for “free glutamic acid.” If “free glutamic acid” is present in a product, it must be disclosed as “MSG,” with the amount stated in milligrams on the labels of processed foods and dietary supplements, and on the product inserts of pharmaceuticals.15
REDUCED SALT , MORE CHEMICALS
Recently, a number of food companies have announced that they will be reducing the salt content of their products by
20 percent. This includes many food giants, such as Kraft Foods and Nestlé. We now have a similar announcement from
Frito-Lay regarding their salted potato chips. Meanwhile, the FDA appears to support the reduction of salt in processed
foods, but has not issued any regulations on the subject.
According to the Frito-Lay announcement, the reduction in salt content will be achieved by changing the shape of salt
crystals, affecting how they will be used in the body. The change in shape of salt crystals would not appear to be detrimental
to humans, but, of course, we do not know the process that will be used nor do we know whether any chemicals
will be used.
Of real concern is the fact that the announcement about salt reduction just happens to have occurred shortly after
a new salt substitute, Senomyx, entered the marketplace. The Senomyx salt substitute is clearly a chemical product that
works in the body as a neurological agent, causing an individual to perceive a salty taste. It would seem to be nothing
more or less than a neurotrophic drug.
Because the maker of the Senomyx product calls it a food, it does not require the extensive testing that would be
required by the FDA if it were called a pharmaceutical. To our knowledge, there has been no testing of the Senomyx salt
substitute for safety, and it is so potent that the amount needed in food is below the amount requiring FDA approval.
Furthermore, it will never be disclosed on food labels as Senomyx. Senomyx can be used in or called “artificial flavor.”
1. FDA News Release dated March 2010: http:/www.fda.gov/newsevents/newsroom/pressannouncememts/ucm203067.htm.
2. Report of Frost & Sullivan, a global consulting and research firm, dated April 3, 2010: http://www.frost.com/prod/servlet/market-insight-top.pag?docid=197382526.
3. Report of Frost & Sullivan, a global consulting and research firm, dated April 3, 2010: http://www.frost.com/prod/servlet/market-insight-top.pag?docid=197382526.
4. April 1, 2010, FDA notice of products containing HVP: http://www.accessdata.fda.gov/scripts/hvpcp.
6. Truth in Labeling Campaign: www.truthinlabeling.org/manufac.html.
7. Pommer, K. (Novo Nordisk BioChem Inc., Franklinton, NC) Cereal Foods World. October, 1995 Vol 40. No 10. p.745.
8. Codex Alimentarius Commission Position Paper on Chloropropanols, March, 2003. Based on Thirty-fifth Session held in Arusha, United Republic of Tanzania, March 17-21, 2003, Item #25.
9. Ibid. Item #20.
10. FDA Issues Compliance Policy Guide Setting “Guidance Level” for a Chloropropanol in Asian-Style Sauces. http://www.fdalawblog.net/fda_law_blog_hyman_ phelps/2008/04/fda-issues-cpg.html.
11. Codex Alimentarius Commission Position Paper on Chloropropanols, March, 2003. Based on Thirty-fifth Session held in Arusha, United Republic of Tanzania, March 17-21, 2003, Items #9-17.
12. Kenney, R.A. and Tidball, C.S. Human susceptibility to oral monosodium L-glutamate. Am J Clin Nutr 25: 140-146, 1972.
13. Reif-Lehrer, L. A questionnaire study of the prevalence of Chinese restaurant syndrome. Fed Proc 36:1617-1623, 1977.
14. Kerr, G.R., Wu-Lee, M., El-Lozy, M., McGandy, R., and Stare, F. Food-symptomatology questionnaires: risks of demand-bias questions and population-biased surveys. Glutamic Acid: Advances in Biochemistry and Physiology Filer, L. J., et al., Eds. New York: Raven Press, 1979.
15. See www.truthinlabeling.org/action.html.
This article appeared in Wise Traditions in Food, Farming and the Healing Arts, the quarterly magazine of the Weston A. Price Foundation, Summer 2010.