Butylated hydroxytoluene (BHT) Butylated hydroxytoluene (BHT) is a chemical cousin to BHA that is also listed as “generally recognized as safe.” It, too, is added to food as a preservative. The two compounds act syner- gistically and are often used together. BHT is not a listed carcinogen, but some data have shown that it does cause cancer in animals. Rats fed BHT have developed lung and liver tumors (EFSA 2012). BHT has also been shown to cause developmental effects and thyroid changes in animals, suggesting that it may be able to disrupt endocrine signaling (EFSA 2012). A neurobehavioral study of rats exposed to BHT throughout development described effects on motor skills and coordination before the animals were weaned (Vorhees 1981b).

What you should do Read labels and avoid products with BHT, particularly those that also contain BHA.

Propyl gallate Propyl gallate is used as a preservative in products that contain edible fats, such as sausage and lard. It is classified as GRAS even though a National Toxicology Program study reported an asso- ciation with tumors in male rats and rare brain tumors in two female rats (NTP 1982). These findings do not establish a causal link between propyl gallate and cancer, but they raise important questions about whether this chemical should be considered safe. A 2014 opinion by the European Food Safety Authority concluded that the available reproductive studies on propyl gal- late are outdated and poorly described. In addition, there is in- complete data on whether propyl gallate is an endocrine disrup- tor; some evidence suggests it may have estrogenic activity (EFSA

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2014; Amadasi 2009; ter Veld 2006).

What you should do Be cautious. Check labels for propyl gallate and consider

avoiding it. Use EWG’s Food Scores to find foods without propyl gallate.

Theobromine In 2010, Theocorp Holding Co. requested that the FDA list theobromine, an alkaloid found in chocolate that has effects similar to caffeine, as “generally recognized as safe” for use in a variety of foods, including bread, cereal and sport drinks. FDA scientists questioned the GRAS designation, noting that the esti- mated average human consumption rate was five times higher than the level the company reported as safe (NRDC FOIA 2013). They also said that the company had not adequately explained why the reproductive and developmental effects seen in animals exposed to theobromine were not a concern. In response, Theo- corp withdrew its request to FDA, but theobromine was later declared GRAS and is being used in food outside FDA oversight (NRDC 2014). Theobromine is just one example of an enormous loophole

in the FDA’s voluntary GRAS notification process. The food ad- ditive industry is allowed to designate a substance as GRAS without even notifying the agency, relying instead on “expert panels.” Theocorp’s submission triggered important questions from FDA scientists about the additive’s safety. Instead of address- ing them, the company withdrew the request, and the GRAS designation was made later without FDA approval. In some cases, companies forego FDA’s notification process altogether. The agency does not know the identity of these secretly GRAS- approved chemicals and cannot review data to determine whether they are truly safe in food (NRDC 2014). This must change. In order for additives to be Generally

Recognized as Safe, FDA must have access to safety information and assert jurisdiction over the approval of all GRAS-listed ad- ditives.

What you should do Tell the FDA that the GRAS approval process must be re-

formed. Companies should not be allowed to secretly approve food additives as GRAS without notifying or sharing safety data with the FDA.

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Secret Flavor Ingredients The term “natural flavor” finds its way into more than a quarter of EWG’s roster of 80,000 foods in the Food Scores da- tabase, with only salt, water and sugar mentioned more fre- quently on food labels. “Artificial flavors” are also very common food additives, appearing on one of every seven labels. What do these terms really mean? Good question. The truth is that when you see the word “flavor” on a food

label, you have almost no clue what chemicals may have been added to the food under the umbrella of this vague term. For people who have uncommon food allergies or are on restricted diets, this can be a serious concern. In addition to the flavor-adding chemicals themselves, flavor

mixtures often contain natural or artificial emulsifiers, solvents and preservatives that are called “incidental additives,” which means the manufacturer does not have to disclose their presence

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