The Natural Solutions Foundation submitted comments to the United States Codex Office and the the FDA prior to the April 10, 2007 public meeting on US policy pertaining to the 2007 Codex Committee on Food Labeling (CCFL). One of the important items on the CCFL agenda is the Draft revised Guideline for organic food standards.
These same comments have been presented to health friendly (and potentially health friendly) nations attending Codex as well as to the US. Documents like these do double duty: we have been told that they have been influential in shaping national positions both inside Codex and at home. The Natural Solutions Foundation comment document on Fluoride, for example, was not only very helpful to a number of countries in allowing them to take a stand directly opposite to that of the US during the 2006 Codex Committee on Nutrition and Foods for Special Dietary Uses (CCNFSDU) and bring about a ban on its use in formula for normal babies, but the information in that document was strong enough to spark national debate on a ban on fluoride in a number of countries following the meeting in Chiang Mai (Thailand).
During the first day of the CCFL Working Group meetings (April 28, 2007) prior to the meeting itself (April 30-May4, 2007) here in Ottawa several countries thanked us for our comments and stated that they were helpful to them in focusing their policy. This included some small countries new to the Codex process. The Working Group will meet today on this topic and its recommendations will be presented to the full CCFL during that committee’s meeting. Stay tuned to this blog for up to the minute information on Codex from inside one of its key meetings.
Yours in health and freedom,
Rima E. Laibow, MD
Medical Director
Natural Solutions Foundation
www.HealthFreedomUSA.org
NATURAL SOLUTIONS FOUNDATION
Major General Albert N. Stubblebine III, President
Rima E. Laibow, MD, Medical Director
April 8, 2007
Comments by the Natural Solutions Foundation on Codex Committee on Food Labeling Agenda Item 4(A) CX/FL 07/35/5, Guidelines for the Production, Processing, Labeling and Marketing of Organically Produced Foods DRAFT REVISED ANNEX 2: TABLE 3 (PART 1 & 2)
(CL 2006/49-FL & CL 2006/12-FL, ALINORM 06/29/22 – APPENDIX III) and all subsequent Agenda sub items referring to Labeling of organically produced foods
The Natural Solutions Foundation strongly opposes the addition of sodium or potassium nitrates or nitrites in any food produce by organic means and labeled as “organic food” or “organically produced food” and urges the United States to oppose its use domestically and internationally. Permitting nitrates and nitrites, well-known and universally recognized carcinogens and co-carcinogens, to be added to organic food destroys any meaning the phrase might have and betrays consumers who trust the concept conveyed by certification of foods as organic. Allowing the addition of universally acknowledged toxins to organic foods betrays the consumer and constitutes false and misleading information which the FDA is tasked with eliminating in the food supply, not fostering.
Furthermore, the human and economic costs of preventable cancers induced by the introduction of unnecessary toxins into food which consumers pay a high premium for because they believe that such food is free from precisely those types of toxins is unacceptable.
Nitrates and nitrites are synthetic compounds added to meats, especially processed meats like bacon and sausages, for two purposes. These compounds aid in the maintenance of an attractive red color in processed meats like bacon, ham, sausage and similar products. This attractive color is associated by consumers with freshness and wholesomeness so this additive prolongs effective shelf life. In the absence of this additive, processed meat turns grey long before it decomposes or spoils. Since consumers are more willing to buy red meat than meat which has turned gray, the additives are extremely popular with producers.
The second purpose for which they are used is to retard the germination of botulinum spores to prevent the occurrence of botulism. However botulinum spores germinate very slowly. Refrigeration, proper hygiene and, if desired, the use of salt in the curing process, retard the growth of botulinum spores much more successfully than nitrates/nitrites and do so without their significant health hazards. Foods prepared in this way could fairly be labeled as organic (provided they met the other requirements of such labeling) while foods with nitrates and nitrates in no way meets any meaningful definition of that term.
Canada and the US regulatory agencies have both demonstrated their awareness of the dangers presented by nitrates/nitrites: both have lowered permissible levels for use in foods. However, since even miniscule doses of nitrites can form potent carcinogenic nitrosamines, lowering permissible levels is not an effective health measure. This problem poses a severe health hazard because nitrosamines are so powerfully carcinogenic at tiny doses.
Organic foods are, by their nature, free of synthetic and chemical additives. Consumers expect that organic foods have no non-food, chemical preservative, artificial coloring agents or similar additives which are not produced spontaneously through the natural process of preparation. When consumers spend premium prices because they want to consume foods which have not been altered or adulterated by industrial food sourcing or processing techniques, they believe that they can eat organic food without the impact of additives, synthetic colors, preservatives, hormones or other non-food components. Nitrates and nitrites are well known to consumers as chemicals which carry significant risks when consumed either before additional cooking or after it.
Consumers are well aware that baby food manufacturers have voluntarily withdrawn nitrates/nitrites in baby food following the 1995 statement at the 44th meeting of FAO/WHO that “nitrite should not be used… in foods for infants below the age of three months.” According to FAO/WHO, babies are especially venerable to methemoglobin. In addition, fetal hemoglobin is more easily changed to methemoglobin so consumption of nitrite by pregnant women can reasonably be expected to pose a danger to the fetus. Nitrates impair the oxygen carrying capacity of hemoglobin, turning it into methemoglobin which cannot carry oxygen. Nitrite in large doses has been fatal for adults. Consumers who are particularly sensitive to this transition, who have profound anemia or suffer from other conditions which impair oxygen transport and seek to avoid nitrites expect that they are doing just that by purchasing organic sausages and preserved meats.
Several other serious and potentially lethal problems attend the use of nitrates/nitrites. Nitrates are associated with increased miscarriages, fetal deaths and birth defects in laboratory animals. Consumers are looking for food without added hazards when they purchase organic food and have the right to expect it.
Parents may spend the extra money for “safe” bacon and sausage for their children since babies and children are especially vulnerable because of their lower blood volume and greater susceptibility to the conversion of hemoglobin to methemoglobin.
Consumers sensitive to, or aware of the dangers of, nitrites may make significant efforts to avoid it only to find their efforts thwarted by a counterintuitive inclusion of dangerous synthetic additives in supposedly organic foods.
Numerous studies show that nitrite alone can cause cancer. However, an even more serious cause for concern is the well documented potential for nitrates/nitrites to cause cancer through the formation of nitrosamines, especially quaternary nitrosamines, formed when nitrites react with secondary amines. These secondary amines occur naturally in protein-containing foods such as the meat of the sausage or bacon to which they have been added.
Nitrosamines are among the most powerful carcinogens known. Numerous studies confirm the strong relationship between nitrate and nitrite intake and cancer including colorectal adeno carcinoma, prostate and breast, stomach cancers in humans. Animal studies make it clear that even minute amounts of certain nitrosamines can produce cancers.
Studies have found a correlation between nitrosamine-contaminated foods and childrens’ leukemia and brain cancer According to Dr. William Lijinsky, former director of the Chemical Carcinogenesis Program at the Frederik Carcinogenesis Center (Maryland) said in his US Senate testimony, “There is evidence to show that nitrites in meat are the most dangerous food additives today and that they are major contributors to cancer… producing cancer in 24 species of animals tested at the Frederick Cancer Research Centre.” Dr. Lijinsky, an internationally recognized expert in the biological impact of nitrates and nitrites, went on to state, “Most of the deaths [from cancer] are due to the foods people ate thirty to forty years ago.”
Adding known carcinogens to organics food is deceptive and misleading and must be avoided by the US and by all members of Codex both on principle and for health reasons.
Consumers and their government representative in many countries recognize that nitrates and nitrites have no place in organic foods. For example, Costa Rica says (CL 2006/49-FL) in its written comments on this issue,
“We must take into consideration that, in addition to accepting the additive [nitrate/nitrite], its use must comply with the organic production guidelines criteria, meaning they must not violate the principles established in those Guidelines. Therefore, … In the case of additives for use in animal origin foods, and particularly in the case of Sodium Nitrite (INS Nº 250) and Potassium Nitrate (INS Nº 252), it is important to note that these substances are known to present a risk for human health as they generate nitrous N compound that have been shown to be carcinogenic in experimental animals, some of them being mutagenic and others teratogenic, as well as having high levels of their salts associated with a higher incidence of stomach and esophagus cancers. Due to the aforesaid, our position is that the use of these substances in organic foods of animal origin violates the principles of organic production and, therefore, our country does not accept their inclusion in this list.”
Norway bans all nitrates and nitrites in all foods, organic or not, noting that proper hygiene and handling eliminate the need for the substances in food altogether noting,
“[250] [Sodium nitrite] For food of animal origin: Not accepted especially for prod. Group 8.2.2. Heattreated [sic], 8.2.3, 8.3. and 9.2.4.1 Should not at all be used for colour [sic] retention. Could doubtfully be used as a preservative. It is possible to produce products without these additives. This requires good hygiene, and HACCP should be in place. There are health concerns about using this additive. The Norwegian consumers do not expect to find this additive in organic products.” [Emphasis added]
252 Potassium nitrate The above mentioned categories are not included for 252. See 250
301 Sodium ascorbate See comments to 250 and 252 The use of this additive is linked to the use of nitrate/nitrite and should therefore not be used.”
Similarly, Thailand states in its written comments, “It is acceptable for us to exclude the use of any kind of nitrate/nitrite from the organically produced food, especially food of animal origin such as sausages.”
Likewise, Germany has banned both substances in the foods.
The Natural Solutions Foundation believes that nitrates/nitrites have no appropriate place in the human food supply and that permitting their use in foods which are labeled “Organic” is totally unjustified and represents a profound betray of the trust placed in regulatory agencies by consumers. Hence, the Natural Solutions Foundation strongly urges the United States to instruct its Delegate to the Codex Committee on Food Labeling and all other Codex meetings and committees to vigorously oppose the use of nitrates and nitrites in human food under any circumstances and most especially, to preserve the meaning of organic food by using all means at its disposal to make sure these dangerous compounds are not permitted in organic foods.
Dated: April 8, 2007
Respectfully submitted,
Major General Albert N. Stubblebine III (US Army, Ret.)
Rima Laibow MD
For: Natural Solutions Foundation
www.healthfreedomusa.org
