A recent analysis uncovers 25 chemicals associated with cancer that the Food and Drug Administration (FDA) permits in American food production. Scientists from the Environmental Defense Fund (EDF), a nonprofit environmental advocacy organization, classify eight of these as known human carcinogens and 17 as reasonably anticipated to cause cancer in humans.
The findings highlight the FDA’s apparent oversight of the Delaney Clause, a 1958 law mandating the prohibition of food and color additives proven to induce cancer in humans or animals. This clause enforces a zero-tolerance policy, disallowing approval of such substances regardless of dosage, exposure levels, or benefits.
The Delaney Clause and Regulatory Gaps
Despite this regulation, substances like formaldehyde, asbestos, benzene, methylene chloride, and trichloroethylene persist in the food supply chain. These chemicals appear not as direct additives but in materials that contact food, including packaging, processing equipment, and industrial aids such as adhesives, coatings, paper products, rubber components, and plastics.
They also feature in food processing methods, such as coffee decaffeination, extraction of spices and hops, modification of food starches, flavorings, chewing gum bases, and color additives like paprika, annatto, and turmeric oleoresins. This allows potential entry into the food chain via contamination from packaging, equipment, or ingredients.
Maria Doa, PhD, Senior Director of Chemicals Policy at EDF, states that none of these chemicals qualify for use as direct food or color additives in the European Union. ‘Any chemicals not on the EU’s approved list are effectively prohibited, and their presence would be considered contamination rather than authorized use,’ she explains.
The classifications draw from evaluations by authoritative bodies. The National Toxicology Program (NTP) defines known human carcinogens as those with sufficient evidence of causing cancer in people, while reasonably anticipated carcinogens show strong evidence from animal studies or mechanistic data. The World Health Organization’s International Agency for Research on Cancer has assessed several of these substances.
Specific Chemicals and Their Applications
EDF notes that the science on these chemicals is well-established, with many reviews dating back decades and lacking updates under current cancer risk standards. Some approvals exceed 50 years old. For instance, methylene chloride, used in coffee decaffeination, has not faced FDA review since the 1980s.
Known human carcinogens include asbestos, benzene, ethylene oxide, formaldehyde, pentachlorophenol, sodium chromate, trichloroethylene, and zinc chromate. These link to cancers such as lung cancer, leukemia, liver cancer, and mesothelioma. Asbestos appears in certain adhesives, rubber articles, and resins for food manufacturing. Benzene features in modified hop extracts and adhesives, while ethylene oxide treats paper and paperboard for food contact. Formaldehyde occurs in defoaming agents, adhesives, animal glues, and paper products for dry and fatty foods.
Reasonably anticipated carcinogens encompass methylene chloride, 1,4-dioxane, acrylamide, chloroform, chloroprene, epichlorohydrin, dimethyl sulfate, ethylene dichloride, bis(2-ethylhexyl) phthalate (DEHP), p-dichlorobenzene, styrene, chloral hydrate, and 1,2,3-trichloropropane. These apply in plastics, coatings, lubricants, rubber, and paper for food contact, as well as in processing.
Methylene chloride, for example, remains in decaffeinated coffee, spice oleoresins, and color diluents, despite ties to cancer, liver toxicity, neurological damage, and fatalities at high levels. Acrylamide appears in modified starches and packaging materials, while 1,4-dioxane and chloroform feature in adhesives and plastics.
FDA Response and Enforcement Calls
EDF argues that the FDA holds authority to eliminate these carcinogens immediately under the Delaney Clause, without needing further evidence. ‘FDA has the authority to remove these carcinogens from the food supply immediately,’ Doa asserts. ‘The agency is choosing to keep them approved, allowing ongoing exposure.’
A spokesperson from the US Department of Health and Human Services indicates that the FDA cannot comment on third-party data without independent validation. However, the agency has initiated a strengthened post-market review for existing food chemicals and additives, including reforms to the Generally Recognized as Safe (GRAS) framework. This process prioritizes evidence-based reviews to ensure safety and revoke authorizations when necessary.
Health Risks from Cumulative Exposure
Even with limits on residual amounts post-manufacturing, studies show these chemicals can migrate into food under everyday conditions, leading to repeated consumer and worker exposure. Doa emphasizes, ‘Even if a single chemical is considered “low” potency individually, there may be greater exposure to it than to a more potent carcinogen.’
The FDA lacks detailed data on real-world exposure levels, complicating risk assessments. Doa adds that Americans encounter these substances alongside others in daily environments. ‘When chemicals like these are so frequently present in our food and elsewhere in our lived environment, the result is near constant exposure. Over time, these small exposures can add up and slowly affect our health, including increasing cancer risk.’
