Dyes in Your Food
Public Citizen Health Research Group, 1985
(Editorial notes in red italics added by the Feingold Association, 2005)
The government has refused to take dangerous dyes out of your food, drugs and cosmetics, but there are several steps you can take to protect yourself and your family.
What do strawberry Jello, orange Koolaid, raspberry soda, grape popsicles, much candy and baked goods, most brands of ice cream, maraschino cherries, many snack foods, and most pet food have in common? They are laced with millions of pounds of artificial coal-tar based dyes with names such as Red 3, Blue 1, Blue 2, Green 3, Yellow 5, Yellow 6, and Red 40. Each year, Americans eat (as food dyes), swallow (as pill coatings or medicinal syrups) or rub on themselves (as cosmetics) 6.4 million pounds of these 7 dyes, mostly in food. (That was in 1985. In 2005, Americans consumed more than 17.8 million pounds of these dyes.) Four of these food dyes (Red 3, Yellow 5, Yellow 6, and Blue 2) which make up over half of the food dyes used each year have been shown to cause cancer as have other dyes which are not used in food but are used in drugs or cosmetics.

CHILDREN AND FOOD DYES

In July 1976, the FDA Division of Consumer Studies published a report concerning the ingestion of food dyes by children in the United States. Some of their findings follow:

  • 95-99% of children eat some food containing coal-tar (petroleum derived) food dyes.
  • Over 4 million children will have consumed a total of more than one pound of coal-tar food dyes by the time they are 12 years old.
  • The maximum consumption of food dyes by children is as high as three pounds by age 12.
Table 1
DISAPPEARING FOOD DYES:
17 U.S. Food Dyes Now Banned,
Delisted or Not Produced
DYE
YEAR BANNED, DELISTED
OR LAST PRODUCED
      Sudan 1
1918
      Butter Yellow
1918
      Red 32
1956
      Orange 1
1956
      Orange 2
1956
      Yellow 1
1959
      yellow 2
1959
      Yellow 3
1959
      Yellow 4
1959
      Red 1
1961
      Green 1
1966
      Green 2
1966
      Violet 1
1973
      Red 2
1976
      Red 4
1976
      Citrus Red 2
1976
      Orange B
1978
These figures are quite conservative since there has been a 50% increase in the total use of food dyes in the past ten years. (from 1976 to 1985. The amount of dyes used per year has tripled since then. It would not be unreasonable to assume that a 12 year old today has already eaten 10 pounds of food dyes)  In addition to the possibility that they are more susceptible to carcinogenic chemicals such as food dyes, children will have a longer history of ingestion and thus a greater likelihood of developing cancer because they eat these dyes.

HISTORY OF FOOD DYES

Although we are very concerned about any carcinogenic or otherwise toxic dye, food dyes are the biggest worry because much larger quantities of these dyes are produced and ingested than drug or cosmetic dyes and because children are major targets/victims of food dyes.

The history of food dyes in the United States is really a history of disappearing food dyes. Of the 24 food dyes which at one time have been allowed in the American food supply, 17 are now banned, delisted or no longer produced as can be seen in Table 1.

Of the seven food dyes still used (see Table 2), three (Red 3, Yellow 5 and Yellow 6) are the subject of a Public Citizen Health Research Group petition to FDA for a ban and a subsequent law suit. These three alone, however, accounted for 3,396,855 pounds or 53% of all food dyes certified in fiscal 1984. (Unfortunately, these 3 colorings are still in use 20 years later, and in 2005 the FDA certified 8,648,679 pounds of them, again almost half of all food dyes certified.) The other four dyes also have serious questions about their safety as indicated in Table 2. Of these four, Blue 2 is currently (in 1985) the subject of an FDA Administrative Hearing as a result of Public Citizen's objections to the FDA's decision to permanently list it. There was a statistically significant increase in the number of brain tumors in animals fed Blue 2. We are currently reviewing the safety studies on the other three dyes (Green 3, Red 40 and Blue 1) because of the toxic findings listed in Table 2.

It is likely that in a very short time, there will be few, if any, "certified" petroleum-derived food dyes left. Fortunately, products such as Dannon Yogurt ("No artificial anything"), General Foods' Cheerios (no Yellow 5 as in the past), and many other foods without artificial colors have shown, by their extraordinary success, that we can all do very well without these dyes.

WHAT HAS PUBLIC CITIZEN DONE?

In December 1984, Public Citizen Health Research Group petitioned FDA to ban the use of ten widely-used food, drug or cosmetic dyes. On January 22, 1985, we sued the government to remove these dyes, all of which have been shown to cause cancer, from the market. None of these dyes has ever been found safe by FDA for all uses but all have remained on the market pending resolution of their "provisionally listed" status. For six of the ten dyes, FDA recommended such a ban. In March, 1984, we argued that as long as these dyes remain on the market, FDA is violating the safety requirements of the Color Additive Amendments to the Food, Drug and Cosmetic Act. By failing to immediately ban these dyes, the Reagan Administration is making a mockery out of its alleged cancer reduction goals and is completely demoralizing dozens of FDA employees who know these dyes are too dangerous for continued use by the public.

We obtained a copy of an internal FDA memo confirming the illegality of marketing five of these dyes (D&C Reds 8, 9, 19, and 37 and D&C Orange 17) written by FDA's Director of the Center for Food Safety and Applied Nutrition Dr. Sanford Miller on November 23, 1984.

Dr. Miller, referring to the cosmetic industry's plea for further peer review of the dyes, said:

"In other words, the only effect that we can realistically see from additional peer review is a further delay that would risk a lawsuit asserting that FDA is not adhering to its responsibilities under the law. In our judgment we have already extended the provisional list so many times for such tenuous reasons that we are in danger of losing both a lawsuit and our credibility as a regulatory agency."
Dr. Sanford Miller
Director of the Center for Food Safety and Applied Nutrition
United States Food & Drug Administration
Internal Memo - 1984

Table 2
7 REMAINING FOOD DYES IN U.S.
DYE
MAIN
USES
POUNDS
CERTIFIED 1984
POUNDS
CERTIFIED 2005
TOXICITY
FINDINGS
COMMENTS
RED 3 Candy, Desserts, Baked Goods 241,265 260,851 Thyroid tumors
Chromosomal
damage
FDA tried & failed to ban it
RED 40 Beverages, Candy, Desserts, Pet Food 2,630,578 6,541,368 Lymphomas
(lymph tumors)
Banned in
EEC
(European Economic Community)
BLUE 1 Beverage, Candy, Baked Goods 260,417 1,802,634 Chromosomal
damage
Banned in France,
Finland
BLUE 2 Pet Foods, Candy, Beverages 101,223 642,246 Brain tumors Banned in Norway
(pending FDA hearing)
GREEN 3 Beverages, Candy 3,597 13,747 Bladder tumors Banned in
EEC
YELLOW 5 Pet Food, Beverages, Baked Goods 1,620,540 4,231,420 Allergies, Thyroid tumors, Lymphocytic lymphomas, Chromosomal
damage
Banned in Norway
YELLOW 6 Beverages, Candy, Desserts, Sausage 1,530,050 4,156,408 Allergies, Kidney tumors, Chromosomal
damage
Banned in Norway,
Sweden
Total 6,392,670 17,648,674 Since the 1985 effort to
ban them, their use has
INCREASED 300%. Are you
very surprised we are losing
the "war on cancer?"
WHAT CAN YOU DO?

  1. Avoid using any foods with artificial dyes ("artificial coloring," "U.S.Certified colors") such as the seven listed in Table 2: Red 3, Blue 1, Blue 2, Green 3, Yellow 5, Yellow 6 and Red 40. More and more nationally distributed foods such as Cheerios, Grape-Nuts, Nutri-Grain, Dannon Yogurt, Pepperidge Farm Products and others not only contain no artificial coal tar food dyes, but also have no other additives. Buy these instead of dye-containing products. In addition, real fruit juices and gelatin desserts or popsicles made with fruit juice are healthy substitutes. (The brand information listed here is out of date and not all of their products are without additives. Many additives are hidden inside "secondary" ingredients, so label-reading is unreliable. The only reliable guidance for foods without the worst of the synthetic additives is provided by the Feingold Association through their continuously-updated Program materials.)

  2. The seven drug and cosmetic dyes which should be avoided, all "D&C" (drug and cosmetic dyes) are: Red 8, Red 9, Red 19, Red 36, Red 37, and Orange 17. Read the ingredient list on cosmetics (if it is there) before using them.

  3. Avoid yielding to arguments that only one in a million people using each of these dyes will get cancer at the doses used in foods, drugs, or cosmetics. For all of these dyes, for all people using them, this amounts to well over 1000 cases of cancer. In addition, hundreds of thousands of people are extremely allergic to Yellow 5 or Yellow 6 and small amounts, even a few thousandths of a gram, can cause severe reactions in some of these people. (Don't forget that the amount your children are exposed to today is many times higher than what you were exposed to as a child, and there is no valid study showing that long term exposure to even low levels of these additives is safe.)

  4. Write your Senator and Congressperson asking them what they are doing to push the government to obey the food safety laws and ban these dyes.