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FDA denies petition against use of phthalates in food packaging

fda.gov

141–150 of 197 posts

Re: FDA denies petition against use of phthalates in food packaging

#141
post #49

A bunch of comments here are roughly "there's not great evidence that these are harmful" -- but is that the right standard? Or should there be an obligation to provide evidence that something is "safe" in order to use it in some consumer applications (like food packaging)? It's tempting to say that we should conclusively establish that something isn't harmful before we use it absolutely everywhere ... but what standa…

Your second paragraph is a very good argument against requiring that everything used in food packaging be shown to be safe before it can be used. Can we reasonably run such a study to prove that wax paper is safe? What about plain paper? Do we just require all food producers to use no packaging at all until these controlled longitudinal studies are completed? If we allow them to use packaging, how do we define in a p…

> Can we reasonably run such a study to prove that wax paper is safe?

We don't need to. We have a "Generally Recognized as Safe" standard that is well known and widely applied.

> widely used in some significant (think 5%) portion of the industry then we allow it

How about we just label things so consumers know whether or not the packaging contains phthalates? That way the market can decide if they want it in their package or not.

Re: FDA denies petition against use of phthalates in food packaging

#142

Earlier quoted context omitted.

For me, the standard is: if the material was used pre-industrial age, it's far more likely to be "safe". Any person could overintellectualize this point and find exceptions. But it's just common sense.

Just because I can: see pre-industrial Romans and their lead acetate. Or Egyptians with their kohl eyeliner (also lead). I prefer strong regulatory bodies that methodically analyze products available to general consumers.

I think you can have both.

I also want strong regulatory bodies doing those analyses, but I also would like to see them using reasonable Bayesian priors on safety. I think assuming the Bayesian prior that: compounds that occur naturally in our environment at concentrations and particle sizes similar to what we'd be exposed to in a proposed new product are likely safe to use. The opposite just is not a good Bayesian prior, and such compounds should require greater assurance of safety before being allowed to be used in novel ways.

The above is particularly true for organic compounds.

I'd also like to see regulation of analogs like they do with drugs. Swapping out BPA for other analog chemicals with very similar shape/composition is something most people with a decent background in biochemsitry would be extremely skeptical of. Let's say they banned BPA entirely. I'd like to then see regulators step in and ban analogs by default for the same use until proven otherwise.

Re: FDA denies petition against use of phthalates in food packaging

#143

Earlier quoted context omitted.

Why do we think our ancestors were not harmed? do we have any reason at all to think that?

Because we exist. Admittedly, "healthy enough to procreate" is not a high bar, but it's pretty good in comparison with no bar at all. Yeah, there are cases where they were unaware of the harm--like lead. We should absolutely be finding better ways to identify and mitigate harms of that sort. But in the absence of reliable information from such efforts, natural==safe is a viable heuristic. And I'd say that our scienti…

I think natural==safe is a terrible heuristic for the exact reason you said.

Healthy enough to procreate is a low bar, and many natural things provide a benefit in terms of procreation but detrimental to health. Almost everything in nature is a trade-off between how much it'll harm you and how much it'll help you procreate.

This reminds me of how whales get the Bends from diving despite 50 million years of evolution. People question whether it causes them pain, and it stands to reason that it would cause them pain to prevent them from diving more than necessary. Nature isn't inherently kind, it is results oriented.

You can make a valid argument that avoiding something entirely is usually safer than something, as few things provide a protective effect. However, when you talk about substitutions, all bets are off.

Re: FDA denies petition against use of phthalates in food packaging

#144
post #91

Earlier quoted context omitted.

This reminds me of a banking software company I used to work at. One of their products was assessing risk for loans, too many purchases for fast food or restaurant categories on your bank statement could cause you to not get a loan. I could see insurance companies purchasing your rewards accounts from data brokers to see what your habits are.

That’s a fascinating thought. Our digital footprints are becoming more telling of our real lives, as more of our lives are mirrored digitally. And in many ways that’s great - not only is booking a flight easier but my eating habits when combined with millions of others can reveal what epidemiology of yesteryear could only dream of But I think this is where the privacy debate falls down - privacy is not real (secrecy…

This is why we need real ownership and control of data about ourselves. It should be totally unacceptable for a bank to pull what OP described. Banks and loan underwriters should not have access to this kind of data about us in the first place, let alone use it to discriminate for/against people. Insurance companies should not have access to this kind of data either. We should be able to control access to these data and companies should not be allowed to discriminate based on whether or not they can obtain consent to access it.

Re: FDA denies petition against use of phthalates in food packaging

#145

I was surprised to learn that some of the highest concentrations of phthalates can be found in alcoholic beverages in glass bottles (Table 3: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7460375/ ) This occurs due to the plastics used in producing the alcoholic beverages combined with ethanol (alcohol) acting as a solvent to liberate the phthalates I was equally surprised to learn that the food industry was already m…

Insurance companies already track whether you smoke, drink, or do recreational drugs. I wonder how long until they start to ask questions that indicate your risk based on chemical \ microplastic consumption.

What questions are you expecting them to ask? "Do you eat chipotle"? "Are you alive"?

Re: FDA denies petition against use of phthalates in food packaging

#146
post #85

Earlier quoted context omitted.

1. It's a lot harder to prove something is 100% assured safe then the other way around 2. Every substance/material/etc that is investigated and banned incurs overhead on taxpayers and industry directly. What you're asking for would be extremely prohibitive to getting anything done at all.

To be clear, I'm not asking for anything. I'm raising a question, because I'm genuinely conflicted. It seems intractable to test everything for long enough to know that it's safe. On the other hand, the 20th century had some good examples of cases where we understood that something harmful only very long after it was in the environment (e.g. leaded gasoline). Also to be clear, at no point did I say 100% about anythin…

It doesn't seem like there's really a right answer. There is such a wide spectrum between "yolo everything into the market and find out later whether it is dangerous" and "don't do anything unless it's proven safe." I personally feel we can afford to throw innovation under the bus a little more than we do today, in exchange for more safety assurances, but reasonable people can disagree about it.

Re: FDA denies petition against use of phthalates in food packaging

#147
post #118

Earlier quoted context omitted.

Doesn't it? Got any evidence for that claim?

no, it doesn't. no, i don't have any evidence it doesn't. if you go looking for evidence that it does, though, you won't find any evidence for that, either

Of course it does - plastics used in packaging scratch easily. That's enough to produce microplastics.

Additionally polypropylene degrades under sunlight, becoming brittle. The process takes several months.

Re: FDA denies petition against use of phthalates in food packaging

#148
post #147
post #118

Earlier quoted context omitted.

no, it doesn't. no, i don't have any evidence it doesn't. if you go looking for evidence that it does, though, you won't find any evidence for that, either

Of course it does - plastics used in packaging scratch easily. That's enough to produce microplastics. Additionally polypropylene degrades under sunlight, becoming brittle. The process takes several months.

oh, sure, they can produce microplastics after you take the food out. but you aren't going to get plastic dust in your lettuce

the most common plastics used in packaging are pet, polypropylene, and polyethylene, which have exceptional elongation at break. when you scratch them, you don't produce microplastics; you produce a burr on the surface

Re: FDA denies petition against use of phthalates in food packaging

#149
post #91

Earlier quoted context omitted.

This reminds me of a banking software company I used to work at. One of their products was assessing risk for loans, too many purchases for fast food or restaurant categories on your bank statement could cause you to not get a loan. I could see insurance companies purchasing your rewards accounts from data brokers to see what your habits are.

That’s a fascinating thought. Our digital footprints are becoming more telling of our real lives, as more of our lives are mirrored digitally. And in many ways that’s great - not only is booking a flight easier but my eating habits when combined with millions of others can reveal what epidemiology of yesteryear could only dream of But I think this is where the privacy debate falls down - privacy is not real (secrecy…

> what do others do with our information - and I think the best answer is the medical ethics answer - nothing unless it is in the individual’s best interests.

How is saving money not in an individual’s best interest?

You have person A who chooses to consume known carcinogens and excess carbohydrate, and person B who abstains from them and exercises control for their diet.

Why is it ethical for person B to have to subsidize person A?

Similarly, person A chooses to spend more money on less nutritious fast food meals, and person B makes quinoa salad at home and takes it to work. A lender may conclude person B exhibits behavior that indicates they have a lower probability of default, so why should person B have to subsidize person A’s lifestyle?

If the counter argument is that person A is poorer, had poorer parents, had a worse upbringing in a worse neighborhood with worse influences, then the correct way to subsidize person A is via government spending (cash, education, raising the floor on pay to quality of life at work ratios).

Re: FDA denies petition against use of phthalates in food packaging

#150
post #53
post #44

Earlier quoted context omitted.

But how can anyone prove safety here? On anything? I’m unaware of any substance which isn’t dangerous or harmful in some context. Even sand! What is the actual bar?

Generally safety is evaluated based on intended use. The intended use of leaded gasoline is burning it and putting lead in the air. The intended use of asbestos is as an inert fire-retardant layer. It's safe in that context. Where it's not safe is in all the work that goes into building, or tearing down that layer. The intended use of BPA was putting it into 'microwave safe' plastic containers, where it leeched into…

I’m not sure your examples make much sense?

It also requires a risk/reward assessment, as everything has tradeoffs. Without some sort of assessment of concrete risks, making tradeoffs is also a wild guess.

Using asbestos in oven mitts? Probably not worth it, safety wise. Plenty of good and safe alternatives, and nobody is going to die if it’s 25% more or less effective.

Using it in firefighter turnouts? Maybe, depending on shedding characteristics and effectiveness of alternatives.

Using it in encapsulated hard paneling for specialized industrial furnaces? Quite safe.

But only if you have some sort of stats on cancer rates vs exposure rates. But that takes a lot of time and exposure (for almost anything except FOOF anyway), and requires actually using it.

Or a lot of guessing and inconclusive/misleading lab tests anyway.

And if you can’t use something until you can prove it’s safe, the whole situation is a Catch 22.

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