Sunday, February 22, 2015

The Fundamental Flaw in North American Food Safety Regulation

Here's a thought:

The moral ethical standard for our justice system whereby you are presumed innocent until proven guilty fails miserably when applied to food safety regulations, e.g. the American FDA's "generally regarded as safe" provision, or GRAS for short.

Rather, we should try to emulate the European and other foreign food and health regulators—that whatever additive, preservative, pesticide or any chemical destined for the food chain, be considered "guilty" until proven innocent; dangerous UNTIL proven safe for human consumption.


The former standard is one that can be described by statistical theory, or what one might call the avoidance of Type I Error. To illustrate using the metaphor of the justice system, an error of Type I is an error whereby a court or jury finds a defendant guilty when in fact they are innocent (i.e. rejecting the null hypothesis). One can see immediately how a Type II Error still yields a more desirable outcome, e.g. a guilty person goes free. In our civic society, our moral ethical standard essentially implies a preference to let 100 criminals walk free than to erroneously incarcerate even ONE innocent person.


Because a Type I Error would constitute an egregious miscarriage of justice, the standard is very high, i.e. a court or jury must find a defendant guilty BEYOND a reasonable doubt. Statistically, therefore, a low significance level is appropriate. The FDA's GRAS provision violates this principle. Not only does it violate the principle, it squarely places the onus of "disproving a compound's presumed safety" squarely on the shoulders of private, for-profit corporations; it is a VOLUNTARY system of disclosure. Yes, you read correctly.


Enjoy your processed foods and GMOs because, so far they're still considered safe for human consumption.

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