By Michael J. Critelli | MakeUsWell Newsletter,
For decades, U.S. food safety assessments have relied on a deceptively simple principle: if the concentration of a food additive is low enough in each product, it must be safe.
This is the logic behind the FDA’s Acceptable Daily Intakes (ADIs) and the industry’s formulation strategies. It assumes that consumers will encounter these ingredients only in modest amounts, spread thinly across a varied diet.
But real life doesn't follow regulatory assumptions. People don’t consume additives in theoretical units—they consume foods, in real households, in real patterns, driven by marketing, convenience, cost, culture, and habit.
California’s Office of Environmental Health Hazard Assessment (OEHHA) recognized this gap and did something paradigm-shifting. Instead of relying on ingredient concentrations, it relied on publicly available real-world consumption data to measure actual exposure. And the results showed that children, the most vulnerable population, were routinely consuming far more synthetic dyes than the FDA’s outdated models ever anticipated.
The lesson is clear: real-world exposure, not theoretical ingredient limits, is the only reliable measure of food safety.