Tag Archives: artificial colors

Sudan dye

Adulteration with Sudan Dye Has Triggered Several Spice Recalls

By Thomas Tarantelli
Sudan dye

In the following article, the author reports finding Sudan dye in spices in New York State, making the argument for Class I recalls.

In New York State (NYS), Department of Agriculture and Markets food inspectors routinely sample domestic and imported food from retail markets for food dye determination. For decades, the NYS Food Lab has examined both domestic and imported food for undeclared allowed food dyes and unallowed food dyes utilizing a paper chromatography method. This method works well with water-soluble acid dyes, of which food dyes are a subset.

The NYS Food Lab has participated in four sets of the FAPAS proficiency tests: Artificial Colours in Soft Drinks and Artificial Colours in Sugar Confectionary (Boiled Sweets). The qualitative analysis was by paper, thin layer silica and thin layer cellulose chromatography. Satisfactory results were obtained.

The paper/thin layer chromatography method is a qualitative non-targeted method and has a limit of detection of approximately 1 to 5 ppm (parts per million) depending on the dye. If an unallowed dye is detected, the food product is violated as adulterated and results are forwarded to the FDA.

Some countries have a maximum concentration of allowed food dye in a food product. For example India has a 100 ppm to 200 ppm maximum for their allowed food dyes, in some food, singly or in combination.1

Sesame seeds, Rhodamine B
Early 2011, sesame seeds were found to contain Rhodamine B.

In early 2011, a food sample of pink colored sugar coated sesame seed from Pakistan was sent to the lab for color determination. The paper chromatography method could not determine any dyes. (As found out later, the unknown pink dye was not an acid dye.) From research it was found that Rhodamine B was a pink water soluble basic dye commonly used as a food adulterant.  A standard was ordered and then a qualitative high performance Liquid chromatography-tandem mass spectrometry (HPLC/MS/MS) method was developed (Waters UPLC Aquity w/Waters Premier XE triple quadrapole) to determine Rhodamine B. After utilizing this new method, Rhodamine B was found in the sugar coated sesame seed.

Rhodamine B is an industrial dye and is not allowed in food anywhere in the world. Industrial dyes are not allowed in food because they are toxic; in fact, some industrial dyes are used for suicide.2,3,4 In addition, industrial dyes are not made to “food grade” specifications with regard to dye purity, heavy metal (i.e., arsenic and lead) concentrations, subsidiary dye concentrations and concentrations of unreacted precursors. From additional research of news articles and research papers, more industrial dyes were identified as common food adulterants; more dye standards were ordered and incorporated into the HPLC/MS/MS method. The NYS Food Lab’s current HPLC/MS/MS surveillance method includes 36 compounds: Water soluble “acid dyes” and “basic dyes”, organic solvent soluble “solvent dyes”, and several pigments.

The HPLC/MS/MS method has a limit of detection in the ppb (parts per billion) range for some dyes and parts per trillion for other dyes. The FDA has an action level of 1 ppb for certain water-soluble basic dyes (such as Malachite Green) when used as a fish antibiotic. However, due to concern that unallowed dyes might be present due to contamination from packaging, the food lab subsequently set an action level of 1 ppm for unallowed dyes determined by the HPLC/MS/MS method. At levels over 1 ppm, detection of dyes in food would indicate intentional dye usage for coloring food.

The food lab has participated in three rounds of the FAPAS proficiency test, “Illegal Dyes found in Hot Pepper Sauce”. The qualitative analysis was by LC/MS/MS. Satisfactory results were obtained.

Sudan Dyes Considered to be Carcinogenic

“Sudan dyes are not allowed to be added to food. There has been worldwide concern about the contamination of chili powder, other spices, and baked foods with Sudan dyes since they may have genotoxic and carcinogenic effects (according to the International Agency for Research on Cancer)”.5

“There have been several documented cases of spices being contaminated with carcinogenic dyes such as Sudan I or lead oxide. We therefore assume that the presence of these chemicals in spice ingredients will be considered a reasonably foreseeable hazard under this rule.”6

“Sudan red dyes have been used to color paprika, chili powders, and curries, but are also known carcinogens and are banned for use in foods.” 7

Sudan Dyes are a family of more than 10 synthetic industrial “solvent dyes”. Solvent dyes are typically used to color oils and waxes, including shoe polish. Sudan dyes that the food lab has found in spices include Sudan 1 (Sudan I), and Sudan 4 (Sudan IV). Sudan 1, also known as Solvent Yellow 14, is an orange colored dye. Sudan 4, also known as Solvent Red 24, is a blue shade red colored dye.

Positive identification of Sudan 4 is often hindered by the existence of a positional isomer, Sudan Red B (Solvent Red 25). This problem was addressed by using the HPLC/MS/MS method with a transition unique to Sudan 4 (381.2 > 276.0). This information was obtained from one of the two corroborating labs. The food lab has recently identified a transition unique to Sudan Red B (381.2 > 366.1).

Sudan Dyes Found in Spices in Europe

In March 2001, Europe began discovering Sudan dyes in spices. A February 2017 search of Europe’s Rapid Alert System for Food and Feed (RASFF) for “unauthorised colour” and “sudan” in the “herbs and spices” food category resulted in 429 notifications.

The 429 RASFF notifications arranged by year and by maximum concentration reported of Sudan 1 and Sudan 4 during that year are listed in Table I.

Sudan dye
Table I.

In a search of the FDA’s Import Alert 45-02 (Detention Without Physical Examination and Guidance of Foods Containing Illegal and/or Undeclared Colors) the author could find no record of spices violated for Sudan dye adulteration.

In a search of the FDA’s Enforcement Reports the author could find no record of spices violated for Sudan dye adulteration.

Industrial Dyes in Food: Class II or Class I Recall?

The NYS Food Lab and the FDA routinely find imported food containing unallowed food dyes such as Ponceau 4R, Amaranth and Carmoisine. These unallowed food dyes are allowed for use in food in other parts of the world, while not allowed in the USA. Foods containing unallowed food dyes are violated as adulterated and a Class II recall will occur. Sudan dyes are not allowed as food dyes anywhere in the world. They are industrial dyes, used in coloring oils and waxes, such as shoe polish.

“Class I recall: A situation in which there is a reasonable probability that the use of or exposure to a violative product will cause serious adverse health consequences or death.

Class II recall: A situation in which use of or exposure to a violative product may cause temporary or medically reversible adverse health consequences or where the probability of serious adverse health consequences is remote.”8

With a Class II recall, there is no consumer notification. In contrast, as part of a Class I recall, a press release is issued. Consumers who have purchased the product might be informed and may discard the product or return it for a refund.

Continue to page 2 below.

Dr. David Acheson is the Founder and CEO of The Acheson Group
Beltway Beat

Panera Throws Down the Gauntlet by Removing Artificial Additives

By Dr. David Acheson
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Dr. David Acheson is the Founder and CEO of The Acheson Group

Earlier this month, Panera announced its intention to remove “artificial additives by publishing a list of artificial colors, flavors, sweeteners and preservatives that it has eliminated or intends to remove from its [menus] by the end of 2016.” The company’s position wasn’t a response to consumer demand but rather the latest step in its Food Policy of holding itself accountable.

Whether you think Panera’s move is good or unnecessary; whether or not your company plans to start removing additives (or GMOs), it’s important to understand that the food industry is truly driven by consumers. And consumers are all-to-often driven by consumer group and media hype, or by trends they don’t truly understand. It is just as important to understand that whether you are a foodservice provider, retailer, or anyone upstream in the supply chain, this movement impacts you.

Panera commented, “We are not scientists”. However, the company did consult with third-party scientists and experts to create a list of “common artificial additives” with a goal to “unengineer” its food menu and remove artificial additives “that have become prevalent across the industry’s supply chain.” Interestingly enough, Panera never directly states that these additives are bad—they’re just “artificial”. Panera did, however, allow others to say it for them in a series of quotes contained in the company’s press release.

According to the release, “The artificial additives on the No No List will be removed across the Company’s food menu, from bakery to soups to salads and sandwiches. The list also includes substances like high fructose corn syrup and artificial trans fats. There are more than 150 ingredients that will be impacted.”

Don’t believe all 150 ingredients are bad? Your product uses only “a little” high fructose corn syrup? You need to use an ingredient on EWG’s “dirty dozen” list (among the 150 to be discontinued)? You use antibiotics for your poultry? Too bad. If you want to supply Panera (or Chipotle or Whole Foods, etc.), you’ll be left with the option either following their limitations or not supplying them at all. Panera touts itself as the first national restaurant company to publicly share a comprehensive list of ingredients to be removed, but it’s not the first to begin banning ingredients. And with the vocal nature of the consumer groups and the media, it certainly won’t be the last.

If you are a retailer or foodservice provider yourself, be aware that Panera has just thrown down the gauntlet. Will you pick it up and join the fight? Will you publicly share your own list of ingredients in a very transparent way … can you? Now that one company has “shared,” we have to believe it’s going to start a wave of disclosure, either as a competitive tool or in response to public demand—or both.

What if you believe in “engineering”? You know your ingredients are beneficially engineered for health, productivity, or to feed the world in 2050. What are your options if you don’t intend to give into the pressure? You can try to fight transparency with transparency focused on science and communication. Consumers want to know what is in their food, and they have a right to know. They also have a right to understand what is in their food and why, but it is up to industry to be communicating that. But, and it is a huge but, there are many consumer organizations that strive to keep the general consumer off balance and continuing to not trust what the science is telling us. Those battles are very hard to fight let alone win. As soon as the food industry points out that “ingredients” are safe and approved for use, the consumer reaction is one of lack of trust.

Just as we are beginning to see global food safety standards being set (e.g., GFSI, FSMA, etc.), manufacturers and suppliers are being handed a whole new array of “clean” requirements (bringing new audits?) that varies from customer to customer. This adds to the complexity of food production. And if we are not careful, these changes will introduce risks to the food. As we use less preservatives and salt, the obvious concern is that the microbes will simply move in and grow.

Does it ever end? Not if you consider the implications of a comment by Michael Jacobson, executive director of the Center for Science in the Public Interest, in a USA Today article that a greater nutritional problem with Panera’s menu items are their high-calorie counts, “wide use of white flour and excessive use of sugar.” Even if the additive-GMO-artificial ingredient issue gets solved or blows over, there will always be a new health-nutrition-safety-quality-trending issue or fad developing just over the horizon.

It seems you can’t win for losing, so your best bet is to do what you believe is best for your customer and your business, communicate what and why you do what you do, be as transparent as is practical, and keep an eye on the horizon for the next wave. Panera has done this; it has put its flag in the sand in order to enhance its brand and its business. There will be some in the food industry that look at these changes as a threat or a mistake. However, the reality is that it is the way of the future. Food companies make money by selling food, and consumers are the ones that ultimately put the money in the system that keeps it all going. So ignore consumers at your peril, but a huge challenge for much of the industry is that, at the retail and food service end it is easy to make quick changes – but in the manufacturing end it is often neither easy nor fast, and it will be costly.