Comment Submissions - Notice of Proposed Rulemaking Title 27, California Code of Regulations Safe Harbor Warnings for Acrylamide Exposure from Food

The 1994 rating of Acrylamide by the International Agency for Research on Cancer is Probable Human Carcinogen. The rating was subject to Suppression of Research. The previous United Nations rating, the 1985 rating of Acrylamide by the World Health Organization was Possible Human Carcinogen. The rating was subject to a Suppression of Research. The suppression was a continuous activity, from 1968 to 1991. The first rating, which involved interference, led to the diversion of the research, in 1989, to 1991, and the retirement of the Lead Investigator in 1991. There are several factors involved in the cause of the suppression, which was enacted by a Tobacco interest. These are presented after a basic review of the scientific inquiry. Laboratory supervision was lacking. Funding was directed. by both government and lab, to institutional granting, with an entity funding that was criticized prior, and an entity funding that was banned later. Government policy obscured opportunities for independent research. Its policy was continued after the discovery of the dietary content in 2002. If one checks the Tobacco Truth Documents for Acrylamide, one notes a sequence of papers at New York University of Adduct Science from 1974 to 1989. One then notes the diversion from the study of Glycidamide, in 1989, to the study of Ethylene Oxide. August 1989, Glycidamide was reported as the oxidized product of Acrylamide at University of Washington. October 1989, Ethylene Oxide was proposed at New York University. There was opportunity, with scientific reason, for the study of Glycidamide at NYU thereafter. The Lead Investigator, however, after beginning the study of Ethylene Oxide, began study of Acrylonitrile Oxide, and retired. Acrylamide was seen to have a stronger Adenine adduct than Acrylonitrile. The general procedure was to use the most powerful adduct to search for mutations with. The epoxides usually had stronger adducts than the original chemicals. The Tobacco Truth Documents present papers of 1974 to 1989, and the Ethylene Oxide proposal, along with statements of Council for Tobacco Research, a group later banned. The statements in 1989 reject further study of Acrylamide and support the diverted study of Ethylene Oxide. In addition, statements were used in creating these directives that questioned the study of an epoxide of Acrylamide, prior to the Glycidamide discovery. The questioning was inconsistent with the current science. A closer look at Tobacco Truth Documents reveals that Philip Morris visited the NYU, Tuxedo lab, in 1967, as preparations were made to form the Tobacco Working Group. One may also view criticism of the Tobacco Working Group's Supervisor, Arthur Upton, given the misleading information offered to the public, in 1979. Both events combined to cause conditions of the diversion of Acrylamide research at NYU. Philip Morris was privy to the staff. Arthur Upton was a poor Director there, beginning in 1980. The sequence of events that led to the Suppression of Research of Acrylamide, directly, began with the influenced WHO scheduling of the 1985 Acrylamide rating for June 1985, ahead of the planned publishing of the NYU paper on its damage to DNA, August 1985. The scheduling did not result in administrative support by Upton. Instead, as seen in the 1988 NYU Propylene Oxide paper, a poster presentation was made in Gaithersberg, Maryland, at an early June 1985 conference, a week before the WHO rating began. Upton spoke at this conference. He later avoided the consequences of the poster presentation, and the registration of Acrylamide data at National Institute of Standards, early June 1985. The NYU lab files contain information on tobacco crime in early 1988,with the NIS registration at issue. By early 1989, as the NYU lab report shows, Ethylene Oxide was described, despite efforts at UW towards identifying the epoxide. The Tobacco Truth Documents include contact made at NYU with Center for Indoor Air Research, a later banned group. CIAR is then seen supporting the diversion to the study of Acrylonitrile Oxide,a second study of the chemical, as the Glycidamide study was delayed, in 1991. American Cancer Society granting was accepted, despite the Report of the Shubik Commission, criticizing ACS's granting of Cancer Research. In Congressional testimony, Dr. Rachel Leboy described the necessity .for consistent federal funding for research. The lack of Adduct Science in the 1994 rating has been criticized. A second criticism of the rating is that it lacked mouse study, directed by NYU Scientists. An imposed NIH mouse was used. As is seen in the September 1986 paper, storage of the mouse was moved from NYU. The move was out of fear of tobacco crime. The lack of coordinated funding of Acrylamide at NYU led to tobacco crime, diversion, and Suppression of Research. Had Health Education and Welfare, as suggested in 1979, investigated the Tobacco Working Group, Upton's appointment might have been avoided. Dr.Beland studied Acrylamide and Glycidamide adducts, at NCTR, and his work with the mice NYU normally used were seen to have mutations. He directed the IARC Advisory Committee in 2019. Acrylamide was prioritized for rating, it was not selected. Dr.Beland's 16 year investigation at National Center for Toxicological Research did not study Cytosine adducts, the main concern of the NYU line of research. NIEHS refused funding in 2004. JNCI had omitted the NYU line of research of Adduct Science in its 2004 article. NIEHS published in its journal ,in mid 1989, NYU's justification of its goals ,the goals of the Nelson Institute, pointing to the adduct study of Glycidamide. In 1991 NIEHS assigned a NIEHS student for the second study of Acrylonitrile Oxide. The Laboratory of Organic Chemistry and Chemical Carcinogenesis, of the Department of Environmental Medicine, was represented at the World Cancer Congress of 1986, where a lecture on Acrylamide was given. World scientific opinion then approved the work and planning. The basic information at Tobacco Truth Documents focuses on communications of 1989. The suppression began upon the hire of the Lead Investigator. Interference increased as he began proposing grants in 1982. Institutional granting improved access to the lab of individuals from later banned front groups. Government initiatives were seen to detract from independent research. Lab supervision did not confront rating discrepancies. NYU presented non-published work with Acrylamide in its1999 IARC Publications review. The WHO held an emergency meeting June 2002, after the filing of Acrylamide at the Tobacco Truth Documents. No reference was made to the suppression in the report. The latter Framework Convention on Tobacco Control/ Global Alliance on Tobacco Control, did not convince the IARC to rerate. It was enacted to use Tobacco Settlement initiatives. One initiative was to allocate funds for public education about cancer. These plans failed. General education on the subject would include reference to the major carcinogens found in tobacco smoke and the diet. Acrylamide is dangerous in slight amounts. There are alternative cooking techniques that are Acrylamide-free.