Comment Period - Announcement of Release of the Public Review Draft of “Health Effects Assessment: Potential Neurobehavioral Effects of Synthetic Food Dyes in Children”

Please consider the following two comments regarding the Epidemiologic Studies of Synthetic Food Dyes and Neurobehavioral Outcomes in Children in the August 2020 DRAFT OEHHA “Health Effects Assessment: Potential Neurobehavioral Effects of Synthetic Food Dyes in Children” (1) In Chapter 2 of this OEHHA draft review document, the authors’ presented their conclusions (Section 2.8, p. 45) from the epidemiologic studies of synthetic food dyes and neurobehavioral outcomes in children. Even though the authors stated that “… the findings in the clinical studies they reviewed are not entirely consistent from one study to the next” and that “..Clear associations were not seen in every study, and not all of the studies were high quality”, they concluded that “Based on the extent of the positive findings reported, and the fact that we could not convincingly or consistently attribute these positive findings to errors in study design or other bias, we conclude that the current human epidemiologic evidence supports a relationship between food dye exposure and adverse behavioral outcomes in children.” In view of the noted inconsistencies across studies and findings of questionable significance from studies of varying quality, the available evidence seems to provide little, if any, consistent or verifiable support for a clear association between food dye exposure and adverse behavioral outcomes in children. Accordingly, the statement of conclusion should be qualified to reflect that the available evidence may suggest or support a possible relationship between certain food dyes and adverse behavioral outcomes in some children. (2) There is a relevant body of evidence from epidemiologic studies using oligoantigenic or ‘few foods’ elimination type diets, which was not considered in this OEHHA assessment document. These studies show that certain children with ADHD or other problem behaviors may exhibit a unique intolerance to a variety of foods and food components, including but not limited to artificial colors (e.g., Boris et al, 1994; Carter et al, 1994; Egger et al, 1985; Egger et al, 1992; Kaplan et al, 1989; Schmidt et al, 1997; Uhlig et al, 1997). These studies support the possibility that certain children, including those with ADHD or other problem behaviors, may exhibit a unique intolerance to a variety of foods and food components, including artificial colors. Submitted 9/11/2020 References Boris M and Mandel FS. Foods and additives are common causes of the attention deficit hyperactive disorder in children. Ann Allergy, 1994 (May), 72(5):462-8. Carter CM, Urbanowicz M, Hemsley R, Mantilla L, Strobel S, Graham PJ, Taylor E. Effects of a few food diet in attention deficit disorder. Arch Dis Child, 1993 (November), 69(5):564-8. Egger J, Carter CM, Graham PJ, Gumley D and Soothill JF. Controlled trial of oligoantigenic treatment in the hyperkinetic syndrome. Lancet. 1985 (Mar 9), 1(8428):540-5 Egger J., Stolla A and McEwen LM. Controlled trial of hyposensitization in children with food-induced hyperkinetic syndrome. The Lancet, 1992 (May), 339: 1150-1153. Kaplan BJ, McNicol J, Conte RA and Moghadam HK. Dietary replacement in preschool-aged hyperactive boys. Pediatrics, 1989 (Jan), 83 (No.1): 7-17. Schmidt MH, Mocks P, Lay B, Eisert HG, Fojkar R, Fritz-Sigmund D, Marcus A and Musaeus B. Does oligoantigenic diet influence hyperactive/conduct-disordered children - a controlled trial. European Child & Adolescent Psychiatry, 1997, 6: 88-95. Uhlig T Merkenschlager A Brandmaier R Egger J. Topographic mapping of brain electrical activity in children with food-induced attention deficit hyperkinetic disorder. Eur J Pediatr, 1997 (July), 156(7):557-61.