Comment from Anonymous

AnonymousSupportIndividual
Summary: The commenter, a registered nurse and consumer, supports a rigorous and transparent post-market review of BHT. They argue that the FDA should account for cumulative dietary exposure and scientific uncertainties rather than relying on outdated safety assumptions.
I am submitting this comment as a registered nurse, a consumer, and someone who has personally faced cancer. My concern about BHT extends beyond any single study or health claim. It is about the standard of evidence we require for chemicals that may be consumed repeatedly, across multiple foods, over many years. Consumers reasonably assume that ingredients permitted in the U.S. food supply are not simply considered safe based on a decision made decades ago, but are continually reevaluated as new evidence, better testing methods, and more complete exposure data become available. I do not believe that assumption has always matched reality. BHT is used in multiple categories of commonly consumed foods. This makes it especially important that the FDA evaluate real-world cumulative dietary exposure rather than considering exposure from a single product or food category in isolation. The assessment should also carefully consider chronic exposure and potentially vulnerable populations, including children and people with significant health conditions. As a nurse, I understand the importance of distinguishing between evidence of hazard and evidence of actual risk at typical human exposure levels. I am not asking the FDA to make decisions based on fear or headlines. I am asking the agency to apply a precautionary, transparent, and genuinely independent scientific review that accounts for uncertainty rather than treating missing data as evidence of safety. I urge the FDA to publicly explain what evidence it relies upon, where meaningful data gaps remain, how cumulative exposure is estimated, and how uncertainty is incorporated into its final decision. If adequate evidence is not available to establish a reasonable margin of safety for long-term exposure, continued widespread use should not simply be the default. Americans should not have to become amateur toxicologists in the grocery aisle. The burden should not be on individual consumers to research every additive and attempt to determine which exposures may matter. We need a food safety system in which approval is not permanent by inertia and in which chemicals already in the food supply are meaningfully reassessed as science evolves. I strongly support rigorous post-market review of BHT and greater transparency about both the evidence and the uncertainties involved in determining its safety.

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