57th Letter to Health Canada
I am writing regarding Health Canada’s recent statement on synthetic food dyes and their potential neurobehavioural effects on children.
While I acknowledge Health Canada’s position that current evidence is "insufficient" to confirm causation, I urge you to reconsider this stance in light of three critical realities that make avoidance impossible and necessitate immediate action under the precautionary principle:
1. Avoidance Is Impossible Due to Non-Food Exposure
Health Canada advises consumers to "check the list of ingredients" to avoid food dyes. This is unrealistic when synthetic dyes are ubiquitous in essential non-food products:
Children’s Medicines: Medicine administered in hospital: Pain relievers antibiotics, cough syrups, and allergy medications often contain synthetic dyes and no alternative exists in a hospital setting. Parents cannot choose "dye-free" alternatives when treating a sick child.
Dental Products: Toothpastes, mouthwashes, and dental treatments frequently contain these dyes.
Vitamins/Supplements: Gummy vitamins and supplements rely heavily on synthetic dyes including prenatal vitamins consumed by the mother and fetus.
When a child needs medicine or dental care, parents have no meaningful choice to avoid exposure—even if they suspect dyes trigger behavioural issues.
2. No Diagnostic Tool Exists to Identify Vulnerable Children
There is no clinically available test to determine which children may be sensitive to synthetic dyes. Symptoms like hyperactivity, inattention, or aggression and violence manifest inconsistently, overlap with other conditions and cannot be preemptively diagnosed. Without this tool:
Parents cannot proactively shield their children.
Health Canada’s advice to "avoid dyes if concerned" is functionally useless.
All children are de facto at potential risk since susceptibility cannot be ruled out individually.
3. The Precautionary Principle Demands Action
Health Canada states it will restrict dyes only if a "safety reason" exists. However, the precautionary principle—enshrined in Canada’s Food and Drugs Act—requires intervention when credible evidence of risk exists, even amid scientific uncertainty. Consider:
Over 50 studies (including meta-analyses and controlled trials) suggest synthetic dyes exacerbate neurobehavioural issues in some children.
The European Union mandates warning labels ("may adversely affect activity and attention in children") on dyed foods.
The American Academy of Pediatrics acknowledges dyes as a "concern" exacerbating behavioural challenges.
If the evidence is inconclusive, why are millions of children exposed daily without consent? When uncertainty exists and exposure is involuntary, the burden of proof must shift to manufacturers—not vulnerable children.
I urge Health Canada to:
Ban synthetic food dyes in all medicines, dental products, and supplements intended for children and pregnant mothers.
Restrict dyes in foods marketed to children (e.g., candies, snacks, beverages) pending further review.
Require warning labels on all products containing these dyes until a ban is implemented.
Fund independent research on neurobehavioural impacts and develop diagnostic tools for sensitivity.
Children cannot avoid these exposures, and parents cannot mitigate unknown risks. When the well-being of children is at stake—and alternatives exist—inaction is not neutrality; it is an endorsement of continued, involuntary exposure. I implore you to apply the precautionary principle rigorously and prioritize children’s health over industry convenience.
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