The cognitive biases preventing Health Canada from making changes to Red 3/Erythrosine even after the FDA did

In the coming years, America will no longer have food dye in their food supply. They didn't outright ban it, because enforcement and an outright ban is costly and timely. But they highly encouraged manufacturers to stop using it, and this method is working. 

This will eventually trickle down to Canada, but as an adovocate, I wanted to better understand Health Canada's inaction. 

Health Canada's stance from day one appears to simply hold firm to their position, and make no changes. The dozens of people making these decisions have worked at Health Canada for up to 20 years. Here's how their biases are preventing them from action. 

Status Quo Bias: This is the tendency to prefer things to remain the same. For a regulator, changing a longstanding safety decision requires immense effort, can create market disruptions, and opens the agency to criticism, making the "no-change" path far more comfortable

Sunk Cost Fallacy: This occurs when past investments unduly influence future decisions, even if staying the course is illogical. Regulators who have defended a dye's safety for 20 years may feel a powerful sense of ownership, making it difficult to acknowledge new evidence that could invalidate their prior work.

Confirmation Bias: This is the universal human tendency to seek out and favor information that confirms pre-existing beliefs. An official who believes a dye is safe may unconsciously prioritize studies supporting safety while scrutinizing negative studies for methodological flaws. Research confirms this bias is present among government risk expert.

Overconfidence/Illusion of Competence: Experts can overestimate their understanding of a system, believing they know more than they do. If a 20-year veteran believes they have a complete grasp of how a dye affects the body, they may be resistant to new, paradigm-shifting science that reveals previously unknown mechanisms of harm

What can we do?

Mandate periodic, independent review
Shift from an "unless we find a problem" approach to a system where all additives are formally re-evaluated every 5-10 years. This normalizes the review process, reduces the sting of change, and fights the status quo bias. This aligns with Health Canada's own risk assessment framework, which includes re-evaluating products based on new science.

Formalize "debiasing" training
Implement regular, mandatory training for risk assessors and policymakers that teaches them to recognize cognitive biases like confirmation and overconfidence. Research confirms such training reduces bias among experts.

When we examine Health Canada's public statements, the fingerprints of some of these biases can be seen.

Status Quo
Canada lists Red 40 and Yellow 5 as permitted but sets its own maximum levels. While touted as science-based, this incremental approach has a clear bias toward maintaining the status quo rather than a wholesale re-evaluation based on emerging concerns.

Confirmation Bias
Health Canada states that after reviewing publications on neurobehavioral effects, the "evidence presented was insufficient". The absence of certainty is the eternal shield of confirmation bias. While it's a valid scientific stance, it's also a perfect justification for inaction.

Inaction as Action
When asked in 2025 about the FDA's ban of Red 3, Health Canada’s response that the dye poses "no human risk in Canada" at current levels is a classic case where not banning becomes the deliberate "action". This decision is itself a powerful action requiring just as much justification as a ban.

As a food dye activist, I've tried all of the standard attempts at getting through my experience to the powers that be at Health Canada. They've disregarded my experience in favour of poorly executed scientific studies. I am not the only Canadian parent who has written them letters. I am currently awaiting a FOIP request result detailing the amount of feedback they've received from everyday Canadians in regards to food dye. Because all knowledge, is critical to enhancing science-informed decision making. 

We are at a point where their cognitive biases are affecting their work, and I must insist their department re-examine their approach to evaluating chemical additives.