FDA Salt Statement Leaves a “Mistaken Impression”

Some 80 years ago this month, Mahatma Gandhi led tens of thousands on a 240-mile march in protest against a British salt tax, inciting millions to engage in widespread acts of civil disobedience.  In a seemingly unintentional display of historic irony, the Food and Drug Administration made national headlines on April 20th for its efforts to forcibly restrict the amount of salt that can be added to processed foods.  The Washington Post was among the first to pick up the story, and was subsequently chastised for its efforts in a statement from the FDA, released later that day.  The FDA accused the Washington Post story of “[leaving] a mistaken impression” in the minds of readers.  But examination of the facts shows that The Washington Post got it right, and that it is the FDA statement itself which leaves the mistaken impression.

The event that triggered media interest was the release of a report by the Institute of Medicine urging the FDA to revoke salt’s GRAS (Generally Recognized As Safe) classification, thereby granting regulators the legal framework needed to mandate acceptable levels of salt for processed foods.

The Washington Post responded to the release by reporting that the FDA’s plans to clamp down on salt were already underway and that the initiative would be launched later this year, citing FDA insiders who spoke only on the condition of anonymity.  Within hours, the FDA responded with a statement that the Washington Post article leads readers to believe that the FDA “has begun the process of regulating the amount of sodium in foods.”  The statement went on to assert that “[t]he FDA is not currently working on regulations… to regulate sodium content in foods at this time.”

While it is true that the FDA has made no official announcements regarding their stance on salt regulation, the claims that they have not begun the process and are not currently working on it are demonstrably false.

For 30 years, the FDA had largely ignored calls to reclassify salt, voiced by groups such as the Center for Science in the Public Interest.  That all changed in October of 2007 when, in an abrupt about-face, the FDA announced in the Federal Register that they would hold a public hearing to consider a change in the regulatory status of salt.  The hearing was conducted that November, and the public comment period was closed in August of 2008.  Just a few weeks later, the IOM kicked off a 21 month project titled “Strategies to Reduce Sodium Intake”—a project sponsored by the FDA.  This project would ultimately lead to the creation of the recent IOM report, also FDA sponsored.

Over the course of 2009, 14 meetings and phone conferences were held discussing the project.  All but the first two of these meetings were entirely closed to the public.

At the first meeting, a representative of the FDA itself made a presentation explicitly discussing the regulatory status of salt, as well as its history as a GRAS substance.  The second meeting included a presentation addressing the legality of a reclassification of salt—concluding that the FDA has “ample legal authority” to do so—and one discussing how low salt reduction levels could be set.

But what of the science underwriting this new FDA push?  Also included in the first meeting was a presentation by the Department of Health and Human Services stating that “100% of adults exceed the [adequate intake] of 1,500 mg sodium/day”.  Presented with such a statistic, certain questions spring to mind.  For instance, if 100% of adults eat more than 1,500mg of salt, what research could possibly have been conducted that would lead them to conclude that 1,500mg is adequate?  One might assume that such research was conducted on residents of other countries, but the reality is that the average American consumes about 9% less salt than the worldwide average.

The only places in the world where you might find a significant population who eat so little salt are in countries so poor that people don’t have reliable access to food at all. In such a place, one might indeed find low rates of hypertension-related illness, but only because those who live under such tragic circumstances don’t enjoy the luxury of living to the age where high blood pressure starts to become a concern.

Decades of research, encompassing multiple lines of evidence, have shown that our bodies naturally self-regulate salt intake.  Not unlike the feeling of thirst we experience when we need more water, our bodies send us queues—though more subtle than thirst—that lead us to unconsciously adjust our diets to meet our salt requirements.  One recent study by nutritionists at the University of California at Davis examined data collected from over 19,000 individuals across 33 countries to find that the normal range of salt consumption is 2,700-4,900mg per day.  The study went on to conclude that, because of our natural ability to regulate salt intake, it is “unlikely to be malleable by public policy initiatives, no matter how well intended.”

A study conducted 12 years earlier coincides with these findings, concluding that most people are simply unable to reduce their consumption below about 2,700mg per day, even when receiving regular dietary counseling and instruction.  A third study, conducted the same year, demonstrates that people will unconsciously increase or decrease their dietary salt intake to stay within the normal range, even when they don’t know how much salt is in their food.  Neuroscientists have even successfully identified the specific neurological mechanism by which this unconscious salt-regulation occurs.

Grossly out of step with the current scientific understanding, the FDA clearly has begun the process of regulating the amount of sodium in foods, and has been working on it for several years.  Between the hearing in 2007, their sponsorship of—and participation in—the 21 month project specifically aimed at reclassifying salt, and their sponsorship of the report itself, there is little more that the FDA could have done to expedite the process.

It is true that the FDA has not yet formally proposed a rule, but that is the obvious next step on the new path it’s been taking for the past few years.

It is an outrage that the FDA would deign to censure The Washington Post for publishing an article informing readers about the shape of things to come.  Far from leaving a “mistaken impression”, The Washington Post’s article hit the nail squarely on the head.  If a mistaken impression is to be had, then readers need look no further than the FDA’s own statement.  And why would the FDA go to such lengths to deny that which is both obvious and confirmed by insiders?  It’s a safe bet that they want the unveiling of their plans to be timed just right, as whatever they are about to drop on us is bound to be damned unpalatable.