Update: Wall of Silence; Removing Bricks

The critical issue is a?non-declaration in foods and drinks of isolated phenylalanine?(this is the active ingredient in neotame – a concentrated derivative of aspartame, and in advantame – a mixture of aspartame and vanillin. Aspartame itself is always declared). And this is a follow-on to my previous articles on the subject, the latest of which was?Either Side of the Wall of Silence?published August 2021. Other than key points, repetition will be kept to a minimum.?

Phrases that have become tiresome include?out of my area of expertise, not in my remit, not part of my terms of reference,?or,?it is a legal issue.?These are bricks in the wall of silence. If pushed against, others are added?it’s the subject of ongoing research, awaiting evidence …

There are facts, undisputed, and there is evidence, open to interpretation. Distinguishing between the two makes the issue a straightforward one. Once the facts are known, further expertise is not needed, just a willingness to act.

Dietetic Summary?For those with the genetic condition phenylketonuria (PKU), a strict therapeutic diet is the mainstay of treatment, instigated soon after birth. In the simplest terms, the diet will include an individual’s total, tolerable amount (that is, before neurotoxic levels are reached) of phenylalanine (phe) from?Natural Protein – to get the maximum accompanying micronutrients.?All other protein is in a synthesized form,?the phe having been removed.

?????It should be clear that for those with PKU, particularly children, there is?no?acceptable daily intake (ADI) of?isolated?phe.

It is important to note that phe never occurs ‘naturally’ on its own in food: it is widely and easily available in protein foods, but always as part of a protein, never an isolate.

Requirement?that all use of isolated phe in foods or drinks be declared, for example “contains traces of isolated phenylalanine”, or it may be possible to use an identification??symbol instead, for the benefit of those responsible for feeding children with PKU.

(It is preferable to use ‘isolated phenylalanine’ rather than trade names, such as those referred to in the first paragraph, as it would negate the need to go through the whole process again for every new version to come onto the market.)

The?Current Position?is based on a wrong premiss:?the estimated maximum exposure to phe from neotame and advantame would be a relatively small increase and not exceed the ADI.?But, I repeat,?There is NO ADI for Isolated?phe for those with PKU.

?????The stated circumstances for instigating a review, stay with that wrong assumption of an ADI, and look for an indication of a?shift in the scientific evidence base?of level of consumption.???

Here we have the crux of the matter. We already have all the undisputed facts needed for the requirement of disclosure. The so-called ‘evidence’ to be sought has no part in the issue.

Whilst not accepting the notion that a ‘shift of evidence’ is needed before action, of some interest is the report for industry on HDS – it includes neotame and advantame in its data – by ARC, pub.9/1/2018: one graph shows growth in HDS market revenue from 2016, predicted to 2022. Globally, an increase is approximately tenfold. Geographically, North America dominated in 2015, but the predicted growth is fastest in Asia-Pacific because of favourable government policies in China and India; the greatest predicted growth in Europe is the UK.

My?Latest Action?(October 2021) has been to go back to the Prime Minister Boris Johnson, saying much of what is written above. Similarly, I had gone back (August 2021) to my constituency MP, Nigel Adams. At the time of my email to Nigel Adams, he held the position of Minister for Asia, and in the light of the ARC report it seemed expedient that this issue be considered in any food trade contracts (of course it should also be a consideration in UK public contracts, for example in schools and hospitals).

(By the time of an initial reply (from a Senior Parliamentary Secretary to Nigel Adams MP), 22nd?September, there had been a ‘swap’ of positions: Amanda Milling MP is now Minister for Asia and Nigel Adams MP is now a Minister without portfolio in the Cabinet.)

I am informed that Nigel Adams is to make representations to Ministers.

It would be opportune if others could give support to those representations, or make other suitable representations to help progress the issue. Your help would be greatly appreciated.

Pamela (Theophilus) Gardner, 20th October 2021

Retired state registered dietitian, and health promotion specialist???

Footnote: The condition PKU is characterized by a deficiency in the enzyme instrumental in converting the amino acid/neurotransmitter phenylalanine (phe) into the amino acid tyrosine. As a consequence,?if untreated,?the unchanged phenylalanine crosses the blood/brain barrier and causes substantial damage to the development and function of the brain; severe mental retardation, and damage to the central nervous system. The developing brain of a child is most affected.

I should point out here that, unlike the known effects in PKU, it is not possible, ethically, to fully establish the effects of isolated phe in children without PKU. More of the mechanisms of interrelated neurological, physiological, and metabolic pathways is still to be elucidated. Although any potential damage is less likely to be as severe as in PKU, my personal view is that I would not, in normal circumstances, choose to give to any child, aspartame-containing Diet Coke, for example. And to those of a different opinion, I would suggest that they ensure the gut also contains some whole protein, which might mitigate the risk.?

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