all net sales (Monsanto 1994) and Canada's population is 10.8% of the U.S. population (CIA 1994). Therefore, Canada's intake of aspartame per person cannot possibly be even equal to that in the U.S., even in the extremely unlikely scenerio where all aspartame sold outside the U.S. is sold only to Canada. (Note: The percentage of regular aspartame users in the United States and Canada are approximately the same if you believe information provided by NutraSweet (Farber 1989, page 56, Butchko 1991). Another preposturous claim can be seen in a paper by Butchko (1991). In this paper aspartame consumption for 6-12 year old children was shown to decrease significantly from 1984 (the year after aspartame was approved for use in carbonated beverages) to 1989 despite nearly tripling the sales of aspartame from the middle of 1984 to 1989. (USDA 1988, Monsanto 1990). By the time this survey began the percentage of regular aspartame eaters in this age category was approximately 25% (Abrams 1991). Therefore, an increase in the percentage of regular aspartame users could not have possibly accounted for the bulk of the increase in sales. Who are they kidding!? It shows that these surveys cannot be trusted to show anything close to accurate figures. Perhaps another reason the average daily intake of aspartame from these surveys is so low is due to the way that the amount of aspartame ingested is calculated. For example, Abrams (1991) points out that what is recorded on these surveys is not the amount of aspartame ingested, but only "the number of times an APM [aspartame] containing item of food was eaten on that day by that person." This value is then multiplied by the "average number of grams per eating occasion of that food for a person of that age and sex group" to give the total number of milligrams of aspartame ingested. However, the "average number of grams per eating occasion of that food for a person of that age and sex group" is drawn from a 1977-1978 USDA National Food Consumption Survey. Therefore, the calculations for the total milligrams of aspartame ingested is based on an old survey which may be equally inaccurate as far as snack food ingestion goes and is most likely out of date. For example, these calculations assume that the average person would ingest the exact same amount of soft drink or diet food in one sitting in 1977 as they would in 1994. With the skyrocketing popularity of one- and two-liter bottles of soft drinks and the marketing push for diet foods, this is a ridiculous assumption. What the NutraSweet tries to show with flawed studies and surveys is often contradicted by other studies which they fund or by statements made by their representatives. In 1976, Frey showed that children who are 7 to 12 years old can have an aspartame intake anywhere from 35 mg/kg to 76 mg/kg per day when aspartame-containing snack food is notrestricted (Frey 1976). Three studies on obese individuals showed that their aspartame intake averaged 20 mg/kg per day (ranging from 8 to 36 mg/kg per day) (Porikos 1984). The Frey study and the three studies by Porikos monitored aspartame intake much more closely than the surveys often quoted by NutraSweet executives. Those surveys relied on the ability of people to remember their snacks. In an article from Science Times, Jane E. Brody states the following (Congressional Record 1985a, page S5494): "The drug agency has set an allowable daily intake of 50 milligrams of aspartame per kilogram of body weight, and the agency predicted that actual average use would run around eight to ten milligrams. According to Dr. Gaull of Searle, levels of use found in a national survey last spring showed that the average was then already twice that--19 milligrams--and the maximum level consumed by 'aspartame abusers' was 28 milligrams. A United States attorney representing the F.D.A. said in court last month that average consumption is now 30 milligrams and that many consumers are above the 50 milligrams maxiumum suggested." Farber gave an example of what a typical aspartame consumption may be for a child (Farber 1989): "An 8-year-old of 20 kg, might eat the following: Cereal 250.0 mg Soda 200.0 mg Milkshake 350.0 mg Ice Pop 250.0 mg Total 1,050.0 mg of aspartame "This would equal 52.5 mg/kg of aspartame consumption....' [Note that even for a 60 kg adult, the above-listed example would amount to over 17 mg/kg per day.] On a hot Summer day, the child may ingest the aspartame listed above and several more carbonated beverages. There may be many children who are ingesting a full 2-liter bottle of pop during an active Summer day (1100 mgs. of aspartame). On top of that ingestion, there may be Jello, cereal, gum, and many other aspartame-containing foods. It is important to note that all aspartame-containing products of the same type do not contain the same amount of aspartame. For example, a one liter bottle of diet cola averages aproximately 560 mg of aspartame. However, orange soda contains as much as 930 mg of aspartame per liter (Federal Register 1984). Neuroscience researcher and Professor of Medicine at the University of California, Dr. William Partridge testified about the intake of aspartame before the U.S. Senate (US Senate 1987, page 367): "The first question is the dosage problem. We are led to believe by the FDA this morning that the typical consumer will have 2 to 4 milligrams per kilogram of aspartame per day; that the 99th percentile intake is 34 milligrams per kilograms per day; and that the advisable daily intake or ADI is 50 milligrams per kilogram per day. "Now, the layperson sitting in the audience is really in no position to analyze these esoteric numbers. But if we put it in a different context and recognize that 50 milligrams per kilogram per day is equal to 5 servings of NutraSweet per 50- pound body weight, we can see that children, owing to their reduced body weight, are at a great risk for overconsumption of NutraSweet. "All one has to do in t his room is look up at that chart and ask yourself if a 50-pound or 60- pound 7 year-old is going to consume 5 or 6 servings of that per day. If they are, then they have consumed 50 milligrams per kilogram per day, or the advisable daily intake. "Now, an 11-year[-old] study in the literature has already shown this, that the average 7-to-12-year- old, when made freely available to products like that, consumes 5 servings per 50-pound body weight per day, and up to 77 milligrams per kilogram per day." In the National Soft Drink Association's draft objection to use of aspartame in carbonated beverages it was stated (NSDA 1983): "FDA relied upon an intake value of 34 mg/kg/day in assessing the possible risks of aspartame, describing that level as the '. . . highest obtained from any estimate of potential consumption and exceed[ing] the 99th percentile consumption (25 mg/kg) for all age groups . . .' 48 Fed. Reg. at 31377. For a 30 kg child, however, it would not be unualual for that level to be achieved or, in terms of the effect on plasma PHE (phenylalanine) levels, even exceeded. For example, if a 30 kg child consumed on a warm day after exercise approximately two-thirds of a two- liter bottle of soft drink sweetened soley with aspartame, that child would be consuming 700 mg of aspartame, or approximately 23 mg/kg. This alone roughly equals what FDA considered, the 99th percentile consumption level. If during the day this child consumed other aspartame-sweetened products, the exposure level could quickly [reach] FDA's so called 'loading dose' of 34 mg/kg. 48 Fed. Reg. at 31377." Had the child in the above example consumed two-thirds of a two-liter bottle of aspartame-sweetened orange soda, the values would be as high as 1240 mg of aspartame or 41.3 mg/kg/day for a 30 kg child. What is generally agreed upon when discussing the intake amounts of aspartame is the following: The majority of aspartame users ingest a relatively small (but not necessarily safe) amount of aspartame. When plotting milligrams per day of aspartame ingested against the percentage of U.S. population, a smaller percentage of the population will ingest the largest amounts. Looking a studies I have seen in the literature as well as USDA figures for artificial sweetener usage, I would estimate that the average person who ingests aspartame regularly ingests approximately 8 mg/kg per day. However, I believe that at least 10 percent of regular aspartame users ingest at least 20 mg/kg per day. This may amount to over 8 million people in the U.S. I would estimate that at least 1 percent of aspartame users ingest at least 50 mg/kg per day. This may amount to nearly 1 million people. For most of these people, the warm and hot weather intake will far exceed their Winter intake, such that a person ingesting 20 mg/kg per day in the Winter may ingest 40 mg/kg per day in the hot Summer months. According to Dr. Woodrow Monte, Director of the Arizona State University Food Science and Nutrition Laboratory, a significant number of people in Arizona drink as much as two or three liters of diet soda every day during the Summer (Monte 1995). Even if we accept the FDA's projection that only 1% of the regular aspartame users will consume more than 34 mg/kg/day of aspartame, that still may amount to nearly 1 million people. While the national average may be lower than 34 mg/kg/day of aspartame, there are undoubtedly several hundreds of thousands of people who are consuming well over 34 mg/kg/day of aspartame, especially on hot Summer days. Some researchers try to argue that they can use much less than the current FDA Acceptable Daily Intake (ADI) in their experiments as long as they use a test dosage well above the average intake of aspartame as deterimined by these (flawed) surveys. Stegink states the following (Stegink 1989): Initial consideration of these projected intakes might lead one to question their validity since 12 oz of aspartame-sweetened beverage ingested by a 27-kg 8-year-old child would account for 7.4 mg aspartame/kg body weight. However, when beverage intake data are examined, the projected aspartame intake values are consistent with these data. For example, Morgan et al reported that 7- to 8-year- old children ingest, on average 6.0 4.2 oz soft drink daily (mean =B1 SD; value includes both regular and diet beverage) (Morgan 1985). Thus, an average 27-kg 8-year-old child would ingest 3.7 mg aspartame/kg body weight daily if all 6 oz of beverage were sweetened with aspartame. A 27-kg child ingesting beverage at 2 SD above the mean (approximately 97% of expected values) would ingest 14.4 oz of beverage. This would provide 8.9 mg aspartame/kg body weight if all beverage consumed was sweetened with aspartame. Therefore, young children would have to drink unusually large quantities of beverage to ingest much larger quantities of aspartame." What Stegink neglects to mention is the following: 1. The study cited by Stegink (Morgan 1985), does not take into account that, as Dr. Wurtman stated, snacks are commonly forgotten in daily food surveys so that the average ingestion of soft drinks would likely be much greater. 2. The study cited by Stegink uses data from a three-day survey instead of the more traditional seven-day survey making it less accurate. 3. The study cited by Stegink was published in 1985. This study was an evaluation of data from the 1977-78 Nationalwide Food Consumption Survey. Thus, the data was over ten years old when Stegink cited it and is now over 16 years old! Anyone adult in the U.S. who was not in a coma for the last 16 years knows that soft drink consumption has increased tremendously since the late 1970s. 4. Stegink neglects to mention that there are thousands of products with aspartame and that 7- to 8-year-old children can be ingesting significant amounts from foods and beverages othan than soft drinks. 5. While the average intake may be relatively low, although much higher than reported by Stegink and not necessary safe, there are undoubtedly a significant number of 7- to 8-year old children who are ingesting large quantities of aspartame by their own choice or by the choice of their parents to avoid sugar. It is ridiculous to use the "average" (even if it was accurately determined) to judge test amounts of aspartame. What should be used in experiments is double the ADI of real world aspartame (to provide a safety margin). Any argument for using less should be taken as an admission that the ADI is not a safe amount of aspartame. Conclusion ---------- NutraSweet-written survey summaries show a negligable increase in daily aspartame consumption since 1983. Aspartame sales has skyrocketed since 1983. Therefore, the numbers from these surveys which are flawed as described by Dr. Richard Wurtman above, do not make any sense and should be ignored until large, well-designed surveys are conducted separate from the influence of the NutraSweet Company. --------------------------------- BEGIN ENCLOSURE #2 --------------------------------- 4. Methanol The article states: "The presence of small amounts of methanol in aspartame has generated a lot of undue concern. Although large amounts of methanol are harmful, the very small amounts of aspartame-derived methanol are easily handled by the body. "Methanol is a common component of the diet, and is found in many fruits, vegetables, and wines. Furthermore, the amount of methanol from foods far exceeds any contribution from aspartame (Lund 1981). Aspartame-sweetened soft drinks, for example, provide 60 mg of methanol per liter as compared to fruit juices which contain 140 mg of methanol per liter. First, I will discuss how ingesting methanol from aspartame differs from ingesting methanol from alcohol, fruits and vegetables, and fruits and vegetable juices. Alcohol ------- An exhaustive literature search by Monte (1984) showed that all natural products which contain tiny amounts of methanol also contain significant amounts of ethanol. Many alcoholic beverages contain over 200 times more ethanol than methanol. The large ethanol content of alcoholic beverages has served to protect humans from methanol poisoning throughout the ages. Despite the wishful thinking of NutraSweet Company spokespersons (Sturtevant 1985), researchers agree that ethanol serves as a protective factor (Leaf 1952, Liesivuori 1991, McMartin 1980, Posner 1975, Roe 1982). Ethanol protects from methanol poisoning by preventing the conversion of methanol to toxic formic acid metabolites thus allowing methanol to be excreted through the lungs and urine (Roe 1982, Kruse 1992). Methanol poisoning is treated with ethanol (Kini 1961, Pamies 1993). Leaf (1952) showed that co- administration of methanol with ethanol immediately stopped the conversion of methanol to its toxic metabolites. Fruits and Vegetables --------------------- Fruits and vegetables do contain methyl ester as part of the pectin. However, human beings do not have digestive enzymes such as pectin esterase to release the methanol (Garrison 1990, page 16, Monte 1984). Fruits and Vegetable Juices --------------------------- When certain fruits and vegetables juices are extracted, the pectinmethylesterase enzymes demethylates some of the pectin and liberates methanol. However, the methanol content of fruit juices do not average 140 mg per liter. The NutraSweet industry has been pushing this fallicy for years even though it has been disproven. The 140 mg/liter figure was obtained from a very old conference paper presented by Francot and Geoffroy (Francot 1956). The authors of this paper state that they did not perform many of the tests and give no original sources for the work except for grape juice and black current juice. No methodology was given although it is certain that in 1956 they did not use the more accurate techniques currently used. The methanol content of fresh juices is probably dependent upon the method used to extract the juice, the type of fruit used (including species), and the time harvested. Lund (1981) showed that the methanol content of fresh orange juice had a mean of 34 mg/liter. Fresh grapefruit juice averaged 27 mg/liter in the Lund study. Sauri (1981) tested fresh orange juice and showed that it contained 33 mg/kg. Nisperos-Carriedo (1990) determined that their sample of fresh orange juice had a mean of 38 mg/liter. The Methanol content of processed juices were much less than fresh juices. Lund (1981) showed that orange juice concentrates average about 6 mg/liter of methanol. Grapefruit concentrates average about 2 mg/liter. The reconstituted juices contained no detectible methanol.Nisperos-Carriedo (1990) showed that pasteurized orange juice contained 22 mg/liter and frozen-concentrated orange juice contained 3.4 mg/liter. The most popular freshly-made juices have about one-half (or less) of the concentration of methanol than aspartame. Processed juices contain many times less methanol than aspartame and reconstituted juices contain only trace amounts of methanol. The average juice product ingested in the U.S. probably contains much less than 10 mg/liter if all types of fruits and processing is included since fresh juice is consumed by only a small segment of the population and in relatively small quantities. The high caloric content of fruit and vegetable juices as well as their osmolarity places limits on the quanity of these products ingested on a regular basis (Monte 1984). Monte (1984) shows, using U.S. Department of Agriculture survey figures that the regular juice drinker probably ingests between 1 and 7 mg of methanol per day from these sources. Aspartame, on the other hand, has a low calorie content, leading to the possibility of ingesting large quantities. In fact, in hot whether, it is not uncommon for a person to drink anywhere from 1 to 3 liters of aspartame- containg beverages every day (Monte 1995). Wurtman describes a case of a person ingested 3.5 liters of diet Coke and a nearly equal amount of diet lemonade every day (Wurtman 1985). This person was ingesting 350 mg of methanol every day! I know several people who drink well over a liter of diet beverage every day. A person ingesting two to three liters of diet orange soda on a daily basis, for example is ingesting 180 to 270 mg of methanol every day. Drinking such large amounts of freshly-pressed orange juice every day is virtually unheard of. As a matter of fact, drinking any significant quanitities of juices every day is only a very recent phenomona limited to developed countries. Fresh juices contain vitamins and minerals which can help protect cells from damage caused by methanol. Folic acid, for example, is an important nutrient which helps break down and eliminate methanol metabolites. It is common that many chemicals in foods protect us from toxic substances in those foods. Remington (1987, page 88) gives a couple of examples of toxic substances causing more damage when not co-ingested with nutrients. In one example, rats which were fasted for six days died at 1/25th the dosage of a toxic substance as compared to rats which ate a normal diet. In the other example, it was shown that giving cabbage and brussels sprouts to rats increased the hydroxylase activity by 100 fold, protecting them from aflatoxin. Diet drinks and other aspartame-containing foods rarely contain nutrients that may protect against methanol damage and often contain other unnecessary chemical additives. Finally, it is quite possible that small amounts of methanol administered as part of nutrient-rich foods is not absorbed at all or absorbed or metabolized in a differnt way. There are no experiments examining whether methanol from nutrient- rich, fresh juices is absorbed at all or in the same way as methanol from aspartame. For example, fructose has been shown to significantly slow methanol oxidation in some species when given in significant quantities (Bradford 1993). Whether this has an effect on humans ingesting small amounts of methanol with fruit juices is unknown. Certain intestinal bacteria have been shown to convert methanol or formaldehyde to acetate (Wolin 1993). It is possible that tiny amounts of methanol from fruit juices may be converted by bacteria in the human digestive tract before it can be absorbed. Some bacteria which convert methanol to acetate are known to do so many times faster in the presence of sodium (Na+) ions (Blaut 1992, Heise 1989). There is clearly a lack of independent research in the area of whether methanol is absorbed and metabolized the same way whether ingested from aspartame or from fruit juices. Since methanol toxicity is blocked by ethanol in alcoholic beverages and since other potentially toxic substances in food are rendered nontoxic when ingested as part of the whole food, it seems rather ridiculous to automatically assume that methanol from juices would be absorbed and metabolized in the same way as methanol from an artificial sweetener. The only common juice that has shown equal or greater levels of methanol has been tomato juice. Nelson (1969) showed that after extracting the juice and heating it for 30 minutes at 212oF in when enclosed in tin or enamel that the methanol content varied from 127 to 560 mg/liter. However, heating can-sealed tomato juice to extremely high temperatures without inactivating the pectinmethylesterase enzyme would likely increase the creation of methanol tremendously. This is something that is unlikely to happen in commercial or home preparation. Kazeniac (1970) found that blended tomatoes had a methanol content of between 64 and 138 mg/liter depending upon the speed of the blendor and the time blended. The same points still apply to tomato juice: 1) much less is ingested on a regular basis (especially for tomato juice), 2) commercial preparations likely have less methanol than fresh tomato juice (unless the enzymes were not inactivated and the juice was heated to high temperatures while enclosed in a can), 3) tomatos contain a wide variety of nutrients which can help protect against the toxicity of methanol metabolites, and 4) no studies have been done to see if methanol from fresh juices are absorbed or metabolized in the same way as methanol from aspartame. In fact, it would have been relatively easier for NutraSweet researchers to test tomato juice to see if it raises the blood methanol and urinary excretion of formate as does aspartame in the experiments discussed later in this section. Two to three liters of tomato juice given to a 30 kg child could contain the same amount of methanol as was shown in NutraSweet experiments to significantly increase blood methanol levels. Similar equivalent amounts could have been determined to correspond to the NutraSweet experiments which showed a significant increase in urinary formate levels. It's been almost two decades since tests relating to aspartame and methanol have been published and this obviously important experiment has not been conducted (or has been avoided). At this point, however, the experiment would have to be conducted and funded by corporate-neutral parties. In summary, juices usually contain much less methanol than aspartame. Due to the calorie content and osmolarity of juices, much less is ingested on a regular basis. Nutrients such as folic acid serve as protective factors against ingestion of methanol. There are no stuides showing that methanol from juices is absorbed similar to methanol from aspartame. References Abrams, I.J., 1992. 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