Science and Safety Behind Caffeinated Flour

While I am all for food science innovation, I am extremely cautious to with anything that makes it harder for one to keep track of how much caffeine they’ve consumed. Yes, I know there’s an app for that. But in a world that both loves coffee and loves to talk about the “dangers of energy drinks”, coffee flour warrants some concern.

An article in FWx discusses new caffeinated flour which can provide 100 mg (aka more than an 8 oz Red Bull) per 4 g flour. The innovation implications are enormous, and wonderful — a product developer’s dream come true! For caffeine and carb lovers, this innovation is the greatest thing since sliced bread! HOWEVER, the application can easily cause problems for those who do love all things caffeine (and/or carbs).

What if someone uses the new caffeinated peanut butter on their caffeinated toast? What if they then wash it down with a large cup of coffee or tea (caffeine amounts vary) or even just something made with green tea extract (such as a V8 V-fusion: 80mg caffeine from green tea extract)?

The European Food Safety Authority confirmed that up to 200 mg caffeine can be consumed per sitting, and 400 mg caffeine is the maximum daily dosage that is safe for healthy adults (anyone under 18 should stick to 100 mg, unless you’re Canadian then it’s just anyone under 14). How easy will it be for one too many (caffeinated) bagels or bear-claws to put someone past the point of safe caffeine consumption?

This innovation should be celebrated, with caution. Let us take this opportunity to revisit caffeine safety and how energy drinks aren’t the only “danger” for over-consumption.




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Dietary Guidelines Advisory Committee Addresses Caffeine and Energy Drinks

Energy drinks are in the news again, but it’s not for any new reason. Too much caffeine is not good for anyone, but that you already knew. With the new Dietary Guidelines proposed by the DGAC comes a renewed warning that energy drinks can be dangerous. But is the DGAC focusing on the right message? Yes, and no.

First, some background on caffeine and energy drink consumption

A massive study published in 2014 showed that 85% of the American population consumes at least one caffeinated beverage per day, but only 10% of that group gets their caffeine from energy drinks. In this study, teenagers and young adults are the biggest proportion of energy drink consumers, but still, less than 10% of tweens, teens and young adults get their caffeine from this source (about 70% get their caffeine from carbonated soft drinks). Teens who use energy drinks consume on average 60 mg caffeine per day, which is under the 100mg limit for adolescents proposed by the American Academy of Pediatrics. For age groups 6-12 and 18-24 there weren’t enough energy drink consumers to calculate intake averages, but the total amount of caffeine (from all sources) consumed by those under 18 is still under this 100mg limit. — read the rest of the recap on this massive study here: “Caffeine Consumption in the USA”

The DGAC got it right when they said…

The committee said moderate coffee consumption may be incorporated into a healthy diet, but high caffeine intake, or greater than 400 mg per day for adults, may occur with the rapid consumption of large-size energy drinks.

The D.G.A.C. recommended limited or no consumption of high caffeine drinks, or other products with high amounts of caffeine, for children and adolescents. The committee said energy drinks should not be consumed with alcohol.
—-Excerpted from the Food Business News article, “DGAC puts energy drinks back in the spotlight”

The DGAC echoes the recommendations of the First International Energy Drinks Conference at Deakin University, Burwood, Victoria, Australia. That committee recommended the following:

From "D.G.A.C. puts energy drinks back in the spotlight" by Keith Nunes
From “D.G.A.C. puts energy drinks back in the spotlight” by Keith Nunes

Lingering concerns

I fervently agree with the DGAC committee and the recommendations of the First International Energy Drinks Conference: mixing caffeine (from any source) and alcohol is a bad idea. Caffeine Informer has already summarized all the reasons why this combo is bad (see here). So let’s discuss the gray areas instead.

Many conclude that the energy drink situation is a result of regulatory failure, and that more laws and bans are the answer. Some legislators have already tried that, but as I’ve pointed out in previous posts, this strategy has a low success rate.

The problem lies in the sheer variety of products marketed as an “energy drink”. Some of these don’t even have caffeine — vitamin B12 is the most popular energy drink ingredient.  (See “Ten Things No One is Telling You About Energy Drinks”)

As I commented on the Food Business News article:

While I agree with the Key Policy Changes outlined above, it’s important to note that the top-selling energy drink is Red Bull, which features 80mg caffeine per 8oz can. the next top selling, Monster and Rockstar have not more than 240mg per can. YES, the Super-Sized cans are disconcerting, but more energy and focus (pun intended) should be placed on the combination of caffeine and alcohol than on demonizing a particular brand. Furthermore, when popular coffee drinks include more caffeine than popular energy drinks, an energy drink ban for minors seems illogical. Too much caffeine is too much, regardless of whether it comes in a cup, mug or can.



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Why Pure Caffeine SHOULD BE Banned

According to an article by Nutritional Outlook, six senators are urging the FDA to immediately ban the marketing and retail sale of pure caffeine. This is the FIRST caffeine regulation I can really get behind, and here’s why:

This proposal addresses a legitimate safety issue; unlike some of the proposed energy drink bans, regulations to ban the sale of pure caffeine are a necessary step toward ensuring safe caffeine consumption.

Now, before you jump up and down with all the reasons you think energy drink bans are good, let me just say this: V8 V-Fusion has 80 mg of caffeine from green tea. This is an energy drink, but would you have a problem letting a 12 year old drink it? V8’s energy drink has the same amount of caffeine as an 8 ounce Red Bull, but they both that LESS CAFFEINE (and potentially less sugar) than a tall mocha from Starbucks.

The rest of my arguments against energy drink regulations can be found here (“Why You Could Get Carded for Buying a V8“), here (“NY Bans Marketing of Red Bull but Misses the Bull’s Eye“),  and here (“Save Lives by Focusing on the Source of the Problem“).

Senator Blumenthal (D-CT) is one of the six senators proposing this pure caffeine ban, and I have NOT been a fan of his other caffeine regulation proposals (see “Which comes first: supplement safety laws or the power to enforce them? The Durbin-Blumenthal Dietary Supplement Labeling Act“).

But for this one time, I will stand with the Senator and support this pure caffeine ban.

Perhaps the best argument FOR this proposed ban on pure caffeine sales is the following stat:

A single teaspoon of pure caffeine is roughly the same amount of caffeine as 25 cups of coffee, according to FDA.


No consumer needs pure caffeine. If you’re buying pure caffeine to make your own energy drinks in your basement so you can sell them online, I am not okay with that. As a food scientist quality assurance professional, and caffeine consumer, everything about that situation scares me.

Dear FDA, I know you’re under-staffed, under-appreciated and over-worked, and I know you’ve got your hands full with the necessary FSMA regulations. But can you do us all a favor and please, please, do something (swift) about this request. It’ll make Mr. Richard Blumenthal (and Mr. Sherrod Brown) very happy.


Related Posts:

Putting Caffeine in Gum is a BAD IDEA, here’s why…

Friends with the Monster? Three Crucial Counterpoints to the Energy Drink Debate

Which comes first: supplement safety laws or the power to enforce them? The Durbin-Blumenthal Dietary Supplement Labeling Act

US Senators Dick Durbin (D-IL) and Richard Blumenthal (D-CT) recently introduced the Durbin-Blumenthal Dietary Supplement Labeling Act. This legislation is intended to protect consumers from dangerous supplements by imposing new requirements on supplement manufacturers. While the intentions of this legislation are noble, there are fatal flaws that will prevent this bill from accomplishing any of its goals.  
There are 4 main objectives of the bill, and what follows is the corresponding 4 reasons why this bill won’t work:
The 4 Objectives of the D-B Supplement Labeling Bill (scroll to the bottom of the page)

Requirement #1: Allowing FDA to track how many dietary supplements are on the market and what ingredients they contain. 
Flaw #1: A registration requirement is only as effective as the person/people reviewing the submissions.
The proposed legislation would require dietary supplement manufacturers to register their products with the FDA and to provide a copy of the label as well as information on its ingredients (to prove safety and efficacy).
Theoretically, that would curtail the number of products that are absolute poppycock, with no scientific basis whatsoever. Example: Deer Antler pills (no, this is not a joke).

In reality, it will take a live human being to read through all the paperwork (electronic or hard copy) of all the dietary supplement registration/submissions. And if said FDA Agent finds something bogus, won’t it require another human being (or multiple people) to call or visit this dietary supplement manufacturer and deliver the warning letter or Cease and Desist notification? 
With human resources and manpower already stretched thin, how will the FDA accomplish any of the supplement review goals stipulated in this bill?

Requirement #2: Requiring more information on product labels including warnings associated with specific ingredients.
Flaw #2: This requirement means supplement manufacturers would have to put warnings on the label to call out the hazards for specific ingredients that may cause adverse events for any particular groups. Hmmm, now that sounds like a fantastic idea…but does this sound familiar to anyone else?

Furthermore, the Council for Responsible Nutrition brought up an excellent point in their official response to the proposed bill. As Steve Mister, President and CEO, CRN said in the statement, 

We cannot support legislation that directs FDA to require warning labels for products or ingredients that ‘could cause’ adverse events or potential risks as this is a case of the precautionary principle run amok. While the premise may be well intentioned, in practice this requirement would lead to confusing and unnecessary label instructions likely to deter consumers from using beneficial dietary supplements based on uncommon or miniscule risks. Further, a new law is unnecessary because the Dietary Supplement Health & Education Act (DSHEA) already provides FDA with the authority to mandate warning labels if the agency determines there is an unreasonable risk of injury or illness under the conditions of use provided in the labeling. Other provisions of the legislation likewise create burdensome new mandates for manufacturers who are already complying with DSHEA without addressing the industry’s outliers.     
Requirement #3: Giving FDA the authority to require manufacturers to provide proof for any potential health benefit claims
Flaw #3: Current law already requires a supplement manufacturer to notify the FDA about their structure/function claims (meaning claims that an ingredient with a particular structure elicits a particular function – ex. Calcium builds strong bones). 
One point for the bill: According to this article by Natural Product Insider, a government report has indicated that the FDA needs more authority to compel a manufacturer to submit these kind of documents to prove their structure/function claims. 
HOWEVER: When the FDA is granted more authority to monitor these claims, the argument of Insufficient Manpower comes up again. What good is having the authority to monitor and request these documents if there aren’t actual people and hours to devote to this task? It would be a tough call to have to decide whether to put FDA’s resources toward monitoring supplement claims and monitoring imported foods and resolving food outbreaks (Remember the Cantaloupe Crisis? The Deadly Peanut Butter Salmonella outbreak?)  FDA Resources Spread Thin in Enforcing Food Safety
Furthermore, the FDA and Federal Trade Commission is already responsible for monitoring labels that are misleading. Warning Letters – see how many are due to “misbranding” 
Requirement #4: Directing the FDA to clarify the distinction between dietary supplements and food and beverage products with additives. 
Flaw #4: Beverages are not inherently safer than supplements. 
It’s no secret that Senators Durbin and Blumenthal are anti-energy drinks. 
Oddly enough, one of the biggest complaints against energy drinks is that they are beverages masquerading as supplements. Supposedly, that makes them less accountable for ensuring product safety. As laid out clearly in this article by The Hill Regulation Blog:
“Energy drinks are marketed as dietary supplements instead of beverages, leading them to be regulated more laxly, Senate Democratic Whip Dick Durbin (Ill.) said.” 

HOWEVER, as food/beverage/supplement industry lawyer Justin J. Prochnow explains in this interview from BevNet Live, (starting around 3 minute mark) switching from a supplement to a beverage doesn’t mean the product is safer. It means the product has to abide by a different set of rules (What? Supplements have regulations? Yes, and this is the #1 myth regarding supplements because indeed, they DO have regulations to abide by). 

Monster energy, Red Bull and Rockstar are now all marketed as beverages (actually, Red Bull has ALWAYS been marketed as a beverage). Does that mean these products are any less likely to harm someone who consumes too many energy drinks in one day or consumes just one energy drink too fast (meaning consuming over 200mg caffeine under 20minutes)? No. 
The bottom line is regardless of whether the product is marketed as a food/beverage/supplement, there are multiple other factors that determine its safety. 
BOTTOM LINE: Those in the supplement AND food industry know safety is multi-factorial. Hygiene, pest control, ingredient contamination and adulteration – all these factors and many more affect how safe a product truly is. In a world where a supplement or food company can easily falsify a piece of paper stating the composition of their product, the answer is NOT to require companies to file more paperwork. The answer is not to give the FDA and other governing bodies the authority to monitor that paperwork, but to give them the resources (money, manpower, hours, grassroots support etc) to enforce the laws and regulations already in existence. 

Impact of AMA’s proposed ban on Energy Drinks for Minors

The American Medical Association has come out in support of a ban on energy drink sales to those under age 18. While it’s true minors and adolescents are more sensitive to caffeine than most adults, I, personally, wish the AMA would recommend the regulations Canada has put in place to address caffeine safety. As someone who’s studied caffeine and energy drinks for years, I see a large gap in AMA’s proposal which would fail to help keep minors safe from caffeine.

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