A few non-dietary studies have reported adverse effects in the gastrointestinal tract of laboratory animals given food-grade TiO₂. However, these same effects were not seen when the same or higher doses of food-grade TiO₂ were administered in the animals' diet. Dietary studies best reflect how humans are exposed to TiO₂ from food. Thus, the Food Directorate placed the most emphasis on the results of these studies in the state of the science report.

What titanium dioxide is really emblematic of ... is the failure of FDA to look back at these old decisions and ask whether its decisions that were made in this case ... 56 years ago (in the 1966 approval) still hold up, he said.