CFA joined the Center for Science in the Public Interest and Environmental Defense Fund in submitting comments on a Food and Drug Administration draft guidance related to “generally recognized as safe” or “GRAS” loophole. Under GRAS, several thousand ingredients have been allowed to be added to food or food packaging based solely on a company’s own determination of safety, without any government or public oversight. The FDA guidance is intended to reduce bias, minimize conflicts of interest and “appearance issues,” ensure balance, and otherwise improve the credibility, reliability, and transparency of expert panels used in making determinations that an ingredient is “GRAS.” However, the guidance is largely unenforceable because companies have no obligation to notify FDA of when they make a GRAS determinations, and can and often do keep those determinations a secret.

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