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GRAS Comment

Re: Substances Generally Recognized as Safe (GRAS)

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The Center for Science in the Public Interest (CSPI), Consumers Union, Environmental Working Group (EWG), and Natural Resources Defense Council (NRDC) present this comment regarding the Food and Drug Administration’s (FDA) 1997 and 2010 proposals to use a voluntary notification process to designate a substance intended for use in food for humans or animals as “generally recognized as safe” (GRAS). The 1997 proposal is an invalid interpretation of the Food Additives Amendment of 1958 (FAA). To achieve its congressionally intended purpose of protecting the public from unsafe chemical additives and come into compliance with the FAA, FDA has an affirmative obligation to fix its proposal.

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