In an April report issued by the Natural Resources Defense Council ("NRDC"), the environmental and public health organization calls on FDA to address a "GRAS loophole," referring to an issue that arises when a company withdraws a GRAS notice to avoid further review of its self-determination that an ingredient it uses in food is GRAS, short for "generally recognized as safe." In such cases, FDA does not publicly disclose any concerns that could have prompted the company's withdrawal. Moreover, this withdrawal does not prevent the company from marketing the product for use in food. NRDC estimates that about 10 percent of food additives are based upon undisclosed GRAS determinations and urges FDA to require that companies inform the agency of determinations, publish safety concerns even when a company withdraws a notice, and limit conflicts of interest that arise when a company conducts its own safety determinations.
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