Abstract

http://ssrn.com/abstract=2353837
 


 



Generally Recognized as Safe?: Analyzing Flaws in the FDA's Approach to GRAS Additives


Laurie J. Beyranevand


Vermont Law School

November 13, 2013

Vermont Law Review, Vol. 37, Book 4, 2013
Vermont Law School Research Paper No. 33-13

Abstract:     
Since the 1970s, consumers and advocates in the United States have questioned the safety of the list of substances considered “generally recognized as safe” (“GRAS”) by the Food and Drug Administration (“FDA”). Despite the directives that have pushed the agency to review and, in certain cases, reconsider the inclusion of certain substances on the list, the agency has failed to take any significant attempts at removing any substances for decades. In some instances, the agency has instead approached the issue as one that requires more consumer awareness about the inclusion of the substance in food and provided labeling information to allow the consumer to determine whether or not to purchase the product. In essence, the agency has placed the burden of ensuring safety in the hands of the purchaser. Many would suggest these efforts do not sufficiently address the underlying issues regarding the substances’ safety. This article traces the history of the GRAS provision, and considers whether the agency’s current approach to GRAS substances accurately reflects the legislative intent. Specifically, the article questions whether the agency’s current approach to removal requires a showing of general recognition of harm rather than a demonstration that there ceases to be a general recognition of safety of the substance, and discusses the practical effects of such an approach using sugar as an example.

Number of Pages in PDF File: 37

Keywords: Food and Drug Administration, FDA, generally recognized as safe, GRAS, Food Drug and Cosmetic Act, food additives, Food Additives Amendment, sugar, food, trans fats, salt

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Date posted: November 15, 2013 ; Last revised: December 2, 2013

Suggested Citation

Beyranevand, Laurie J., Generally Recognized as Safe?: Analyzing Flaws in the FDA's Approach to GRAS Additives (November 13, 2013). Vermont Law Review, Vol. 37, Book 4, 2013; Vermont Law School Research Paper No. 33-13. Available at SSRN: http://ssrn.com/abstract=2353837

Contact Information

Laurie Beyranevand (Contact Author)
Vermont Law School ( email )
164 Chelsea Street
P.O. Box 96
South Royalton, VT 05068
United States
(802)831-1030 (Phone)
HOME PAGE: http://vermontlaw.edu
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