Generally recognized as safe and effective
Generally Recognized as Safe and Effective (GRASE) is a designation used by the United States Food and Drug Administration (FDA) to indicate that a chemical compound or substance added to food or used in medicinal products is considered safe by experts, and therefore is exempted from the usual Federal Food, Drug, and Cosmetic Act (FFDCA) food additive tolerance requirements. GRASE status is a critical concept in the regulation of food additives, dietary supplements, and drugs in the United States.
Overview
The GRASE designation is based on a substance's history of safe use in food or its safety established through scientific procedures. For a substance to be considered GRASE, there must be a consensus among qualified experts that the substance is safe under the conditions of its intended use. The FDA uses GRASE status to allow the use of certain substances without the need for a pre-market review and approval process that is typically required for food additives.
Criteria for GRASE Status
For a substance to be deemed GRASE, it must meet several criteria:
- Scientific Evidence: There must be sufficient scientific data and information to establish safety.
- Expert Consensus: The safety determination must be based on a consensus among qualified experts.
- Intended Conditions of Use: The substance is safe under the intended conditions of use, including the amount used and the type of food it is used in.
Categories of GRASE Substances
GRASE substances can be categorized into two groups:
- Direct Food Additives: These are substances added directly to food to affect its characteristics, such as preservatives, flavorings, and colorings.
- Indirect Food Additives: These include substances that may come into contact with food as part of packaging or processing equipment but are not intended to be added directly to food.
Regulatory Process
The process for determining GRASE status involves the submission of a GRASE affirmation petition by manufacturers or other interested parties to the FDA. The petition must include all relevant scientific data and information supporting the substance's safety. The FDA reviews the petition and determines whether the substance can be considered GRASE under the intended conditions of use.
Controversies and Challenges
The GRASE designation has faced challenges and controversies, particularly regarding the adequacy of safety evidence for some substances. Critics argue that the reliance on industry-provided data and the lack of post-market safety monitoring for GRASE substances can lead to public health risks. In response, the FDA has taken steps to reevaluate the safety of certain GRASE substances and update its regulatory policies.
Conclusion
The GRASE designation plays a crucial role in the regulation of food additives and drugs in the United States, allowing for the efficient introduction of safe substances into the market. However, ongoing scrutiny and regulatory updates are essential to ensure that GRASE substances continue to meet safety standards that protect public health.
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Contributors: Prab R. Tumpati, MD