The Value of GRAS

December 9, 2010

The Washington Legal Foundation recently published an article written by HPM attorneys, Ricardo Carvajal and Nisha P. Shah, on the February 2010 Government Accountability Office ("GAO") report that criticized FDA's general oversight of uses of ingredients that are generally recognized as safe (“GRAS”) and the agency's voluntary GRAS notification program.  The GAO report identified several gaps in FDA’s current approach, and recommended tighter oversight of industry GRAS determinations.  However, the GAO gave short shrift to the drain on resources that would result from implementation of its recommendations, and failed to acknowledge the GRAS regime’s important role in fostering innovation in the food supply.