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Americans are “GRAS-fed” because of a “loophole” in the strict regime Congress provided for the regulation of food additives. Additives - and food products containing them - are exempt from this strict regime if they are accorded GRAS (Generally Recognized as Safe) status. The guidelines Congress provided for achieving that status by scientific evidence of safety are no longer observed. Most additives are determined by the producer alone to be GRAS. At the same time, Americans’ consumption of highly processed foods continues to rise, giving rise to long-term health problems that are increasingly tied to diet. The average American’s diet includes many additives, most of whose safety has never been reviewed by the Food & Drug Administration. Our GRAS-laden diet may be making us sick. This Article reexamines the GRAS exception and proposes modest changes to restore some of the rigor Congress provided.



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