The FDA assesses the safety of food additives through a cumbersome, lengthy process. However, ingredients that are generally recognized as safe, or GRAS, are exempt, meaning a shorter, easier path to putting GRAS products on the market. Who decides which ingredients qualify for GRAS status? Basically, the corporations that stand to gain from the expedited approval.
The FDA delegates the task of determining GRAS to trade groups that work directly for the food companies. One of the most prolific is the Flavor and Extract Manufacturers Association (FEMA). The members of this flavoring trade association include the biggest names in food production, such as Campbell Soup, Cargill, ConAgra, General Mills, Kellogg, Kraft, Nestlé and PepsiCo. In return for a hefty fee, these food and flavoring manufacturers can submit their products to the FEMA GRASTM program for certification. FEMA claims its GRAS Expert Panel is unbiased and independent.
Could this trade organization possibly issue unbiased, independent assessments of its member’s products? Well, let’s put it this way, would you hire a company that repeatedly undermined your business? I sure wouldn’t. I wouldn’t pay a reviewer to pan my writing and I wouldn’t retain a lawyer to negotiate for the other side. Likewise, I doubt Ocean Spray would hire a company that issued profit-zapping analyses of its products.
In fact, FEMA’s mission statement and critical objectives clearly state that the organization’s sole purpose is to act in its members’ best interests. The consumers’ and public’s interests are never mentioned. As a benefit of joining, the Flavor and Extract Manufacturers Association “serve[s] as an effective advocate for FEMA members by representing industry interests before domestic and global legislative, regulatory, and other bodies.” How can an organization both advocate for its members and act contrary to a member’s interests? The answer is, it can’t, at least not for long before it goes under.
FEMA’s success is directly tied to the profitability of its members’ products. Membership dues are charged on a sliding scale based upon the value of total annual sales of all a company’s flavor ingredients manufactured or sold in the United States. So, the more a company makes the more money FEMA earns in dues. The incentive is to help its members sell as much flavoring as possible and not to temper their earning potential with negative assessments. After spending millions on R&D, a negative GRAS assessment would be costly to both the member and to the Flavor and Extract Manufacturers Association.
Flavor and Extract Manufacturers Association won’t bite the hand that feeds it. So, GRAS determinations belong in the hands of a more neutral party that truly has the public interests at heart.