Toxicological Principles for the Safety Assessment of Food Ingredients; Public Meeting on Updates and Safety and Risk Assessment Considerations

Please see attached PDF. Dear Sir or Madam: As the voice of more than 300 leading food, beverage and consumer product companies, the Grocery Manufacturers Association (GMA) appreciates the opportunity to provide data and information in response to the Food and Drug Administrations (FDAs) thoughtful questions raised in the Toxicological Principles for the Safety Assessment of Food Ingredients; Public Meeting on Updates and Safety and Risk Assessment Considerations; Request for Comments published on October 30, 2014. GMA continues to support the FDAs efforts to revise and modernize the Redbook as it remains a valuable tool in developing safety assessments. GMA and our members believe that the Redbook provides sound guidance for assessing food ingredients and looks forward to working with the agency to enhance the Redbook which has always been based on sound scientific principles. We applaud the agency for holding an open and transparent process in soliciting feedback. Because of the strength of the scientific approach and principles currently included in the Redbook, the opportunity to enhance the Redbook guidance through this transparent process will only benefit the public and private sector users of the Redbook. GMA values the opportunity to provide the agency with comments that underscore 1) the need to have toxicological testing procedures to be consistent and harmonized with recognized standards such as those adopted by other agencies, countries, and international organizations; 2) the value of the development of alternative testing methodologies which allow for rapid and efficient data output along with reduced animal testing and, as well as the importance of the validation of these methods if they are to be used to make regulatory; 3) for the importance of transparency of chemical safety assessments. GMA appreciates and looks forward to working with FDAs Center for Food Safety and Applied Nutrition to enhance this valuable scientific tool. Sincerely, Emilia Lonardo, PhD Vice President, Consumer Product Safety & Science Policy Science and Regulatory Affairs Grocery Manufacturers Association