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Infant Formula: Evaluating the Safety of New Ingredients
CURRENT REGULATORY GUIDELINES FOR CLINICAL STUDIES
Canada’s Food and Drug Regulations
There are no specific requirements for clinical testing of infant formulas set out under Canada’s Food and Drug Regulations in Division 16 (Food Additives), Division 25 (Infant Formula), or Division 28 (Novel Foods) (Canada, 2001). Division 25 of the Regulations requires that a premarket submission with respect to a new infant formula or an infant formula that has undergone a major change in composition, manufacturing, or packaging include the evidence relied on to establish that the infant formula is nutritionally adequate to promote acceptable growth and development in infants when consumed in accordance with the directions for use. Divisions 16 and 28 require that data be submitted to Health Canada that include information used to establish the safety of a food additive or a novel food, respectively. Health Canada refers manufacturers to internationally accepted guidelines for clinical testing or asks to be consulted because decisions are made on a case-by-case basis.
Sections 409 and 412 of the Federal Food, Drug and Cosmetic Act
There are no explicit requirements for clinical testing of infant formulas specified under Section 409 of the Food, Drug and Cosmetic (FD&C) Act. Section 409 stipulates that a petition to establish safety of a food additive shall contain “all relevant data bearing on the physical or other technical effect such additive is intended to produce …,” but it does not dictate a specific type of clinical study.
Current regulations for infant formulas under Section 412 of the FD&C Act do not define quality factor requirements, such as physical growth, but only describe required nutrient levels, without considering bioavailability. This gap is addressed in a proposed rule (FDA, 1996), where assessment of physical growth, using anthropometry, is proposed “as an integrative indicator of net overall nutritional quality of the formula.” The proposed rule further states, “as the science evolves, FDA anticipates being able to progress beyond generalized, nonspecific indicators of overall nutritional intakes (e.g., measures of physical growth) to more specific and sensitive measures of biochemical and functional nutritional status” (FDA, 1996, P. 36181). Thus neither the current nor the proposed rules identify specific requirements for other clinical studies.
FDA does not require petitioners to conduct human clinical studies to support the safety of food additives or color additives used in food, but, if deemed necessary, it recommends that the studies conform to guidelines presented in section VI.A. of the Redbook (OFAS, 2001, 2003). These guidelines are comprehensive and relevant for the clinical testing of ingredients new to infant formulas.
General guidance is provided to identify the scientific and ethical principles for clinical studies, including the need for presentation of a defensible rationale for human studies. The Redbook states that this rationale should be based on:
adequate preclinical investigations,
results of clinical studies conducted elsewhere,
consideration of the organs and organ systems that may be affected, and