Drug, and Cosmetic Act to foods whose components have moved in interstate commerce, thus making the food item subject to the same standards relevant to processed foods. The implementation activities outlined for modification of the GRAS status of salt for processed foods, as well as the process for determining the modification, should apply equally to standardized restaurant/foodservice operations.

Given that sodium can be added to foods in ways other than by the addition of salt, it is important for FDA to consider these other sources of sodium, take into account their approved conditions of use and function in food, integrate their presence in the food supply into the considerations for modifying the GRAS status of salt, and adjust as necessary the GRAS or food additive provisions for these sodium-containing compounds.

Voluntary approaches cannot serve as the main focus of future strategies, but may be useful until regulatory approaches can guarantee sustainable strategies. There are questions as to the levels of success that might be achieved in the interim on a voluntary basis. But given impending regulations and heightened attention to sodium reduction, interim strategies may achieve some success and inform the regulatory process.

Although the regulatory strategies identified above should be initiated immediately, as a practical matter the process of rulemaking requires time. The committee has therefore identified voluntary strategies that could achieve some reductions in sodium intake ahead of the implementation of mandatory standards for the levels of salt added to foods. While identifying these voluntary strategies as important interim steps, the committee underscores that experience would indicate that voluntary standards have not been sufficient to provide adequate breadth and sustainability to the reductions and do not offer the level playing field that is important to realizing meaningful sodium reduction in the food supply.