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deliberations, the committee outlined a number of implementation approaches. However, it recognized that the level of detail needed to translate a number of the overall strategies into functioning activities was beyond its scope and undoubtedly required information that is not currently available or that needs to be collected and analyzed by specific responsible agencies mentioned in this report, by the food industry, or by other researchers. Implementers therefore will have to further explore these approaches and related options as they become apparent.

Modification to the GRAS Status of Salt

Modifying the generally recognized as safe (GRAS) status of salt will be a complicated and challenging process for the Food and Drug Administration (FDA). It will require considerable information gathering, detailed input from stakeholders, in-depth analysis of the food supply, simulation modeling of the effect of different levels of sodium on total intake, examination of consumers’ eating behaviors, adjustments for food safety concerns, and studies of economic impact and potential unintended consequences. This, in turn, will require resources and time. The following approaches at a minimum should be considered by FDA in carrying out these important activities.

Food Category Framework

As a general matter, it anticipated that the overarching goal should be to specify as GRAS the uses and use levels for salt that allow persons to consume such foods as part of a normal diet with a reasonable likelihood of keeping their total daily intake of sodium consistent with the Dietary Guidelines for Americans. However, the committee could find no rationale for establishing allowable standards of salt content as a single, across-the-board, quantitative amount of sodium applied to each food equally. Rather, the nature of the food supply suggests that the better approach is to develop standards for the levels of salt added to foods on the basis of food categories. In the United Kingdom, salt targets were set for all product categories, based on the contributions of different foods to salt intake and the feasibility of making reductions given food safety and technical considerations.1 If foods are grouped by category, the technological feasibility of reducing salt levels can be taken into account along with consumers’ taste expectations. Examination of potential sodium reductions on the basis of food categories can also help to set meaningful yet feasible targets for sodium reduction.

1

Available online: http://www.food.gov.uk/multimedia/pdfs/howsalttargetsmet.pdf (accessed November 17, 2009).



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