The GRAS is always greener...

Health-minded organizations and bloggers have suggested that the FDA remove salt from the list of food ingredients that are generally regarded as safe (GRAS). Most notably, the American Medical Association jumped on the bandwagon last year. The argument goes something like this: Salt is bad for you. It can cause high blood pressure, and increase your chances of having a heart attack. And studies have linked an over-consumption of salt with everything from asthma to osteoporosis. Clearly anything that increases your chances of finding yourself at the bottom of a six foot hole is not safe, and should not be "generally regarded" as such.

Proponents of this idea do have a point, although only to a limit. Many ready-to-eat convenience foods and restaurants serve salt way in excess of the recommended daily allowance of 5.8 g. This practice is bad for the health of diners, who might otherwise be led to believe that the food they chose is healthy given a variety of common label claims (low fat, heart smart, etc.). Reducing salt intake by 50% as the American Medical Association recommends would likely contribute to better health.

However, I kind of wonder how many of these activists have actually looked into the regulations they want changed.

First and foremost, what does it mean for an ingredient to be have GRAS status? Well, it actually might be easier to say what GRAS doesn't mean. According to the FDA, "GRAS ... status does not guarantee a substance's safety."

Now that we have that out of the way, let's get down to business. In 1958, the US Congress passed a measure that divides all things added to food into four categories: food additives, prior sanctioned, generally regarded as safe, and color additives. Food additives, what activists argue salt should be classified as, must be approved by the FDA before they can be used in any amount. Substances that have GRAS status are said to have a "long, safe history of safe history of common use in food" or have been adequately demonstrated to be safe by science. GRAS substances don't need to be tested because they have been used for such a long time that the safety is taken for granted.

This sentiment is codified in law in title 21 of the Code of Federal Regulations section 182.1 ("21 CFR 182.1") where it is stated

(a) It is impracticable to list all substances that are generally recognized as safe for their intended use. However, by way of illustration, the Commissioner regards such common food ingredients as salt, pepper, vinegar, baking powder, and monosodium glutamate as safe for their intended use. This part includes additional substances that, when used for the purposes indicated, in accordance with good manufacturing practice, are regarded by the Commissioner as (generally) recognized as safe for such uses.

In struggling to define what GRAS status means, I found consolation in the fact that the FDA can't seem to define it either. At any rate, the ensuing sections provide a list of substances that are generally considered to be safe. This list includes everything from alfalfa to zedoary bark and amusingly lard and hydrogenated tallow (when contributed to food from cotton or cotton fabrics used in dry food packaging).

My main objection to the reclassification of salt is that it is not the consumption of salt that's unhealthy, it's the over consumption that results in adverse health effects. Within recommended levels, salt is absolutely essential for the human body to function. Consuming too much of nearly anything will bring you to harm, as the news story that came out today of a woman dying of water intoxication so poignantly demonstrates. If drinking too much water will kill you, so will consuming too much lactic acid or zein. And especially ethanol (the chemical that makes you drunk). So in challenging the GRAS status of good ol' sodium chloride, the entire basis of the GRAS classification is being challenged if dosage is ignored. Everything is bad for you if you consume too much of it, therefore nothing can be regarded as safe?

The bottom line is that people have been seeking out salt to eat for thousands of years. It can't be that bad for you.

If the proponents of the measure have anything going for them, it's that the FDA could do a better job of making sure that salt levels are reasonable. Indeed, the government already mandates that (21 CFR 182.1)

(b) For the purposes of this section, good manufacturing practice shall be defined to include the following restrictions:

(1) The quantity of a substance added to food does not exceed the amount reasonably required to accomplish its intended physical, nutritional, or other technical effect in food; and

(2) The quantity of a substance that becomes a component of food as a result of its use in the manufacturing, processing, or packaging of food, and which is not intended to accomplish any physical or other technical effect in the food itself, shall be reduced to the extent reasonably possible.

Well, then, the amount of any GRAS substance added to food must be the very least necessary to accomplish its function. Most fast food products probably add salt in excess of this limit. However unless otherwise stated 21 CFR only applies to the manufacture of food products, not restaurants (see 21 CFR 1.327). Then again, many prepackaged food items probably contain unreasonable amounts of salt as well. The FDA could challenge the manufacturers of these products to reduce the amount of sodium in their products.

I have mixed feelings, though, about the FDA compelling manufacturers into strict compliance. For one thing, just because something is unhealthy doesn't mean that it should be illegal. The sodium content of all prepacked food is already required thanks to 21 CFR 101.9, so consumers can if they are sufficiently inclined be knowledgeable and make reasonable decisions accordingly. Eating The Big One is bad for my health, but the government shouldn't prevent me from eating it if I want to. And besides, government involvement tends to make things suck. Take a look at Chicago banning the sale of foie gras.

Eating a healthy diet is important, and salt is a critical part of one. To the extent that we'd all be healthier if we ate less salt, I applaud the AMA for the reminder. Their argument, however, doesn't make sense in the context of federal regulations. And, frankly, it fails the common sense test too.