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C &EN missed a major point in the diacetyl article (Nov. 16, 2009, page 24). The writer points out that the Food & Drug Administration considers diacetyl as GRAS (generally recognized as safe) and then fails to define GRAS so readers can see why this is true and still should be true.
GRAS status is given to substances for use in foods either at specific levels or in accordance with Good Manufacturing Practices. For example, acetic acid is GRAS because good manufacturing process would limit it to the roughly 5% in vinegar. Glacial acetic acid is not GRAS.
Many GRAS substances are acutely toxic as determined by their oral rat lethal dose tests (LD50s). For example, vanillin, sage oil, and clove oil are acutely toxic.
Even some carcinogens are GRAS. One of these is titanium dioxide, which has been considered a carcinogen by the National Institute for Occupational Safety & Health for more than 20 years and is now also listed by the International Agency for Research on Cancer. But TiO2 is GRAS at concentrations of 0.5% or less in candy, ham, cake icings, and many other foods.
Titanium dioxide is a good example to illustrate the most important assumption of the GRAS definition; namely, these substances are approved by FDA for ingestion. Titanium dioxide is a lung carcinogen when inhaled but apparently is not a hazard when ingested.
For another example, mineral oil is GRAS. Even at high doses it will only roar through your digestive tract like grass through a goose. But if you inhale even a small amount, you are likely to develop lipoid pneumonia, which can be fatal.
Nowhere in the diacetyl story is the point made that diacetyl is not a threat by ingestion when found naturally in butter or when synthesized and used with good manufacturing practices. Diacetyl has a right to GRAS status. It is only a hazard when it is airborne and inhaled in significant quantities.
Mom was right: Don't inhale your food.
Monona Rossol
New York City
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