Exhibit 565

Out of balance: conflicts of interest persist in food chemicals determined to be generally recognized as safe (Environmental Health 22:59)

Exhibit 565 · Peer-reviewed study

Out of balance: conflicts of interest persist in food chemicals determined to be generally recognized as safe (Environmental Health 22:59)

We found no evidence that GRAS panels have adhered to FDA’s guidance.

Assessed 403 GRAS notices FDA filed between 2015 and 2020 against FDA's guidance on convening GRAS panels. Notifiers relied on a panel in 57 percent of notices on average; seven people held 46 percent (340 of 732) of panel positions. Funded by the Environmental Defense Fund; two authors were paid by EDF as consultants. EDF was a plaintiff in the 2016-17 challenge to FDA's GRAS rule.

Source: Matouskova K, Neltner TG, Maffini MV (Environmental Defense Fund; independent consultants)
Date: 6 September 2023
Quoted from: Abstract, Results
Grade: Peer-reviewed
Document: https://doi.org/10.1186/s12940-023-01004-8
Accessed: 2026-11-09
Cited by: Findings citing this exhibit
Note: Abstract checked on PubMed (PMID 37670318); funding and panel counts read in the open-access full text (PMC10481496).

Cited by

Finding AGR-1.6: Peer-reviewed A study of the 403 GRAS notices FDA filed from 2015 to 2020 found that seven people held 46 percent of the 732 panel positions and found no evidence that panels followed FDA's guidance on convening them. The Environmental Defense Fund funded the study, and EDF was a plaintiff in the 2016 challenge to FDA's GRAS rule.