Calcium acid pyrophosphate Phosphoric acid used during manufac- ture of substance can cause toxicity to aquatic organisms if released into the environment.

Sugar Beet Fibers

Processing this substance generates wastewater with high biologic oxygen demand that can cause nitrification and degrade water quality if released directly into a water source. May also be treated with formaldehyde, a vola- tile organic compound subject to emis- sion restrictions set forth by the Clean Air Act.

Ammonium hydroxide Toxic to aquatic organisms if spilled; if volatized to the atmosphere, contrib- utes to greenhouse gases.

Morpholine Substance is a volatile organic com- pound subject to emission restrictions set forth by the Clean Air Act.

Sulfuric Acid

Manufacture of this substance gener- ates acid rain and other adverse envi- ronmental impacts if substance is im- properly disposed.

Key Differences Between Conventional and Organic Regulatory Reviews

The Conventional Process Thousands of chemicals can be added

to conventional packaged foods. These chemicals serve many purpos-

es, such as preserving food or improving taste, texture or appearance. Some of the chemicals added to conventional food have been reviewed by the FDA. In these cases, food and chemical companies must submit a formal petition supporting the safety of the food additive that is under review and being considered for approval by the FDA. But many of these reviews were conducted decades ago. If new evi- dence suggests a food additive may be unsafe, the FDA can choose to re-evaluate the additive, but it is not required to review additives periodically to reflect new sci- ence or changes in eating patterns. Two groups of food additives are ex-

empt from FDA review: additives the FDA deemed safe before Congress passed a food additives law, in 1958; and additives that are deemed "Generally Recognized as Safe,” or GRAS, by the FDA, a food or chemical company, or a food industry trade association.

Experts estimate that roughly a third

of the chemicals and other ingredients added to conventional packaged food have been approved for use by private parties, not the FDA. The GRAS exemption was initially created to cover ingredients widely known to be safe, like vinegar. But the FDA expanded the loophole to allow

manufacturers to conclude that a chemical was “safe” for use in food without notifying the agency.

Rather than close the loophole, the FDA has instead allowed companies to volun- tarily notify the agency about food chem- icals and to allow companies to summa- rize the industry science supporting their conclusions. Many of the scientists con- ducting these reviews have been paid by industry, and the FDA does not review the underlying biological and chemical data.

The Organic Process In contrast, fewer than 40 synthetic

additives can be used in organic packaged foods.

Any synthetic ingredients that can be added to organic packaged food must be formally added to an official registry, known as the National List, of substances that have all been reviewed by indepen- dent and government experts. The list is reviewed and approved by the National Organic Standards Board every five years. Since 2008, 72 synthetic additives have been removed, denied or further restricted from use in organic food, whereas only six synthetic substances have been allowed. To add or remove an additive to the National List, a petition must be submitted for review by the National Organic Stan- dards Board and the USDA. Once a peti- tion has been filed, a subcommittee of the National Organic Standards Board will determine whether additional information is needed, and the subcommittee may

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