INTERNATIONAL PROGRAMME ON CHEMICAL SAFETY
WORLD HEALTH ORGANIZATION
SAFETY EVALUATION OF CERTAIN
FOOD ADDITIVES
WHO FOOD ADDITIVES SERIES: 42
Prepared by the Fifty-first meeting of the Joint FAO/WHO
Expert Committee on Food Additives (JECFA)
World Health Organization, Geneva, 1999
IPCS - International Programme on Chemical Safety
EVALUATION OF NATIONAL ASSESSMENTS OF INTAKE OF BUTYLATED
HYDROXYANISOLE (BHA)
First draft prepared by
Janis Baines
Australia New Zealand Food Authority, Canberra, Australia
1. INTRODUCTION
The Committee assessed the intake of butylated hydroxyanisole
(BHA), for which maximum limits have been proposed in a wide range of
solid foods and water-based, flavoured, non-alcoholic drinks in the
draft General Standard for Food Additives (GSFA) being developed by
the Codex Committee on Food Additives and Contaminants (CCFAC). An ADI
of 0-0.5 mg/kg bw has been allocated to BHA (Annex 1, reference 83).
BHA is a food additive generally used as an antioxidant in
products containing fats or oils and can be use in conjunction with
butylated hydroxytoluene, tert-butylhydroquinone, and propyl
gallate, for a synergistic combination of antioxidants.
Information was provided by 10 countries: Australia, Brazil,
China, Finland, France, Japan, New Zealand, Spain, the United Kingdom,
and the United States. A combined assessment was provided by Australia
and New Zealand (Aus-NZ). The assessments were based on data on
poundage, household economic surveys or sales data, information from
model diets, and/or individual dietary records. A summary of the data
submitted is given in Table 1.
Table 1. Summary of submissions on butylated hydroxyanisole
Country Budget Poundage FBS/HES/ Model Individual dietary
method data sales data diets records
Australia-New Zealand X X X
Brazil X X
China X X X
Finland X
France X X
Japan X
Spain X X X
United Kingdom X X X
United States X X
FBS, food balance sheet; HES, household economic survey; sales, retail stores
2. SCREENING OF BUTYLATED HYDROXYANISOLE BY THE BUDGET METHOD
The Codex GSFA proposes to permit use of BHA in a wide range of
solid foods and in water-based, flavoured drinks. Table 2 summarizes
the calculations made by the budget method in each country, including
the permitted patterns of BHA use, the proportion of solid foods and
beverages likely to contain BHA, the maximum levels of BHA permitted,
and a comparison of those levels with the theoretical maximum level
calculated by the budget method for that country.
The theoretical maximum level of use for BHA in solid foods was
less than the national permitted maximum in the four countries that
submitted data and was also less than the GSFA level of 1000 mg/kg.
The submission from the United Kingdom noted that a previous
assessment of intake of BHA by the budget method had indicated to
CCFAC that detailed intake assessment was required.
Spain and United States were the only countries in which use of
BHA was reported to be permitted in beverages. As for solid food, the
theoretical maximum level calculated by the budget method was less
than the Spanish or GSFA permitted level of use. The United States did
not submit detailed budget calculations, but it is likely that, as in
Spain, at least 15% of the United States population consumes beverages
that contain BHA. The theoretical maximum concentration would
therefore be 17 mg/kg, which is lower than the 90 mg/kg permitted in
beverage mixes in the United States.
Detailed intake assessments are required for use of BHA in solid
foods and beverages.
3. ASSESSMENTS OF INTAKE OF BUTYLATED HYDROXYANISOLE
3.1 Assessments based on data on poundage (disappearance)
Estimates based on poundage data of the amount of BHA available
per capita in five countries are shown in Table 3. The estimates are
all below the ADI, with the exception of those for Spain, and vary
widely, from 0.01 mg/kg bw per day (1% of the ADI) for China to
0.48 mg/kg bw per day (100% of the ADI) for Spain. The mean
per capita intake of BHA appears to have declined from 0.03 to 0.01
mg/kg bw per day (from 6 to 2% of the ADI) in Finland between 1980 and
1995, but appears to have increased from 0.01 to 0.07 mg/kg bw per day
(from 2 to 10% of the ADI) in the United States between 1987 and 1995.
The estimated intake of 100% of the ADI in Spain is higher than
in other countries, even for high consumers in the United States
(0.14 mg/kg bw per day for those in the 90th percentile in 1995).
These differences may be due to the reported use of BHA in both solid
foods and beverages in Spain. Furthermore, the maximum permitted level
in beverages (200 mg/kg) is higher than that in all other countries
(90 mg/kg). It should be noted that the European Union does not permit
use of BHA in beverages. The Spanish data may have been collated
before the European Directive was agreed.
Table 2. Estimates of theoretical maximum level for butylated hydroxyanisole (BHA) by the budget method
Country % food or beverage National maximum GSFA maximum Theoretical maximum
supply containing BHA level (mg/kg) levela (mg/kg) level (mg/kg)
Australia-New Zealand 50% solid food 200 1000 solid food 40
Brazil 25% solid food 200 1000 solid food 80
China 20% solid food 200 1000 solid food 100
Spainb 5% solid food 400 solid food 1000 solid food 200 solid food
15% beverages 200 beverages 90 beverages 17 beverages
GSFA, General Standard for Food Additives
a Maximum use levels proposed are: 1000 mg/kg for 9.2.1, 'frozen fish, fish fillet and fish products, including
molluscs, crustacea and echinoderms';
90 mg/kg for 14.1.4.3 'concentrates (liquid or solid) for water-based flavoured drinks'.
b Assumes that 50% BHA is used in solid food, 50% in beverages; current European Union directives do not permit
use of BHA in beverages
3.2 Assessments based on data from food balance sheets and household
economic surveys
No countries reported use of data from food balance sheets to
assess the intake of BHA. The submission of the United Kingdom notes
that such data are expressed as raw commodities, and the percentages
of the commodities that are processed and likely to contain the
additive are not usually known.
Four countries submitted data based on household surveys or sales
data, in which maximum levels of use were assumed. The data are
summarized in Table 4. Although high consumers generally cannot be
identified from household economic surveys or sales data, the
submission from France included estimates of the potential intake of
consumers at the 90th and 95th percentiles on the basis of data for
high consumer households.
Estimates of the intake of BHA based on household economic
surveys and sales data indicate that the potential intakes are all
below the ADI, ranging from 0.02 mg/kg bw per day (3% of the ADI) in
France to 0.25 mg/kg bw per day (50% of the ADI) in Spain. The higher
estimate for Spain may reflect the use of BHA in both solid foods and
beverages, whereas it is permitted for use only in solid foods in
France and Brazil.
3.3 Assessments based on model diets
Six countries submitted data based on model diets, details of
which are summarized in Table 5. It is essential for the
interpretation of estimates made with a model diet that the
assumptions made in constructing each model diet be stated. The
results cannot be compared directly because different assumptions were
made. The model diets used in Aus-NZ and the United Kingdom were
constructed to estimate the intake of a high consumer, assuming
maximum additive concentrations. The model diet used in the United
States was constructed to predict intake by a long-term consumer by
using data on food consumption derived from food frequency tables for
1982-88 from the Market Research Corporation of America (MRCA) and
average portion sizes from a three-day national food consumption
survey conducted in 1987-88 by the US Department of Agriculture.
Maximum additive concentrations were assumed. The Japanese model diet
is different in that analytical values for food additive
concentrations were used with data on national food consumption to
derive an estimate of actual BHA intake for the average consumer.
Table 5 summarizes the estimates based on model diets. The
estimates based on the high-consumer models of Aus-NZ and the United
Kingdom both exceed the ADI, with adult intakes of 2 mg/kg bw per day
(400% of the ADI) in the United Kingdom, and 1.8 mg/kg bw per day
(360% of the ADI) in Aus-NZ. The model used in the United Kingdom for
children indicates that the intake of BHA by young children, 5.4 mg/kg
bw per day (1000% of the ADI), tends to be higher than the intake of
adults because of higher ratios of food consumption to body weight. A
similar estimate, 4.8 mg/kg bw per day (950% of the ADI), was
submitted by China for high consumers; however, this is an
overestimate of intake even for a high consumer, as high levels of
consumption of five food groups are summed to give a total BHA intake.
In general, the estimates of intake in Aus-NZ, China, and the
United Kingdom are higher than those from the long-term consumer model
in the United States, as might be expected from the assumptions made.
In the United States model, the estimated intakes are 0.38 mg/kg bw
per day (76% of the ADI) for a mean consumer and 0.76 mg/kg bw per day
(150% of the ADI) for a 90th percentile consumer. If GSFA levels of
BHA are assumed, both the mean and high-consumer intakes of BHA exceed
the ADI.
The Japanese estimate for BHA intake from their total diet survey
was much lower (0.003 mg/kg bw per day or 1% of the ADI) than the
results from other model diets, because the concentrations of BHA were
those actually measured -- for example, 0 for frozen fish, fats, and
oils, 12 mg/kg for dried fish, 1 mg/kg for salted fish -- which were
much lower than the maximum GSFA permitted levels of 200 mg/kg for
frozen, dried, or salted fish, fats, and oils. In the absence of
information on national levels of permitted use, BHA intake in Japan
was estimated by assuming maximum GSFA levels and the reported
Japanese food consumption data (the model assumed 200 mg/kg for all
surveyed foods except 750 mg/kg in chewing gum). The revised estimate
of intake for Japan was 0.11 mg/day (20% of the ADI).
One useful aspect of the Aus-NZ and United Kingdom high-consumer
models is that individual foods or food groups for which high
consumption is likely to exceed the ADI can be identified. In the
Aus-NZ model, assuming national additive use levels, high consumers of
edible fat and fat emulsions may have BHA intakes that exceed the ADI
(260% of the ADI). High consumers of dried mashed potato may have BHA
intakes at the ADI (100%). In the United Kingdom model, high consumers
of soup, processed vegetables, and comminuted meats may exceed the ADI
(150, 140, and 130% of the ADI, respectively); however, this model
diet assumed that the maximum concentration in fine bakery wares was
200 mg/kg, a level that actually applies to fine bakery ware mixes.
Fine bakery wares would not be identified if the correct level of 25
mg/kg were used. If the proposed GSFA levels of BHA are substituted
for national use levels in the models for the range of foods in which
use is allowed, an additional list of foods is identified for which
high consumption may result in BHA intakes that exceed the ADI. In the
Aus-NZ model, such additional foods include cocoa and chocolate
products, processed comminuted meat, fresh fish, and products
including frozen fish, supplementary foods for dietary uses, and
soups. Information on additional foods in which the concentration of
BHA is at the GSFA level but not that of the European Union was not
available for the United Kingdom model.
Table 3. Estimates of intake of butylated hydroxyanisole (BHA) based on poundage data
Country Date Assumptions Estimated intake of % ADIa Comments
BHA (mg/kg bw per day)
China ? Population, 1200 million 0.005 1 Used only in solid foods
70% consumes BHA
Finland 1980 Population, 4.9 million 0.03 6 Used in 75% margarines, 25% oil
1994 Population, 5.1 million 0.01 2 dressings only
Spain ? Not consumed by 15% of 0.48 100 Used in solid foods and beverages
population < 3 years
United Kingdom 1984-86 Population, 56 million 0.007 1 Used in limited number of solids
foods only
United States 1987 Population, 240 million Mean, 0.01 2 Used in solid foods and beverage
90th percentile consumers, 0.02 5 mixes
1995 Population, 260 million Mean, 0.07 10
90th percentile consumers, 0.14 30
100% consumes BHA
Intake for 90th percentile
consumers is twice the mean
a JECFA ADI, 0-0.5 mg/kg bw
Table 4. Estimates of intake of butylated hydroxyanisole (BHA) based on household economic surveys and sales data
Country Date Survey Assumptions Estimated intake % ADIa
of BHA (mg/kg
bw per day)
Brazil 1992-96 AC Nielsan Maximum national use levels for all foods, except chewing gumb 0.08 20
Brazil; Maximum national use levels, including chewing gum at 0.13 20
sales data GSFA level
Population, 160 million
1984-94 Datamark; Maximum national use levels for all foods, except chewing gumb 0.09 20
mainly from Maximum national use levels, including chewing gum at 0.14 30
manufacturers GSFA level
France ? Sales data Maximum European Union levels of use; mean corrected for 0.02 (corrected) 3
foods that never contain BHA in France (fats/oils) 0.08 (uncorrected) 20
Adjustment for catering outside the home:
90th percentile consumers 0.16 (uncorrected) 30
95th percentile consumers 0.2 (uncorrected) 40
Spain 1993 Household All foods in permitted groups contain BHA 0.25 50
survey Consumption inside and outside home
No distinction for subgroups or rural/urban groups
a JECFA ADI, 0-0.5 mg/kg bw
b Assumed maximal level in final coconut and chewing gum products even though the use level in coconut is based on 60% fat content
and that in chewing gum is based on 20% gum content, resulting in overestimates of BHA intake
Table 5. Estimates of intake of butylated hydroxyanisole (BHA) based on model diets
Country Date Survey Assumptions Type of model BHA intake %ADIa
(mg/kg bw
per day)
Aus-NZ 1983 National, 24-h Two models: Aus-NZ /GSFA High consumerb
recall; adults, -- maximum levels (Aus-NZ or GSFA) Aus-NZ permissions 1.78 360
25-64 years; -- 95th percentile high consumption level GSFA permissions 6.77 1400
sample, 6254; -- modified GSFA classification system
body weight, 71 kg -- corrections for premixes/drink bases
China 1992 National household survey, One model Average consumer 0.69 140
24-h recall; 30 provinces; -- maximum GSFA levels High consumer 4.77 950
sample, 91 818;
body weight, 60 kg
Japan 1994 Total diet/national One model: Japan Average consumer levels 0.003 1
nutrition intake survey; -- Analysed food additive concentrations GSFA permissions 0.11 20
body weight, 60 kg (zero values when not detected) (selected foods only)
United 1986-87 National; 7-day weighed Three models: UK adult/child, GSFA High consumerb
Kingdom record; adults, 16-64 years; -- maximum additive levels (EU) UK permissions/adult 2.02 400
body weight, 60 kg -- unit quantity diet (Codex model with UK permissions/child 5.38 1100
1992 National; 7-day weighed GSFA levels) Unit quantity diet/ 5.83 1200
record; children, 1.5-4.5 -- 97.5th percentile high consumption GSFA permissions
years; body weight, 14.5 kg level (UK adult/child models)
-- GSFA classification system
United 1982-88 14-day menu obtained Two models/ US and GSFA Long-term consumer
States from MRCA food -- maximum additive levels (US or GSFA) US permissions/means 0.38 80
frequency data (1982-87) -- 90th percentile high consumption level US permissions/90th 0.76 150
combined with portion twice mean consumption GSFA permissions/mean 0.94 190
sizes from USDA/NFCS -- all respondents are consumers GSFA permissions/90th 1.88 380
(1987-88); > 2 years; -- GSFA classification system (except
body weight, 60 kg FSDU)
-- corrections for premixes/drink bases
Table 5 (continued)
Aus-NZ, Australia-New Zealand; GSFA, General Standard for Food Additives; EU, European Union; MRCA, Market Research Corporation of America;
USDA/NFCS, US Department of Agriculture/National Food Consumption Survey; FSDU, foods for special dietary uses
a JECFA ADI, 0-0.5 mg/kg bw
b Assumed to consume one food with potentially highest BHA intake from two major food groups at the 97.5th percentile (United Kingdom) or
95th percentile (Aus-NZ) and from one food with potentially highest BHA intake from each of the other major food groups at a mean level
for all respondents
3.4 Assessments based on individual dietary records
Estimates of the intake of BHA based on individual dietary
records were submitted by three countries. Aus-NZ and France derived
the mean and percentile intakes from individual estimates adjusted for
individual body weight, while the United Kingdom did not. The
assumptions made in deriving these estimates and the estimated intakes
of BHA are summarized in Table 6.
The estimates of mean intake of BHA based on individual dietary
records and national use levels range from 0.03 to 0.39 mg/kg bw per
day and are lower than the ADI for mean consumers in all countries and
for high consumers in France and the United Kingdom. The lower
reported intake in France (0.03 mg/kg bw per day) may be due to the
exclusion of category 2 (edible fats and oils) in the estimates. There
may be cause for concern for high consumers in Aus-NZ where the BHA
intake is 0.91 mg/kg bw per day (130% of the ADI). Estimates of the
intake of BHA based on GSFA levels and the range of foods in which use
is allowed in Aus-NZ are higher than those based on national levels of
use and exceed the ADI for both mean and high consumers.
4. EVALUATION OF ESTIMATES OF INTAKE OF BUTYLATED HYDROXYANISOLE
In screening additives by the budget method, CCFAC identified BHA
as an additive requiring detailed assessment. Inclusion of national
proportions of food or beverages that may contain BHA in the budget
method of screening did not alter this decision.
Estimates of the intake of BHA were submitted by 10 countries.
All of the approaches except that based on poundage were based on the
assumption that the maximum permitted national levels represented
actual additive levels, except in Japan where analytical data were
used. Estimates based on maximum permitted additive levels result in
overestimated actual intakes of additives.
Estimates of per capita BHA intake based on poundage, household
surveys, or sales data would be expected to predict lower intakes than
those based on actual consumption, such as model diets and individual
dietary records. In general, this was shown to be the case. Spain was
the only country to submit intake estimates based on both poundage and
household or sales data, the former being twice as high (100% of the
ADI) as that based on sales data (50% of the ADI). The differences may
be due to the fact that loss of additives in exported foods, non-food
uses, and wastage are not taken into account in the poundage approach.
Estimates of BHA intake based on high-consumer model diets and
individual dietary records were submitted by Aus-NZ and the United
Kingdom. In both cases, the estimates were two to three times higher
than those based on individual dietary records of high consumers (95th
percentile in Aus-NZ, 97.5th percentile in the United Kingdom). For
these two submissions, the estimate based on individual dietary
records was considered to be the most accurate.
Table 6. Estimates of intake of butylated hydroxyanisole (BHA) based on individual records
Country Date Survey Assumptions Type of model BHA intake %ADIa
(mg/kg bw
per day)
Aus-NZ 1983 National survey; -- maximum additive levels (Aus-NZ or GSFA) Mean Aus-NZ 0.39 80
24-h recall; -- modified GSFA classification system Mean GSFA 0.91 180
adults, 25-64 years; -- maximum additive level within any one group
sample, 6254 -- corrections for premixes/drink bases 95th Aus-NZ 1.3 260
-- reports 95th percentile consumption 95th GSFA 2.51 500
-- intakes adjusted for individual body weight
-- all respondents are consumers
France 1993-94 5-75 years; -- maximum additive levels (EU) but corrected Mean EU 0.07 14
sample, 1116 for foods that never contain BHA in France Corrected mean EU 0.03 6
(fats/oils) 90th EU 0.14 30
-- adjusted for catering outside the home 85th EU 0.16 30
-- intakes adjusted for individual body weight
-- reports 90th, 95th percentile consumption
-- reports by age group
United 1986-87 National survey; -- maximum additive levels (EU) Mean EU 0.19 40
Kingdom 7-day weighed -- reports 97.5th percentile 97.5th EU 0.45 90
record; adults, -- GSFA classification system
16-64 years; -- assumes average body weight of 60 kg
Aus-NZ, Australia-New Zealand; GSFA, General Standard for Food Additives; EU, European Union
a JECFA ADI, 0-0.5 mg/kg bw
The estimates based on individual records in Aus-NZ were higher
than those for the United Kingdom, and both were higher than the
estimates for France. In the Aus-NZ calculations, several GSFA food
categories were combined, and the maximum permitted level was assigned
to the wider food group. This tends to overestimate intake. The Aus-NZ
estimates were also based on 24-h recall data, which is likely to lead
to overestimated intakes in comparison with the seven-day record
method used in the United Kingdom, because the range of reported daily
food consumption levels tends to be wider. Some important differences
in food consumption were seen, however, with much higher oil and fat
consumption reported in Aus-NZ (mean, 130 g/day; 95th percentile, 450
g/day) than in the United Kingdom (mean, 23 g/day; 97.5th percentile,
58 g/day). These differences may be due to use of different
assumptions about the BHA concentration in various classes of oils and
fats: the Aus-NZ model included all fats and oils (all GSFA category 2
foods), consumed both as fats and oils and as ingredients in mixed
foods. The United Kingdom model may have assumed that BHA was used in
a more specific group of fats and oils, for example fat emulsions
only.
The estimates of mean national intake from the Chinese and United
States model diets were in the same range as those based on individual
dietary records in Aus-NZ and the United Kingdom. The estimated mean
intakes for Japan, based on a model diet, and for France, based on
individual records, were lower than those for other countries. All of
the estimates for national mean intake of BHA, whether based on model
diets or on individual dietary records, were lower than the ADI.
The estimated intakes from individual records in Aus-NZ and from
model diets in the United States indicate that high consumers of the
whole diet might exceed the ADI. In addition, high consumers of
individual foods may exceed the ADI, assuming maximum permitted
additive levels in individual countries.
Estimates derived by using GSFA additive levels grossly
overestimate the actual intakes in any one country, because the GSFA
is generally compiled by adopting the highest level of use of any one
food category submitted to the CCFAC. The range of use specified in
the GSFA is also much wider than in national standards. The best
estimates from countries that submitted calculations based on GSFA
levels in the range of foods in which it is allowed and model diets or
individual records are summarized in Table 7. The mean BHA intakes in
Aus-NZ (0.91 mg/kg bw per day) and the United States (0.94 mg/kg bw
per day) are similar. The estimate for 95th percentile consumers in
Aus-NZ is approximately three times higher than the mean intake in
Aus-NZ and higher than the United States 90th percentile intake
derived by multiplying the United States mean intake by two. These
relationships between mean and 90th and 95th percentile intakes are
generally recognized (UNEP/FAO/WHO, 1987).
Table 7. Summary of estimates of intake of butylated hydroxyanisole (BHA)
based on additive levels permitted within the General Standard for Food
Additives
Country Model Intake of BHA % ADIa
(mg/kg bw
per day)
Aus-NZ Individual records, mean BHA intake 0.91 180
(all respondents are consumers)
Individual records, 95th percentile
BHA consumers 2.51 500
United Model diet, mean BHA intake 0.94 190
States (all respondents are consumers)
Model diet, 90th percentile BHA
consumers 1.88 380
a JECFA ADI, 0-0.5 mg/kg bw
Estimates of intake based on GSFA maximum levels and the range of
foods in which use of BHA is allowed indicate that the mean and the
high consumer of BHA in Aus-NZ and the United States could exceed the
ADI.
5. CONCLUSIONS AND RECOMMENDATIONS
5.1 National estimates of intake of butylated hydroxyanisole based on
maximum limits specified in the General Standard for Food
Additives
Estimates of national mean intake based on maximum limits and the
range of foods specified in the GSFA were available from two countries
only; the mean intake estimates exceeded the ADI in these countries:
180% of the ADI for Aus-NZ and 190% of the ADI for the United States.
5.2 National estimates of intake of butylated hydroxyanisole based
on national or European Union maximum limits
All of the estimates of national mean intake by consumers of BHA
were lower than the ADI of 0-0.5 mg/kg bw: 1% of the ADI for Japan to
80% of the ADI for Aus-NZ and the United States. These estimates were
based either on model diets or on individual dietary records submitted
by six countries, Aus-NZ, China, France, Japan, the United Kingdom,
and the United States. Estimates of the intake of high consumers of
BHA, based on food additive levels in national standards, exceed the
ADI in some cases (30% of the ADI for France, 260% of the ADI for
Aus-NZ); however, the available data were insufficient to estimate the
number of high consumers or the magnitude or duration of intake at
levels above the ADI over a lifetime.
All of the estimates, with the exception of that from Japan, are
based on the assumption that BHA is the only antioxidant in foods in
which its use is permitted and that all such foods contain the
additive at maximum permitted levels, thus tending to overestimate
actual intake. Actual intakes of BHA depend on the relative
proportions of BHA, butylated hydroxytoluene,
tert-butylhydroquinone, and other antioxidants used in foods, the
actual levels of use according to good manufacturing practice, and the
the proportion of foods in any one category that contain the additive.
5.3 Recommendations to the Codex Committee on Food Additives and
Contaminants
The Committee identified foods and food groups that could
potentially contribute to a high intake of BHA. The Codex Committee
may wish to review the appropriate levels of BHA in the GSFA for
category 2, 'edible fats and oils'; category 4.2.2.2, 'dried
vegetables'; category 4.1.3, 'cocoa products'; category 8.3.1,
'processed comminuted meat'; category 9.2.1, 'frozen fish, fillets and
products; category 12.5.1, 'ready to eat soup and broths'; and
category 13.6, 'food supplements'.
The Committee noted that intake estimates based on national
maximum use levels of BHA were below the ADI, but those based on the
maximum limits and range of foods specified in the GSFA exceeded it.
The differences arise because the range of foods specified in the GSFA
is wider and the proposed levels of use in specific food categories
are generally higher than in national standards.
6. BIBLIOGRAPHY
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