Aug 21, 2017

Self-Affirmed GRAS Is Not Solid Proof of Food Safety

Self-Affirmed GRAS Is Not Solid Proof of Safety

While the company has not done anything illegal, it's worth noting that establishing self-affirmed GRAS is nothing to brag about. GRAS is an antiquated system that allows novel chemicals and ingredients into the food supply without stringent testing and safety review. The problem stems from the fact that the concoctions used in processed foods today didn't exist in the 1950s when the GRAS amendment was written into law.

At the time, GRAS was meant to apply to common food ingredients like vinegar and baking soda — regular cooking ingredients known through their historical use as being safe. Nowadays, however, novel GE and/or manufactured ingredients end up slipping through this loophole. The introduction of man-made ingredients into the food supply without stringent testing and verification of safety was never the intention of this law.

A significant part of the problem is that food companies are allowed to determine, on their own, whether an ingredient is GRAS. Food companies do not even need to submit their GRAS findings for FDA review. Again, this would not be a problem if we were talking about baking soda or vinegar but, today, all sorts of man-made ingredients are being self-affirmed GRAS.

All a company needs to do is hire an industry insider to evaluate the ingredient, and if that individual determines that it meets federal safety standards, it can be deemed GRAS.

In the quote above, Impossible Foods admits the safety of their Impossible Burger is based on "a panel of food safety experts," which determined the soy leghemoglobin proteins are similar to natural proteins and hence safe. But similar and identical are two different things. Moreover, who are those experts? Do they have conflicts of interest? The mere fact that such experts are being paid by the food company increases the likelihood they'll give the food two thumbs-up.

In this case, Impossible Foods appears to write off the allergen concern relating to their GE substance because their product already carries a wheat and soy allergen warning. But what if the proteins turn out to have allergenic properties unrelated to wheat and soy? If that's the case, a wheat and soy allergen warning is insufficient.   

Are Consumers Placed in Harm's Way?  

So, does self-affirmed GRAS comply with federal food regulations? Yes. Does that mean the product has been proven safe? Not necessarily. Jim Thomas, research program manager for the ETC group, noted that Impossible Foods did not seek FDA approval for its GE heme additive as a color additive, which has stricter safety regulations, despite touting the GE heme as the core component that gives the Impossible Burger its distinct red "blood" qualities. According to Thomas:24

"The FDA told Impossible Foods that its burger was not going to meet government safety standards, and the company admitted it didn't know all of its constituents. Yet it sold it anyway to thousands of unwitting consumers. Responsible food companies don't treat customers this way. Impossible Foods should pull the burgers from the market unless and until safety can be established by the FDA and apologize to those whose safety it may have risked."

Impossible Foods CEO Aims to Eliminate Meat From Human Diet

According to Impossible Foods' founder and CEO, Pat Brown — a self-professed vegan — his incentive for producing the meatless, "bleeding" burger is to eliminate the need for animal foods in the human diet.25 Part of his argument is that plant-based diets are more sustainable and environmentally-friendly. While I agree with his view that people eat too much meat, and the worst kind — factory farmed meat — monocultured GE crops are hardly the picture of sustainability.

I also don't think eating GE yeast excretions readily qualifies as a "plant-based" diet. It really falls under ultra-processed food, all of which are best avoided if you care about your health and longevity. In addition to that, there's the issue of the Impossible Burger failing to provide certain key nutrients typically obtained from meat. For example, the Impossible Burger does not contain cholesterol.

Ultimately, Impossible Foods wants to "produce all the foods we [traditionally] get from animals much more sustainably using scalable ingredients from plants … We're after 100 percent of the market, not a niche of people avoiding meat or being health conscious." According to the company website, "We are already developing other types of meat and dairy. Our team of scientists and food researchers can make chicken, pork, fish or yogurt entirely from plants."26

It's one thing to be vegan by choice. It's another entirely to eliminate animal foods for everyone. There are a number of problems with strict veganism, as you eliminate many necessary nutrients. Once you start talking about a GE-based vegan diet the risks are bound to be even higher.

Where to Find the Most Wholesome Food

Brown dismisses the notion that livestock play an important role in sustainable agriculture. In my view, this is a fatal error, as the evidence shows grazing livestock are indeed part of the overall, long-term answer to many of our environmental problems. It may not be readily evident how food animals contribute to our ecological stability and sustainability, but agricultural and soil experts who understand the system as a whole have done a great job explaining it, and I've interviewed several such experts over the years.

One of the best things you can do if you want to eat meat and care about environmental sustainability is to purchase animal products certified 100 percent grass fed by the American Grassfed Association. Many can also easily reduce their meat consumption, as most people eat far more than they need for optimal health. Fake foods are, in my view, not a viable answer to our environmental problems. Organic, regenerative farming is.

You can help steer the agricultural industry toward safer, more sustainable systems by supporting your local farmers and choosing fresh, local produce or grow some of your own. If you live in the U.S., the following organizations can help you locate farm-fresh foods:

American Grassfed Association

The goal of the American Grassfed Association is to promote the grass fed industry through government relations, research, concept marketing and public education.

Their website also allows you to search for AGA approved producers certified according to strict standards that include being raised on a diet of 100 percent forage; raised on pasture and never confined to a feedlot; never treated with antibiotics or hormones; born and raised on American family farms. provides lists of farmers known to produce raw dairy products as well as grass fed beef and other farm-fresh produce (although not all are certified organic). Here you can also find information about local farmers markets, as well as local stores and restaurants that sell grass fed products.

Weston A. Price Foundation

Weston A. Price has local chapters in most states, and many of them are connected with buying clubs in which you can easily purchase organic foods, including grass fed raw dairy products like milk and butter.

Grassfed Exchange

The Grassfed Exchange has a listing of producers selling organic and grass fed meats across the U.S.

Local Harvest

This website will help you find farmers markets, family farms and other sources of sustainably grown food in your area where you can buy produce, grass fed meats and many other goodies.

Farmers Markets

A national listing of farmers markets.

Eat Well Guide: Wholesome Food from Healthy Animals

The Eat Well Guide is a free online directory of sustainably raised meat, poultry, dairy and eggs from farms, stores, restaurants, inns, hotels and online outlets in the United States and Canada.

Community Involved in Sustaining Agriculture (CISA)

CISA is dedicated to sustaining agriculture and promoting the products of small farms.


The FoodRoutes "Find Good Food" map can help you connect with local farmers to find the freshest, tastiest food possible. On their interactive map, you can find a listing for local farmers, CSAs and markets near you.

The Cornucopia Institute

The Cornucopia Institute maintains web-based tools rating all certified organic brands of eggs, dairy products and other commodities, based on their ethical sourcing and authentic farming practices separating CAFO "organic" production from authentic organic practices.

If you're still unsure of where to find raw milk, check out and They can tell you what the status is for legality in your state, and provide a listing of raw dairy farms in your area. The Farm to Consumer Legal Defense Fund27 also provides a state-by-state review of raw milk laws.28 California residents can also find raw milk retailers using the store locator available at