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Date: Fri, 14 Nov 2003 13:05:54 +0100
Reply-To: PSA Forum
Sender: PSA Forum
From: fao.who.psaforum@WHO.INT
Subject: FW: Comment
Comments: To: psaforum@who.int
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-----Original Message----- From: Taylor, Christine L [mailto:Christine.Taylor@cfsan.fda.gov] Sent: Friday, 14 November 2003 12:58 To: fao.who.psaforum Subject: Comment
FAO/WHO Electronic Forum CONSULTATIVE PROCESS ON SCIENTIFIC ADVICE 1 October to 14 November 2003

Comment Submitted by:

Christine Taylor, Ph.D. Director, Office of Nutritional Products, Labeling and Dietary Supplements US Delegate to Codex Committee on Food Labeling --and-- Elizabeth Yetley, Ph.D. Lead Scientist for Nutrition, Office of Science US Delegate to Codex Committee on Nutrition and Foods for Special Dietary Use
Center for Food Safety and Applied Nutrition U.S. Food and Drug Administration College Park, Maryland USA

Comment Pertaining to: Paper 1.a. Scientific Advice Provided by FAO/WHO and Paper 1.b. Basic Principles Underlying the Provision Scientific Advice

The intent of this comment is to (i) underscore the appropriateness of specifically addressing scientific advice relevant to current nutrition in this effort and (ii) suggest as a principle the appropriateness of the risk analysis model for a range of nutrition-related topics.

Need for Scientific Advice for Nutrition

As more scientific information emerges about nutrient requirements, imbalances and toxicities, as well as about diet and health relationships, the need for FAO and WHO to provide nutrition-related advice through a transparent, accountable and appropriate process will only increase. Meeting this need is critical to support international standard setting and public health guidance.
Risk Analysis as Related to Nutrition Issues

Classically, risk analysis for foods has been driven by concerns related to chemical and microbial contaminants in foods. A widely accepted conceptual framework and scientific analysis strategy have evolved, which can be applied to nutrition issues. The distinguishing feature of risk analysis in the nutrition arena would be that the substances at issue have potential benefits as well as risk, and this would have to be taken into account in the risk assessment and risk management decision making. However, this does not argue against the appropriateness and wisdom of applying the risk analysis model in order to address today's wide ranging nutrition concerns. While risk analysis for nutrition has most notably been applied to safe upper levels of nutrient intakes pertaining to vitamin/mineral supplements, this analysis could be expanded to include the "risk" related to, for instance, the levels of saturated fat or to the "risk" of soy protein in infant formula. An extremely useful exercise at this point in the development a consultative process on scientific advice would be to include "nutrition risk analysis."