Comment from Food Contact Safety Council
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Summary: The Food Contact Safety Council (FCSC), with support from America's Plastic Makers, supports the FDA's effort to establish a science-based, risk-informed framework for post-market chemical safety assessments. They argue that the FDA should prioritize current-use data over conservative assumptions and clearly distinguish between direct food uses, food-contact uses, and impurity scenarios to ensure a rigorous and accurate assessment of BHT.
The Food Contact Safety Council (FCSC), with co-signatory America's Plastic Makers, respectfully submits the attached comments in response to Docket No. FDA-2026-N-2526, "Butylated Hydroxytoluene (BHT); Request for Information."
FCSC supports FDA’s efforts to establish a science-based, transparent, and risk-informed framework for post-market chemical safety assessments. Our comments emphasize the importance of exposure-based decision-making, the extensive data supporting the continued safe use of BHT, and the need for a predictable, evidence-based review process.
Thank you for the opportunity to comment.