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Wednesday, July 10, 2019 4:00:48 PM
CVSI is no longer using their seed to shelf program...if they had one.
CVSI's Seed to Shelf program will not be affected by farming in Kentucky. Why? The process is key in the GRAS certification CVSI obtained for it's Gold Formula, IMHO. No reason a different seed (selected from the approved fiber hemp seed list) or a different farm will nullify CVSI self-GRAS affirmation; provided they continue to plant, grow, and process CBD into their GOLD formula as outlined in the self-GRAS affirmation.
V- your argument has holes makes no sense.
An Introduction to Generally Recognized as Safe (GRAS) Filings for Food Ingredients
WHAT IS THE DIFFERENCE BETWEEN SELF-DETERMINED GRAS AND AN FDA-GRAS NOTIFICATION?
A GRAS determination can be either self-determined, independent of the FDA, or submitted to the FDA in the form of a notification for the Agency’s assessment. FDA notification of GRAS status for a substance to be used in food or may come in contact with food for human consumption becomes publically available information. Often, a company will choose to perform a self-determined GRAS assessment rather than FDA notification in order to keep certain information proprietary and to control the release of the information up on request. Often this information is proprietary manufacturing information.
Both regulatory pathways--the self-determined GRAS or FDA GRAS notification--are performed by appropriately qualified scientific entities, such as GRAS Associates, on behalf of sponsoring firms. The findings result in establishing compliance with FDA regulations for the subject food ingredient.
It is important to note that a self-determined GRAS status should be of the same scientific rigor as a GRAS notification submitted to the FDA. Often a sponsoring company, after having obtained self-determined GRAS status, may voluntarily elect to “notify” the FDA and subsequently get their opinion. This constitutes the FDA GRAS notification process, and a favourable review results in feedback from the FDA that is referred to as a “no questions” letter.
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