Shifting focus from fuels to foods: nutraceutical markets.
Transcription
Shifting focus from fuels to foods: nutraceutical markets.
Algae Biomass Summit October 2013 Orlando, FL Shifting focus from fuels to foods: How to enter the food, feed, and nutraceutical markets. Greg Sower, PhD Meghan McKelvey, MBA, HACCP certified Gavin Thompson, PhD The Regulatory World of Food in the U.S. Food Additive Traditional Food Dietary Dietary Supplements Ingredients GRAS Ingredients The Food Market. 2 Getting to Market: Key Questions • What is your product? • Is it well characterized? • Is there a history of use? • Are there safety data? • Who is the intended consumer? • What is your intended timeline? The answers affect your path to market. 3 Food Safety Modernization Act: Heads Up Preventive Controls Product Tracing •FDA to establish and receive information from a food tracking/tracing system Foreign Supplier Verification •Responsibility of the importer to verify suppliers Voluntary Qualified Importer Small Entity Guidance & Flexibility 4 •Hazard assessment and risk-based preventive controls (HACCP-lite) •Program to expedite review and importation •Plain language guide to new regulations •Phased implementation High Risk Foods •Designation and new recordkeeping requirements Enforcement •Recordkeeping violations result in denial of entry Regulatory Options in the U.S. Food Animal Feed Food Additive Petition AAFCO GRAS GRAS New Dietary Ingredient Infant Formula Color Additive Petition 5 AGRN Color Additive The Basic Path to Market Facility Registration Production under cGMP Characterization Safety Dossier Panel Review or Notification Market 6 Common Paths to Market: GRAS & NDI Proposed Ingredient Data Gaps Review Product Dossier NDIN to FDA FDA non-response (75 days) NDI or GRAS GRAS Determination Self-determined GRN to FDA FDA response (180 days) Dietary Supplement Market 7 Food Ingredient Market GRAS Ingredients (Self-determined or GRN) X Traditional Food Dietary Supplements Dietary Ingredients (NDIN) A GRAS ingredient can be used in a dietary supplement. A NDIN does not permit use in traditional food. 8 New Dietary Ingredient Notification Develop Safety Dossier 1 FDA Review (75 days) 2 3 Submit to FDA 9 To market 4 Objection/ No Objection GRAS Determination & Notification To market Develop Safety Dossier 1 2 3 Expert Panel Review (if GRAS, then to market or FDA) 10 “No questions” (or withdrawal) Submit to FDA (voluntary) 5 4 FDA Review (180 days) Components of a Product Dossier Identity & Characterization History of Use Product Dossier Dietary Intakes Toxicology/Clinical Studies The product dossier defends the safe use of the product. 11 Product Identity & Characterization • • • • • • Chemical name/CASRN Phys/chem properties Product specifications Manufacturing Process Batch data Impurities Both GRAS ingredients and NDIs require adequate characterization and specifications. 12 Relative Weight of Components 1. History of Use 2. Identity 3. Toxicology 4. Clinical 13 The Stats: Updated for 2013! Factor Pre-market notification FDA review duration Safety review by: Unsuccessful notices* Algae notices (total) Algae successful Algae unsuccessful GRAS NDI Exempt Yes 180 days (voluntary) 75 days “qualified experts” (FDA optional) FDA 20%* 70% 19 -- 10 (53%) -- 9 (47%) -- *As of Sep 27, 2013. Includes those withdrawn at the notifier’s request & those FDA determined did not provide a basis for a GRAS determination. Sources: FDA TRACK website (http://www.fda.gov/AboutFDA/Transparency/track/default.htm) and FDA GRAS Notice Inventory (http://www.accessdata.fda.gov/scripts/fcn/fcnNavigation.cfm?rpt=grasListing) 14 Case Study: Solazyme Chlorella Flour From the FDA’s public GRAS Notice Inventory: Solazyme has a successful GRAS Notification, but it took some work. Source: http://www.accessdata.fda.gov/scripts/fcn/fcnNavigation.cfm?rpt=graslisting :Note: ENVIRON had no involvement with Solazyme or the GRAS submission. 15 Identity – Increased Information • Original Submission: Genotyping of the organism appears to be provided to the Expert Panel only. • Final Submission: Genotyping provided in the publicly available dossier/notification. The notification is specific to Solazyme’s product. 16 Intended Uses – Revised Estimates & Uses GRN 330 GRN 469 More categories and modified amounts 17 Manufacturing Process and Toxicology 1. Modified the raw materials: “In response to FDA concern, the formulation was modified to eliminate cobalt as a trace mineral in the media used in the production …” –GRN 450 2. Performed and published toxicity studies: Szabo et al. 2013: – 90 day feeding study in rats – Mutagenicity – Genotoxicity – Allergenicity Safety must be based on publicly available information. 18 Solazyme GRN Summary Identity Use Manufacturing Process Toxicology GRN 330 GRN 450 GRN 469 Genotyping not released Genotyping included Same as GRN 450 3.5 – 50% of RACC 10 – 120 g/kg 5 – 120 g/kg Cobalt as a raw material Cobalt removed Same as GRN 450 No mutagenicity or genotox studies; no modern 90-d feeding study Mutagenicity, genotox, 90-d feeding, & allergenicity studies Source: http://www.accessdata.fda.gov/scripts/fcn/fcnNavigation.cfm?rpt=graslisting 19 Same as GRN 450 Expert Panel Conclusion No cGMP = not GRAS Doesn’t meet specs = not GRAS Different conditions of use = not GRAS 20 Lessons from Solazyme Submissions 1. FDA raised concerns that the Expert Panel did not. 2. Solazyme got help and addressed the issues. 3. GRN 469 is also a marketing tool for Solazyme. 21 Getting Your Product to Market: Key Questions • What is your product? • Is it well characterized? • Is there a history of use? • Are there safety data? • Who is the intended consumer? • What is your intended timeline? The answers affect your ability to get to market. 22 Getting Your Product to Market Take home: What are you making, from what and for whom? 23 Greg Sower, PhD Gavin Thompson, PhD [email protected] 602-734-7738 [email protected] 602-734-7704