UC San Diego

Some firms and marketers of electronic cigarettes (e-cigarettes; a type of electronic nicotine delivery system (ENDS)) and refill liquids (e-liquids)have made claims about the safety of ingredients used in their products based on the term “GRAS or Generally Recognized As Safe” (GRAS).However, GRAS is a provision within the definition of a food additive under section 201(s) (21 U.S.C. 321(s)) of the U.S. Federal Food Drug andCosmetic Act (FD&C Act). Food additives and GRAS substances are by the FD&C Act definition intended for use in food, thus safety is based onoral consumption; the term GRAS cannot serve as an indicator of the toxicity of e-cigarette ingredients when aerosolized and inhaled (ie, vaped).There is no legal or scientific support for labeling e-cigarette product ingredients as “GRAS.” This review discusses our concerns with the GRASprovision being applied to e-cigarette products and provides examples of chemical compounds that have been used as food ingredients but havebeen shown to lead to adverse health effects when inhaled. The review provides scientific insight into the toxicological evaluation of e-liquidingredients and their aerosols to help determine the potential respiratory risks associated with their use in e-cigarettes.