CSPI's comments to FDA on azodicarbonamide (ADA)
CSPI respectfully submits these comments in response to Docket No. FDA-2026-N-4126. As part of the FDA's ongoing commitment to reforming the post-market assessment system for evaluating food chemical safety, CSPI is encouraged to see the agency initiate a post-market evaluation of azodicarbonamide (ADA) following its inclusion in the FDA’s List of Select Chemicals in the Food Supply Under FDA Review.
At present, ADA is approved in the US for use as a dough strengthener and flour-treating agent in a variety of food products and in food contact materials, despite concerns regarding its safe use. These primarily stem from its breakdown products, semicarbazide (SEM) and ethyl carbamate (EC; also known as urethane), that form during the cooking process. The FDA itself recognizes that ADA forms SEM and EC during the baking process and acknowledges that both SEM and EC are associated with cancer in animals.