KHKELLER AND HECKMAN LLP 

·JO 

erving Bn ·iness thro11gh Law and Science-g. 

1001 G Street, N.W. 

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tel. 202.434.4100 

fax 202.434.4646 

Via Certified Mail 

April21, 2014 

OPPT CDR Submission Coordinator 

Mail code 7 407M 

Attn: Inventory Update Reporting and 

Chemical Data Reporting 

Office of Chemical Safety and Pollution 

Prevention 

Environmental Protection Agency 

1200 Pennsylvania Ave., NW. 

Washington, DC 20460 

Writer's Direct Access 

Herbert Estreicher, J.D., Ph.D. 

(202) 434-4 334 

es tr e i ch er@kh I a w. com 

Re: REQUEST FOR EXEMPTION OF CITRIC ACID, TRISODIUM 

CITRATE AND TRIPOTASSIUM CITRATE FROM TSCA 

CHEMICAL DATA REPORTING (CDR) PROCESSING AND USE 

INFORMATION REPORTING REQUIREMENTS IN 2016 

Dear Sir or Madam: 

The Com Refiners Association (CRA) hereby requests the U.S. Environmental Protection 

Agency (EPA) to exempt citric acid (CASRN 77-92-9), trisodium citrate (CASRN 68-04-2) and 

tripotassium citrate (CASRN 866-84-2) from the Toxic Substances Control Act (TSCA) 

Chemical Data Reporting (CDR) processing and use reporting requirements (Part III of the 

reporting form, Form U) pursuant to 40 C.F.R. 711.15(b)(2)(iii). Citric acid and the 

corresponding citrates are predominantly used in food and are of low risk to human health and 

the environment. 

I BASIS FOR PETITION 

EPA regulations at 40 C.F.R. § 711.15(b)(2)(iii) permit any person to request that the 

EPA amend the list of substances of "low current interest" that are partially exempt from CDR 

requirements, specifically from the processing and use reporting requirements contained in 40 

C.F.R. § 711.15(b)(4). EPA states that in making the determination ofwhether this partial 

exemption should apply to a particular chemical substance, EPA will consider the totality of 

information available for the chemical substance in question, including but not limited to, certain 

enumerated considerations at 40 C.F .R. § 711.15(b )(2)(ii). 

The supporting attachments to this petition address each of the six exemption 

considerations for citric acid and the citrates. Most importantly, our petition demonstrates that 

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This document was delivered electronically. WWW.khfaW.COm 
KELLER AND HECKMAN LLP 

OPPT CDR Submission Coordinator 

April21, 2014 

Page 2 

there is "low current interest" in CDR processing and use data for these products because they 

are of low potential human and environmental risk, are comprehensively regulated by other state 

and federal agencies, in particular the U.S. Food and Drug Administration, have a long history of 

safe use in both food and non-food products, and offer great promise for environmentally 

beneficial and sustainable alternatives to traditional synthetic chemistry. 

Based on these and the other considerations discussed below, we are confident that the 

EPA will conclude that these substances should be added to the list of CDR partially exempt 

substances. 

II TSCA REGULATED USES 

According to the SIDS Initial Assessment Report (SIAR), the TSCA regulated uses of 

citric acid include "technical applications in various industries as a complex-forming agent, 

cleaning agent, softening agent, decalcifying agent, derusting agent, corrosive agent and 

synergist in antioxidant mixtures .... " The 2006 IUR report for trisodium citrate lists its use as a 

pH-regulating agent in paper mills and as a solvent in soap and cleaning compound 

manufacturing. The 2006 IUR identifies tripotassium phosphate use as a pH-regulating agent in 

paper mills. 

Even though the subject request is to partially exempt citric acid, trisodium citrate and 

tripotassium citrate for the 2016 CDR reporting cycle, the Coalition requests that the EPA 

provide its response to this petition within the 120 days contemplated under 40 C.P.R. 

711.15(b )(2)(iii)(A). The Coalition has a number of other food related substances for which it 

intends to submit similar requests and is anxious to receive the Agency's feedback on its general 

approach as reflected in the subject petitions. 

Sincerely, 

&rei~ Partner 

Enclosures 

This document was delivered electronically. 
CDR Petition for Certain Food-Use Substances 

40 C.F.R. § 711.415(b)(2)(ii)(A) Criterion Information 

(Whether the chemical qualifies or has qualified in past IUR collections for the reporting of 

the information described in§ 711.15(b)(4)). 

Publicly available information on the 1986-2006 IUR and the 2012 CDR database was 

searched for citric acid, trisodium citrate and tripotassium citrate to determine whether the 

substances meet the criteria of "whether the chemical qualifies or has qualified in past IUR 

collections for the reporting of information described in §711.15(b)(4)." See 40 C.F.R. § 

711.15(b )(2)(ii)(A). Citric acid, trisodium citrate and tripotassiurn citrate were reported in the 

2006 IUR and the 2012 CDR. 

In 2012, processing and use data was provided by 41 companies for citric acid, 11 

companies for trisodium citrate and 5 companies for tripotassium citrate. The 2012 CDR 

Volume was reported as 386,128,547lb/yr for citric acid, 14,333,759lb/yr for trisodium 

citrate and 1,903,962lb/yr for tripotassium citrate. Data reported to EPA for purposes ofiUR 

on a confidential basis is not necessarily reflected in this submission. The Agency is 

respectfully requested to review the IUR database for confidential data to supplement the data 

provided. 

This document was delivered electronically. 
CDR Petition for Certain Food-Use Substances 

40 C.F.R. § 711.415(b)(2)(ii)(B) Criterion Information 

(The chemical substance's chemical and physical properties or potential for persistence, 

bioaccumulation, health effects,' or environmental effects (considered independently or 

together). 

Extensive data are available to EPA for citric acid in the OECD SIDS Database (see 

http://webnet.oecd.org/HPV /UIISIDS Details.aspx?key== 1 a33 7636-fb4f-42e0-a9e7-

a37fa7124cb2&idx=O). Data for trisodium citrate and tripotassium citrate are available in the 

U.S. High Production Volume (HPV) Chemical Challenge Program Robust Summaries for 

Carboxylic Food Acids and Salts Category provided to EPA by the American Chemistry 

Council's Acetic Acid and Salts Panel April16, 2003. 

The following provides a summary of the data from these databases. 

Data Available on Citric Acid (CASRN 77-92-9) from the OECD SIAR 

1) Substance identity profile 

a. Substance identifiers 

IUPAC name: 2-Hydroxy-1 ,2,3-propanetricarboxylic 

CAS name: citric acid 

Other names: B-Hydroxytricarballylic acid 

2-Hydroxypropanetricarboxylic acid 

CASRN: 77-92-9 

EC number: 209-069-1 

Molecular formula: C6H807 

Molecular weight: 192.124 g/mol 

b. Physical properties' 

Ap12_earance: white crystalline powder 

pH: 2.2 at 0.1 N, ~ 1.8 at 50 g/1 and 

Melting point: 152 to 159 degC 

Boiling point: ~153 degC 

Relative density 1.665 at 20 degC 

Vapour pressure 7.3 X 1 o-/ Pa at 25 degC (calculated ) 

Partition coefficient (log Kow) Log Pow= -1.72 at 20°C 

Solubility: 576- 771 g/L at 20 degC/room 

temperature, data from 4 sources 

Dissociation Constants pKa1 =3.3, pKa2 = 4.76, pKa3 =6.4 

Henry's Law Constant Kh = 2.3 x 10- 1 Pam"'/mol (calculated) 

This document was delivered electronically. 
c. Manufacturing 

According to the SIAR, worldwide, citric acid production is mainly 

through microbiological fermentation of molasses and sugar solutions, 

while extraction from lemon juice or chemical synthesis is negligible. 

Dilute citric acid from filtered fermentation broths is precipitated with 

milk of lime (calcium hydroxide) as practically insoluble calcium 

citrate, which is then reacted with sulfuric acid to form citric acid and 

calcium sulfate (gypsum) as a recoverable and valuable by-product. 

d. Uses 

According to the SIAR, approximately 50% of the production is 

estimated to be used by the beverage and soft drinks industry, another 

20% in food processing industry and around I 0% in pharmaceutical 

industry, where citric acid is used as an acidulant, buffering agent, taste 

enhancer and synergist in antioxidant mixtures. Thus, approximately 

four fifths of the production is destined for human consumption. The 

remainder is split between technical applications in various industries as 

a complex-forming agent, cleaning agent, softening agent, decalcifying 

agent, derusting agent, corrosive agent and synergist in antioxidant 

mixtures. Last, small fractions are used in special applications such as 

citrate buffering of whole blood samples for transfusion. 

2) Toxicological profile 

a. Human Toxicity 

Information about the toxicology and environmental effects and fate of citric 

acid is summarized in the OECD SIDS Dossier. Also, additional information is 

presented in the EPA Technical data sheet supporting the registration of citric 

acid based products as biopesticides under the Federal Insecticide, Fungicide, 

and Rodenticide Act ("FIFRA"). The Office of Pesticide Programs (OPP) has 

waived the generic data requirements for citric acid, except for certain technical 

chemistry information, in light of its low toxicity. They state that "citric acid is a 

well-known component of carbohydrate metabolism in living organisms, and is 

found naturally in soil and water. It degrades readily when in contact with a 

variety of microorganisms that are found in soil, natural waters and sewage 

treatment systems. " Available literature indicates that this substance has low 

chronic toxicities. In addition, FDA has granted GRAS status to citric acid for 

use in human food . Citric acid is an edible substance that is readily metabolized 

by humans. Citric acid is "generally recognized as safe," or GRAS (see 21 CFR 

182.1 033). 

This document was delivered electronically . 
The conclusion of the SIDS Initial Assessment Report (SIAR) is that: 

"Based on many experimental data in animals and on human experience, citric 

acid is oflow acute toxicity. The NOAEL for repeated dose toxicity for rats is 

1200 mg/kg/d. The major, reversible (sub)chronic toxic effects seem to be 

limited to changes in blood chemistry and metal absorption/excretion kinetics. 

Citric acid is not suspected of being a carcinogen nor a reprotoxic or teratogenic 

agent. The NOAEL for reproductive toxicity for rats is 2500 mg/kg/d. Further, it 

is not mutagenic in vitro and in vivo. Also, the sensitising potential is seen as 

low. In contrast, irritation, in particular of the eyes but also ofthe respiratory 

pathways and the skin, is the major toxicological hazard presented by citric acid; 

this conclusion is confirmed by a series of reports relating to eye and skin 

irritation. " 

b. Ecological Toxicity: 

Numerous metabolic studies on the dietary effects and metabolism of citric acid 

in birds, mammals, and fish are reported in the SIDS Dossier. In summary, the 

conclusion of the SIAR is that: 

"Due to its physico -chemical characteristics citric acid is highly mobile in the 

environment and will partition to the aquatic compartment. Citric acid is rapidly 

degraded in both sewage works and surface waters and in soil. Citric acid is of 

low acute toxicity to freshwater fish, daphnia and algae and also to the few 

marine species tested; longer -term tests show comparable effect values. 

Similarly, citric acid has no obvious toxic potential against protozoans and many 

specie s or strains of bacteria including activated sludge micro-organisms. Based 

on the available data, citric acid is not judged to be a substance that presents a 

hazard to the environment." 

c. Exposure 

The SIAR summarizes exposure as follows: 

"Citric acid is a water soluble organic solid. It is a natural substance that appears 

as an intermediate in the basic physiological citric acid or Krebs cycle in every 

eukaryote cell. Citric acid has been produced for many years in high volumes, 

current global production is estimated to approach 1,000,000 t/a. It has wide 

dispersive use, being added to processed food and beverages, used in 

pharmaceutical preparations and in household cleaners as well as in special 

technical applications." 

3) Other information 

The SIDS Initial Assessment Report is attached to this document. It concludes that no 

further work is recommended on citric acid. The SIAR includes detailed data and 

references supporting the conclusion. 

This document was delivered electronically. 
Data Available on Trisodium Citrate (CASRN 68-04-2) 

1) Substance identity profile 

a. Substance identifiers 

IUPAC name: Trisodium citrate 

CAS name: Citric acid, trisodium salt 

Other names: Sodium citrate 

I ,2,3-Propanetricarboxylic acid, 2-

hydroxy-, sodium salt (1 :3) 

CASRN: 68-04-2 

EC number: 209-069-1 

Molecular formula: Na3C6Hs07 

Molecular weight: 258.06g/mol 

b. Physical properties' 

Appearance: white crystalline powder 

pH: ~8 

Melting point: 150 degC 

Boiling point: Decomposes at red heat 

Relative density 1.7 

Vapour pressure (calculated) 2.79 X 10-u hPa (2.09 X 10-t.,; mm 

Partition coefficient (log Kow) Log Pow= -0.28 (calculated) 

Solubility: ~425 g/L at 25 degC 

c. Manufacturing 

According to information from manufacturers, trisodium citrate is 

manufactured by neutralizing citric acid derived from a submerged 

fermentation process. 

d. Uses 

Trisodium citrate is chiefly used as a food additive E331, usually for 

flavor or as a preservative. It is also used as a pH -regulating agent in 

paper mills and as a solvent in soap and cleaning compound 

manufacturing. A small amount is used in blood collection tubes and 

for the preservation of blood in blood banks and for other medical uses. 

2) Toxicological profile 

a. Human Toxicity 

Information about the toxicology and environmental effects and fate of trisodium 

citrate is U.S. High Production Volume (HPV) Chemical Challenge Program 

This document was delivered electronically. 
Robust Summaries for Carboxylic Food Acids and Salts. In addition, FDA has 

granted GRAS status to trisodium citrate for use in human food (see sodium 

citrate, 21 CFR 184.1751 ). Trisodium citrate is an edible substance that is 

readily metabolized by humans. 

Studies cited in the Robust summaries gave the following LD5o values when 

trisodium citrate was administered by IV: 

Species LDso, mg/kg-bw 

Rat 1,548 and 1,364 

Mouse 170 

Rabbit 449 

b. Ecological Toxicity: 

Trisodium citrate showed very low ecotoxicity in the following tests: 

Species Result 

Poecilia reticu/ata (Guppy) LC50 (96 h) > 18,000-32,000 mg/L 

and Oryzias latipes (medaka) 

Daphnia magna 

EC50 (48 h)= 5,600- 10,000 mg/L 

Chiarella vulgaris biomass EC50 (96 h) > 18,000 - 32,000 

mg/L 

Trisodium citrate is readily biodegradable. 

c. Exposure 

As with citric acid, trisodium citrate is a water soluble organic solid. It has been 

produced for many years in high volumes, is added to processed food and 

beverages, and used in pharmaceutical preparations and in household cleaners. 

3) Other information 

U.S. High Production Volume (HPV) Chemical Challenge Program Robust Summaries 

for Carboxylic Food Acids and Salts Category are attached to this document. Data 

referenced above for trisodium citrate was reported in the summaries. 

This document was delivered electronically. 
Data Available on Tripotassium Citrate (CASRN 68-04-2) 

1) Substance identity profile 

a. Substance identifiers 

IUPAC name: Tripotassium citrate 

CAS name: Citric acid, tripotassium salt 

Other names: Potassium citrate 

1,2,3-Propanetricarboxylic acid, 2-

hydroxy-, potassium salt (1 :3) 

CASRN: 866-84-2 

EC number: 212-755-5 

Molecular formula: C6HsK307 

Molecular weight: 306.395 g/mol 

b. Physical properties' 

Appearance: white crystalline powder 

pH: 8.5 

Melting point: 211 degC 

Boiling point: Decomposes at 230 degC 

Relative density 1.98 

Vapour pressure (calculated) 2.79 x 10-1

..: hPa (2.09 x 10-1

..:mm 

Partition coefficient (log Kow) Log Pow= -0.28 (calculated) 

Solubility (calculated) 63 g/L at 25 degC 

c. Manufacturing 

According to information from manufacturers, tripotassium citrate is 

produced by adding potassium bicarbonate or potassium carbonate to a 

solution of citric acid until effervescence ceases, filtering the solution 

and evaporating to granulation. 

d. Uses 

Tripotassium citrate is chiefly used as a food additive E332, usually to 

regulate acidity. It is also used as a pH-regulating agent in paper mills. 

A small amount is used to reduce the frequency of kidney stones and for 

other medical uses. 

2) Toxicological profile 

a. Human Toxicity 

FDA has granted GRAS status to tripotassium citrate for use in human food (see 

potassium citrate, 21 CPR 184.1625). Tripotassium citrate is an edible substance 

This document was delivered electronically. 
that is readily metabolized by humans. It is also used in medical treatment to 

diminish the frequency of kidney stones. 

Tripotassium citrate also has a negative Ames Test. 

b. Ecological Toxicity: 

There were no studies that directly address the ecological toxicity of tripotassium 

citrate, but data developed for citric acid and trisodium citrate reported above 

should also be applicable to tripotassium citrate. Tripotassium citrate is expected 

to be readily biodegradable. 

c. Exposure 

As with citric acid, tripotassium citrate is a water soluble organic solid. It has 

been produced for many years in high volumes, and has wide dispersive use, 

being added to processed food and beverages, used in pharmaceutical 

preparations. 

3) Other information 

U.S. High Production Volume (HPV) Chemical Challenge Program Robust Summaries 

for Carboxylic Food Acids and Salts Category are attached to this document. Data 

referenced above for tripotassium citrate was reported in the summaries. 

This document was delivered electronically. 
CDR Petition for Certain Food-Use Substances 

40 C.F.R. § 711.15(b)(2)(ii)(C) Criterion Information 

(The information needs of EPA, other federal agencies, tribes, states, and local 

governments, as well as members of the public). 

None of the petitioned substances have been the subject of or considered for information 

collection requirements by EPA under TSCA (other than the TSCA IUR), the Interagency 

Testing Committee (ITC), or the Agency for Toxic Substances and Disease Registry (ATSDR). 

No petitioned substance has been or is the subject of any proposed or final regulation by the EPA 

under the following programs: 

TSCA 4 Test Rules 

TSCA 4(F) Required Actions 

TSCA 5(A)(2) Chemicals Subject to Significant New Use Rules (SNURS) 

TSCA 5(B) Data Gathering Requirements 

TSCA 5(E) Testing Consent Order Chemicals 

TSCA 5(F) Immediately Effective Rules 

TSCA 6(A) Hazardous Chemical Control Rules 

TSCA 8(A) Toxic Substances Subject to Reporting Rules on Production 

TSCA 8(A) CAIR Comprehensive Assessment Information Rules 

TSCA 8(A) Pair Preliminary Assessment Information Rules 

TSCA 8(C) Records of Allegations of Significant Adverse Reactions 

TSCA 8(D) Health and Safety Reporting Rules 

TSCA 8(D) Health and Safety Reporting Rules Termination 

TSCA 12(B) Notices of Export 

SARA 313 Chemicals Regulated Under §313 of EPCRA 

See http://www.epa.gov/opptintr/CORR/index.htm. 

The petitioning associations are not aware of any unmet information needs of the EPA, other 

federal agencies, tribes, states, local governments, or members of the public in light of: 

D FDA regulatory clearances currently available for these petitioned substances which 

acknowledge that their use in food applications is safe; 

D The extensive data on the substances published on the ECHA website. See 

http://apps.echa.europa.eu/registered/data/dossiers/DISS-9d9b878d-05c8-56aa-e044-

00 144 f67 d249/DISS-9d9b878d-05c8-56aa-e044-00 144 f67 d249 DISS-9d9b878d-05c8-56aae044-00 144 f67 d249 .html 

The petitioning associations would like the opportunity to respond and submit additional 

information needs identified by EPA during the petition process, if any, prior to EPA's final 

action on the petition request. 

This document was delivered electronically. 
CDR Petition for Certain Food-Use Substances 

40 C.F.R. § 711.15(b)(4)(ii)(D) Criterion Information 

(The availability of other complementary risk screening information). 

The following table provides the status of the petitioned substances on the Annex IV exemption 

determinations by the European Union for the REACH program, the REACH registration 

process, and the voluntary EPA High Production Volume (HPV) Chemical Challenge Program, 

as well as EPA safety determinations for low toxicity pesticide inerts. 

BU Lew Risk CAS E Ahaex RE.A:CH 

1Numb€r Ch mical Ind~ ~arne ' II Exempti E ~~@H HPV List inert 

Registrati~rl L"sting en ;;; 

77-92-9 1,2,3- No No Yes 2,4- 4A 

. Propanetricarboxylic sponsored 

I acid, 2-hydroxy-

(Citric Acid) 

68-04-2 1,2,3- No !No Yes 0- 4A 

Propanetricarboxylic sponsored 

acid, 2-hydroxy-, 

trisodium salt I 

(Sodium Citrate) I 

866-84-2 1,2,3- INo No Yes lo- 4A 

Propanetricarboxylic sponsored 

acid, 2-hydroxy-, I 

tripotassium salt 

(Potassium Citrate) • ·-

The categorization for the 1990 and 1994 HPV lists are as follows: 

0 = Chemical is within the scope of the HPV Challenge Program and may be sponsored. 

1 = Chemical is not considered a candidate for testing under the HPV Challenge Program, based 

on preliminary EPA review indicating that testing using the SIDS base set would not further 

EPA's understanding of the chemical's properties. 

2 = Chemical is otherwise being handled under the Organization for Economic Co-operation 

and Development (OECD) Screening Information Data Set (SIDS) Program. 

3 = Chemical is not subject to the HPV Challenge Program because it is a polymer or inorganic 

substance. 

4 = A company or consortium has clearly indicated to and has had confirmed by ICCA its 

sponsorship ofthis chemical in the Global HPV Initiative ofthe International Council of 

Chemical Associations, and all information essentially equivalent to a Full Commitment under 

the HPV Challenge Program (i.e., chemical name, CAS number, start year for each chemical, 

technical contact person and telephone number) has been provided to EPA. 

This document was delivered electronically. 
The key to EPA's Pesticide and Inert listings are as follows: 

1 = Inert Ingredients of Toxicological Concern 

2 = Potentially Toxic Inert Ingredients/High Priority for Testing Inerts 

3 = Inerts ofUnknown Toxicity 

4A =Minimal Risk Inert Ingredients 

4B = Inerts which have sufficient data to substantiate they can be used safely in pesticide 

products 

This document was delivered electronically. 
CDR Petition for Certain Food-Use Substances 

40 C.F.R. § 711.15(b)(2)(ii)(E) Criterion Information 

(The availability of comparable processing and use information) 

Processing and use of these substances is well characterized. TSCA-regulated exposures 

associated with these substances are comparable to, or less significant than, the food-use 

exposures associated with these substances which have already been shown to be "safe". More 

specific processing and use information is included in the data summaries at that section of this 

petition that discusses (B) Criterion Information. 

This document was delivered electronically. 
CDR Petition for Certain Food-Use Substances 

40 C.F.R. § 711.15(b)(2)(ii)(F) Criteria Information 

(Whether the potential risks of the chemical substance are adequately managed by EPA 

or another agency or authority) 

CRA is not aware of any information to suggest that these agencies are inadequately managing 

the safe use of the petitioned substances. 

The manufacturing and use of these substances primarily fall within the jurisdiction and 

authority ofthe FDA. However, the EPA, the Occupational Safety and Health Administration 

(OSHA), the National Institute for Occupational Safety and Health (NIOSH), and the Consumer 

Product Safety Commission (CPSC) regulate the manufacture and use of the petitioned 

substances as well. In addition, state environmental protection agencies have authority over 

facilities within their jurisdictions. 

As previously indicated, food uses of the petitioned components far exceed TSCA-regulated 

uses. Activities related to TSCA-regulated processing and use of the petitioned substances will 

also result from food-processing activities. Indeed, the same production equipment, processing 

techniques, and feed stocks may be used. These activities and their resulting environmental 

effects are already controlled adequately under other regulatory regimes. With respect to EPA 

programs specifically, human and environmental exposures are adequately controlled through 

existing regulatory programs such as the Clean Water Act, the Clean Air Act, and the Resource, 

Conservation and Recovery Act, and the Spill Prevention, Control and Countermeasures 

(SPCC) Program. Relevant FDA regulations for the petitioned substances are provided below. 

p . . d s b etltwne u stance CASRN FDAR egu I at:IO. n at 21 CFR .. 

1 ,2,3-Propanetricarboxylic 77-92-9 73.85- Caramel 

acid, 2-hydroxy- 131.111 - Acidified milk 

(citric acid) 131.112- Cultured milk 

133.123- Cold-pack and club cheese 

133.124- Cold-pack cheese food 

133.129- Dry curd cottage cheese 

13 3.169 - Pasteurized process cheese 

133.173- Pasteurized process cheese 

food 

13 3 .1 7 8 - Pasteurized neufchatel cheese 

spread with other foods 

13 3.179 - Pasteurized process cheese 

spread 

145.134- Canned preserved figs 

145.145- Canned grapefruit 

146.187 - Canned prune juice 

150.161- Artificially sweetened fruit 

preserves and jams 

150.141 -Artificially sweetened fruit 

jelly 

This document was delivered electronically. 
155.130- Canned com 

161.190 - Canned tuna 

163.110- Cacao nibs 

163.111 - Chocolate liquor 

163.112 - Breakfast cocoa 

169.115 - French dressing 

169.140 - Mayonnaise 

169.150- Salad dressing 

172.755 - Stearyl monoglyceridyl citrate 

172.861 - Cocoa butter substitute from 

coconut oil, palm kernel oil, or both oils 

173.165 - Candida lipolytica 

173.160 - Candida guilliermondii 

173.280 - Solvent extraction process for 

citric acid 

178.1010- Sanitizing solutions 

184.1033 - Citric acid food use 

1 ,2,3-Propanetricarboxylic 68-04-2 131.111 - Acidified milk 

add, 2-hydroxy-, trisodium salt 131.112- Cultured milk 

131.160- Sour cream 

131.185- Sour half and half 

133.179 -Pasteurized process cheese 

spread 

13 3.169 - Pasteurized process cheese and 

Jams 

13 3.173 - Pasteurized process cheese 

food 

150.141- Artificially sweetened fruit 

jelly 

150.161 -Artificially sweetened fruit 

preserves 

175.300 -Resinous and polymeric 

coatings 

179.45 - Packaging materials for use 

during the irradiation of prepackaged 

foods 

181.29 - Stabilizers 

184.1751 - Sodium citrate food use 

1 ,2,3-Propanetricarboxylic 866-84-2 175.105 -Adhesives 

acid, 2-hydroxy, tripotassium 

salt 

This document was delivered electronically.