Phosphatidylserine Derived from Soy Lecithin
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GRAS Notice (GRN) No.636 http://www.fda.gov/Food/IngredientsPackagingLabeling/GRAS/NoticeInventory/default.htm ORIGINAL SUBMISSION 000001 NutraSource, lnc . 6309 Moming Dew Ct, Clarksville, MD 21029 (41 0)-531-3336 or (30 I) 875-6454 March 8, 2016 ( G~N00Db36 Dr. Antonia Mattia Office of Food Additive Safety (HFS-255) Center for Food Safety and Applied Nutrition Food and Drug Administration 5100 Paint Branch Parkway College Park, MD 20740 Subject: GRAS Notice for Phosphatidylserine derived from Sunflower Lecithin Dear Dr. Antonia Mattia: On behalf of ECA Healthcare, Inc., we are submitting for FDA review a GRAS notification for phosphatidylserine (PS) derived from sunflower lecithin. The attached documents contain the specific information that addresses the safe human food uses for the notified substance. We believe that this determination and notification are in compliance with proposed Sec. 170.36 of Part 21 ofthe Code of Federal Regulations (21 CFR section170.36) as published in the Federal Register, Vol. 62, No. 74, FR 18937, April17, 1997. We enclose an original and two copies ofthis notification for your review. Please feel free to contact me if additional information or clarification is needed as you proceed with the review. We would appreciate your kind attention to this matter. Sincerely, (b) (6) 3/;?/2-t:J/6 Susan Cho, Ph.D. Susanscho [email protected] Agent for ECA Healthcare, Inc. enclosure ~~cc:;~U'\!1~\Q) 1 MAR 16 20'6 oFfiCE OF FOOD AODI11VE SAfETY j I 000002 GRAS EXEMPTION CLAIM for SunPSTM Manufactured by ECA Healthcare, Inc. Prepared by: NutraSource, Inc. 6309 Morning Dew Court Clarksville, MD 21029 Tel: 410-531-3336; [email protected] A. GRAS EXEMPTION CLAIM: phosphatidylserine (PS) from sunflower lecithin (SunPS®) - Exemption from the Requirement for Premarket Approval Pursuant to Proposed 21 CFR 170.36 ECA Healthcare, Inc. (hereinafter referred to as ECA) has determined that its phosphatidylserine (PS) from sunflower lecithin (SunPSTM) is Generally Recognized As Safe (GRAS). Consistent with Section 201(s) of the Federal Food, Drug, and Cosmetic Act, this determination is based on scientific procedures described in the following sections. Since these procedures specify the conditions of its intended use in food, the use of ECA’s SunPSTM is exempt from the requirement of premarket approval. Signed Susan Cho Date: Agent for ECA Healthcare, Inc. B. Notifier’s Name and Address Jiang Su, Managing Director ECA Healthcare, Inc. 1017 North Building, 1839 Qixin Rd Shanghai, China 201101 Tel: +86+139-1704-0601 or 909-859-4956 (Cell phone in California) Fax: +86-21-3358-0611 E mail: [email protected] 1 000003 GRAS EXEMPTION CLAIM for SunPS™ Manufactured by ECA Healthcare, Inc. Prepared by: NutraSource, Inc. 6309 Morning Dew Court Clarksville, MD 21 029 Tel: 410 -531-3336 ; Susanscho 1({U yahoo.com A. GRAS EXEMPTION CLAIM: phosphatidylserine (PS) from sunflower lecithin (SunPS ®) Exemption from the Requirement for Premarket Approval Pursuant to Proposed 21 CFR 170.36 ECA Healthcare, Inc. (hereinafter referred to as ECA) has determined that its phosphatidylserine (PS) from sunflower lecithin (SunPS™) is Generally Recognized As Safe (GRAS). Consistent with Section 201(s) of the Federal Food, Drug, and Cosmetic Act, this determination is based on scientific procedures described in the following sections. Since these procedures specify the conditions of its intended use in food, the use ofECA' s SunPS™ is exempt from the requirement of premarket approval. Signed (b) (6) Susan Cho Date: Agent for ECA Healthcare , Inc. B. Notifier's Name and Address Jiang Su, Managing Director ECA Healthcare, Inc. 1017 North Building, 1839 Qixin Rd Shanghai, China 201101 Tel: +86+ 139-1704-0601 or 909-859-4956 (Cell phone in California) Fax : +86-21-3358-0611 E mail: [email protected] 1 000004 C. Name of GRAS Substance TM Common name is Phosphatidylserine (PS). Trade name is SunPS , manufactured by ECA Healthcare, Inc. D. Product Description D.1. Identity Chemical name: Phosphatidylserine (PS). Per IUPAC-CBN nomenclature, it is a 1,2-diacyl-sn-glycero-3-phospho-L-serine. Chemical Abstract Registry Number: There is no CAS Reg. Number assigned specifically to PS derived from sunflower lecithin. The generic CAS Reg. Number assigned to PS is: 84776-79-4. Chemical Formula: The empirical formula of the most abundant molecule (comprising two linoleic acids) is C42H73O10PNCa. Structure: PS consists of a glycerophosphate skeleton conjugated with two fatty acids and L- serine via a phosphodiester linkage. The structural diagram below shows the general representation of the glycerophosphate backbone with R as fatty acids. The counter ion for the phosphate moiety is Ca2+ . Figure 1. General structure of PS, where R= alkyl group; the counter ion for the phosphate moiety is Ca2+ in the most abundant form. 2 000005 Fatty Acid Profile: The mean percentages of the fatty acids (FA) in PS from various sources are presented in Table 1. Table 2 presents the FA profile of SunPSTM. The bovine source is mainly composed of stearic and oleic acids; the main fatty acids in plant sources have linoleic acid and oleic acid; and fish sources have docosahexaenoic acid (DHA), eicosapentaenoic acid (EPA), and palmitic acid as the main fatty acids. Different sources do not significantly impact safety profiles of PS. Table 1. Fatty acid (FA) profiles of soy-, sunflower-, fish-, krill-, and bovine-derived PS Fatty Acid Typical FA composition (as % of total FA) Soy- Sunflower- Fish- Krill- Bovine- derived derived derived derived derived PS1 PS PS2 PS3 PS4 Caprylic acid (C8:0) 1 Myristic acid (C14:0) 2 2 Palmitic acid (C16:0) 14 11 23 23.5 3 Palmitoleic acid (C16:1) 2 1.8 Stearic acid (C18:0) 4 2.9 2 1 40 Oleic acid (C18:1 n-9) 15 15.8 13 13 35 Vaccenic acid (C18:1n- 11) Linoleic acid (C18:2n-6) 62 70.11 2 1.2 alpha-Linolenic acid 5 0.2 1 1 (C18:3 n-3) Octadecatetraenoic acid 2 (C18:4n-3) Eicosenoic (C20:1n-9) 2 0.6 6 Arachidonic acid (C20:4n- 1 0.7 6) Eicosapentaenoic acid 12 31 (C20:5n-3; EPA) Erucic acid (C22:1) 1.3 6 Docosapentaenoic acid 1 0.7 (C22:5) Docosahexaenoic acid 33 14 7 (C22:6n-3; DHA) Nervonic acid (C24:1n-9) 0.3 3 Others 5 5 1 GRN No. 000223; 2 GRN No. 000279;3 GRN No. 000311. 4 Adopted from Claro et al. (1999) and GRN 545. DHA=Docosahexaenoic acid; EPA=Eicosapentaenoic acid; FA= fatty acid. 3 000006 Table 2. Typical fatty acid (FA) composition of ECA’s SunPSTM Fatty acid Percentage (as % of total FA) Palmitic acid 14.58 Stearic acid 3.88 Oleic acid 15.90 Linoleic acid 60.32 Linolenic acid 5.32 Total 100 D.2. Manufacturing Process The phosphatidylcholine-enriched lecithin is enzymatically trans-phosphatidylated with L-serine using phospholipase D, which catalyzes the substitution of the choline head-group with serine to form PS. Following the enzymatic reaction, PS is separated from the reaction mixture, purified and dried. ECA uses a Hazard Analysis and Critical Control Point (HACCP)-controlled manufacturing process and rigorously tests its final production batches to verify adherence to quality control specifications described below. Processing aids, such as ethanol and other ingredients including excipients used in the manufacturing process, are food-grade as specified in the Food Chemical Codex (FCC). The ECA’s manufacturing facility and process are certified with the NSF International, based in Ann Arbor, Michigan, USA. D.3. Typical Composition and Specifications SunPSTM is produced as an off-white to brown-colored powder. Table 3 presents the typical composition of SunPSTM in comparison to those described in other GRNs for PS. Table 4 shows specifications of SunPSTM. Analysis of pesticides (less than 0.05 ppm) and dioxin congeners (less than 0.5 ppm) showed that the levels for the pesticides and other contaminants are minimal in this product. Specifications are comparable to those established in the previous GRAS notices (GRNs 186, 197, 223, and 545; PS content: GRN 186, ≥19%; GRN 197, ≥90%; GRN 223, ≥70%; GRN 545, ≥60%). ECA’s product is specified to contain ≥50% PS. The product also contains other phospholipids and glycerides naturally occurring in sunflower lecithin. These other phospholipids include lysoPS, phosphatidic acid, lyso phosphatidic acid, and associated phospholipids. Compared to the sunflower PS described in GRN 545, the specifications of SunPSTM are approximately 10% lower in the PS content and 10% higher in other phospholipids. These phospholipid profiles are not expected to impact the safety profile of PS products since other phospholipids follow similar metabolic pathways to that of PS. Phospholipids including phosphatidic acid, lyso PS, and lyso phosphatidic acid, are a class of lipids that are a major component of all cell membranes. Due to their safety and functionality, phospholipids are widely used as an emulsifier in food formulations. 4 000007 Table 3. Typical composition of SunPSTM and other PS Parameter SunPS GRN GRN GRN GRN GRN GRN 545 186 197 223 279 311 PS, % 52.3 66.8 19* 90 72.0 48.0 55.0 Phosphatidyl acid, % 7.3 9.2 ≤81 3.2 10.6 6.6 5.6 Phosphatidylcholine, % 3.6 0.4 NA NA 1.6 0.8 Lyso PS, % 0.8 0.9 0.3 0.5 0.8 0.8 Lyso phosphatidyl acid, % 0.6 0.7 0.3 0.3 NA NA Phosphatidyl inositol, % 3.5 1.3 NA NA 1.6 1.6 Other phospholipids, % 17.2 8.0 0.5 4.3 19.8 12.8 Glycerides (Tri-, di- and 4.9 0.1 2.8 3.1 mono-), % DHA+EPA, % NM NM NM NM NM 22 23 Calcium, % 2.8 2.5 NA 0.2 2.5 NA NA Sodium, % NA NA 3.1 ≤0.1 NA NA Silicon dioxide should be ≤1 1-1.5 less than 1.5% Free L-serine, % 0.5 0.4 NA 0.3 ≤0.1 NA NA Loss on drying, % 1.1 NA ≤5.0 1.0 ≤0.2 NA NA Ash, % 14.2 14.6 NA NA 12.7 NA NA Volatiles, % NM NM NM NM NM 2.0 1.5 NA=not available; NM=not measured; PS= Phosphatidylserine; *This value represents the sum of PS and lysoPS.