"By my reading, acetic acid is classified as GRAS (generally recognized as safe) as a food additive"

FDA maintains a GRAS list for food additives.  EPA maintains a GRAS list of formulation additives.  Inclusion on the FDA list does not mean it is on the EPA list or vice versa.  At one time I wished to use a FDA food additive GRAS list substance in an Ag formulation.  This substance was not on the EPA GRAS list.  EPA refused to register the formulation due to use of an illegal ingredient.  EPA was happy to go thru the process of getting this substance included on their GRAS list.  There are laws as to the procedure that must be followed to get any new substance on the EPA GRAS list and those laws burn about  a years time.  So, for one year we were unable to use that substance.  Fortunately there were alternatives that were included on the EPA GRAS list that could do the job.  Just at higher cost and less convenience.

Dick

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