Potential conflicts of interest and appearance issues
The Food and Drug Administration, when issuing draft guidance on convening a GRAS (generally recognized as safe) panel, gave examples of conflicts of interests and appearance issues.
Sources of conflicts of interest include:
? Ownership of any equity of an affected entity (excluding equity held through a publicly traded diversified (i.e., non-food sector specific) mutual fund);
? Compensation for services, such as management or consulting services to an affected entity (excluding honoraria for service on the GRAS panel);
? A role as director, officer, trustee, general partner or employee of an affected entity (including trade and professional associations);
? Funding for research purposes from an affected entity, regardless of whether there is post-grant oversight;
? A debt relationship of any kind with an affected entity, whether as lender, borrower, holder of debentures, or the like;
? Any of the above examples with respect to a spouse, minor child, general partner or prospective employer.
Examples of appearance issues include:
? Direct and predictable effect on the current financial interest of a household member, including adult children and parents, as well non-relatives in residence;
? Having or seeking a business, contractual or other financial relationship with an affected entity;
? Having a household member or relative with a close personal relationship who is an affected entity;
? Serving in the last year as an employee, officer, director, consultant, agent, attorney, trustee, contractor or general partner for an affected entity;
? Having a spouse, parent or dependent child who currently serves or is seeking to serve as an employee, officer, director, consultant, contractor, agent, attorney, trustee or general partner of an affected entity;
? Being an active participant in an organization that is an affected entity;
? Consistently and strongly advocating specific views or positions on a scientific issue relevant to safety assessment;
? Having one’s own work as a key element of the relevant evidence for safety of the substance under the conditions of its intended use.