Have you folks ever been to NSF International? I suggest this group get insight from the chemistry laboratory staff and project and business management staff at NSF Int. world HQ in Ann Arbor, MI. Consider discussion with Kerri LeVanseler, Kathryn Foster or others. NSF has one of the worlds most well known and advanced chemistry testing laboratories. NSF can test for BPAs at very low levels, NSF can test for PFOA/PFAS to PPT levels. I agree with others this language would be out of step with other norms and regulations and need to be redone soon after, if this ballot were to pass. The 'not intentionally added' concept should be replaced by, "Tested and verified to not contain the chemical or chemicals of concern" as verified via a swab test (which includes a control test to account for background) or after conducting a product exposure (ie use product at temperature, pressure etc as would be used in the field) and analysis for the contaminant of concern. Consider that NSF 51 could be revised to include product testing for target contaminants through a test regiment that includes the product being used, and exposed to 1 or more of its normal food products. Then the exposed food and a control food are analyzed for the target contaminant. This paradigm exists in other NSF programs and testing that use the NSF Chemistry labs like NSF 61, NSF 42. In those cases, the standards, exposure protocol, and pass fail levels for contaminants are used to evaluate drinking water contact products, parts, and materials.
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