plements (Marriott, 1997). Therefore, depending on the most current information regarding risk to specific populations, it might be decided that the scientific justification for discretionary fortification necessitated a more in-depth scientific review process or was more congruent with a trial period of fortification while more data was collected.

The UL for vitamin A (as retinol) is 3,000 μg for pregnant women 19 to 50 years of age and 2,800 μg for pregnant women 18 years of age and younger. These values are approximately four times the Recommended Dietary Allowance (RDA). Some foods are highly concentrated sources of preformed vitamin A (e.g., liver). Other common food products, such as fortified low-fat milk, butter, or margarine, can provide additional preformed vitamin A. Thus preformed vitamin A may pose a significant risk of adverse effects to women of childbearing age who may become pregnant. According to the decision flow diagram in Figure 6-1, vitamin A could possibly be an example when discretionary fortification would not be scientifically justified or would necessitate careful study.

Alternatively fortification could be considered using provitamin A carotenoids, such as β-carotene, rather than retinol to increase vitamin A content. Provitamin A carotenoids are converted to retinol at an estimated rate of 12 μg as β-carotene or 24 μg as other provitamin A carotenoids (e.g., α-carotene and β-cryptoxanthin) to 1 retinol activity equivalent (RAE) (IOM, 2001). These conversation rates, however, assume that the carotene is bound in a fruit or vegetable matrix, so food fortified with carotenes may provide more RAEs than corresponding endogenous carotenes. Carotenes have no known level of toxicity and no UL, and there is no cautionary language about them in the DRI report (IOM, 2000b). Therefore, assuming that a public health need has been demonstrated, fortification might be scientifically justified.

Vitamin C is a nutrient that is added to food not only for fortification purposes, but also for its in vitro antioxidant effects. Vitamin C has a UL of 2,000 g for adults. This value decreases to 650 mg for children ages 4 to 8 years. In considering the risk of harm based on the decision flow diagram in Figure 6-1, two factors emerge as important in assessing the scientific justification about fortification