Could gelatin contains amine functionalities, which react with nitrosating agents to form nirosamines?

Indeed, there is data to work with allowing to address the topic in the risk assessment, which has been accepted by regulators.

Luckily these would have to be non-amino acid related then based on structure and have already been evaluated in the step 2 where identified.

This study also concludes pyrrolidine, piperidine, piperazine, morpholine to be non-tumorigenic under the same conditions. The study might not have adequate positive control to support N-PRO is not carcinogenic. Has anyone found a stronger study concluding N-PRO to be non-carcinogenic?