Can I derive a NOAEL from an ADI value?

The Acceptable Daily Intake (ADI) indicates the amount of substance that can be ingested (orally) on a daily basis over a lifetime without an appreciable health risk. This parameter is obtained dividing a NOAEL for a factor equal to 10. Since many ingredients such as preservatives are used both in food and cosmetics, toxicological data used to calculate the ADI are accepted for safety evaluation of cosmetics. However we can't derive a NOAEL simply dividing an ADI by a factor of 10 because crucial informations would be missing (e.g. animal model used to investigate toxicity, time and route of subministration etc...).