September 12, 2007
Food and Drug Administration
5100 Paint Branch Parkway
College Park, MD 20740
Re: Docket No. 2007N-0277
Dear Sir or Madam:
The Salt Institute submits these comments to the Food and Drug Administration in reference to Docket No. 2007N-0277 - Food Labeling: Use of Symbols to Communicate Nutrition Information, Consideration of Consumer Studies and Nutritional Criteria; Public Hearing; Request for Comments
The Salt Institute is the trade association representing the major United States food salt producers. For many years, the Salt Institute has closely monitored developments in food labeling as well as the scientific quality of the information given to consumers.
We strongly support the provision of objective scientific information to consumers, particularly in a manner that will be fully understood so that consumers can make informed choices.
An informed choice can only be made when scientifically proven objective information is made available. When information is prejudiced by subjective interpretations, the freedom to make an informed choice is severely curtailed and consumer are prevented from enjoying the benefits of a free society.
Food labeling as is presently practiced in the United States is scientifically flawed and using this unsound system as a basis for further simplification through will mislead consumers and may result in poor consumer choices as a result of misinformation.
As a means of communicating information to consumers, the food labeling system is scientifically flawed because foods are characterized by the chemical composition of their ingredients. It is a laboratory chemical analysis of individual ingredients followed by a mathematical treatment to approximate an overall composition of the formulated food. With the exception of water or moisture, no value is given to any changes that take place during processing. There will be changes to major ingredients that take place during processing that are not reflected anywhere in the label. In the minor ingredients, some of which may be very important, very large changes can take place.
As an example, the epsilon amino group of lysine, an essential amino acid, is very reactive in the Maillard browning reaction. Up to 30% of lysine can be lost in breadmaking and up to 60% in cereal flake production. Lysine is not currently an item on the food label, but is included in systems such as the Overall Nutrition Quality Index (ONQI). Unfortunately, the modification or destruction of nutrients as a result of processing is not taken into account and can result in erroneous scores.
A second major scientific flaw is that the consumer is led to believe that all the nutrients on the label are available. This is not the case. All data is based upon the USDA tables which does not take any of the dynamics of human digestion into account. When consumers read that a product has high fiber and high protein, they do not realize that the high fiber will be making a significant percentage of the protein unavailable. That is, after all the role of fiber, to make things indigestible. And indigestibility appears nowhere on the label. The errors resulting from indigestibility are very significant.
Consumers do not understand that the label does not account for processing changes and does not reflect the bioavailability of nutrients to their body tissues.
Finally, the label gives no indication of the very significant upgrading of nutrients that can take place in the gut, particularly as a result of bacterial action. At times there are relatively low quality food components that can be upgraded into important contributors to the immune system as a result of microbial action in the gut, yet current labeling systems may guide consumers away from these components – to the detriment of the consumers’ nutrition.
If this very imperfect and scientifically flawed labeling system is further “dumbed down” through the use of symbols, there is a strong chance of consumers being grossly misinformed. The will also be deprived of a free choice, because all symbols that are supposedly informational are, by their very nature, prejudicial. A red light means “stop.” That is not a free choice. When the decision to make a prejudicial marking on a food is based upon scientifically flawed information, you do the consumer harm.
We should not continue upon this march of folly. We must stop for a moment and re-evaluate where we are and this re-evaluation must be based upon science and science alone, if not we do consumers, our fellow citizens, a disservice.
The Salt Institute is grateful for the opportunity to comment upon this matter.
Sincerely,
Morton Satin
Director, Technical and Regulatory Affairs
Salt Institute
700 North Fairfax St.
Alexandria, VA 22314
Phone: (703) 549-4648
morton@saltinstitute.org
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