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"Food Labeling Policy of FDA"
-----------------------------
a talk by Felicia Satchel
summarized by Jim Lyles
Felicia Satchel is a Consumer Safety Officer working for the Food and
Drug Administration of the USA federal government. She gave a talk
at the conference entitled "Celiac Disease: The Dark Side of the
Gastrointestinal Planet", held July 14-15, 1995, in Baltimore,
Maryland. What follows are some highlights of Felicia Satchel's
talk.
There are four federal agencies involved in food product regulations.
The USDA regulates meat and poultry products, but not seafood and
game meats. The Bureau of Alcohol, Tobacco, and Firearms regulates
alcoholic beverages that contain 7% or more alcohol; this excludes
products such as wine coolers. The FDA regulates the remaining food
products available to consumers. To further confuse things, the
Federal Trade Commission, not the FDA, is responsible for ensuring
that all advertising is truthful and not misleading.
Here are some of the guidelines that food manufacturers must follow
in the US:
* Any food which is fabricated from two or more ingredients must
declare each of the ingredients in the ingredient list, using
the common and usual ingredient names.
* Source declaration is now required for protein hydrolysates. In
other words, the vegetable source must be declared for HVP
(hydrolyzed vegetable protein) and HPP (hydrolyzed plant
protein).
* If a substance is added during processing, and then later
completely removed, it does not have to be included in the
ingredients. (Editor's note: rice syrup, which is often
processed with barley enzymes, is an example of this.)
* Flour can be dusted on conveyor belts, and not be declared as an
ingredient, so long as an "insignificant" amount gets on the
product. The amount considered "insignificant" is too high to
be safe for celiacs.
* By law, the FDA cannot place requirements on manufacturers that
would be impractical. However, the FDA can require specific
labeling of certain ingredients when scientific evidence can be
presented showing that consumers need to be aware of them. For
example, several years ago evidence was presented to the FDA
that consumers allergic to sulfiting agents could be come ill
and in some cases actually die after ingesting them. If it were
not for this, sulfites would not have to be listed because they
would be considered "incidental" ingredients.
* In foods, the ingredient "starch", when listed by itself and not
in combination with other words, must be corn starch and nothing
else. However, be wary of ingredients such as "modified food
starch", "food starch", or "food starch-modified", these could
come from any source, not just corn.
* "Malt", "malt syrup", and "malt extract", when listed without a
source, must be a product of barley.
As of today, there is no request or petition before the FDA to allow
a wheat-based coating for fresh fruits and vegetables. If there ever
becomes a wheat-based coating for commercial use, the FDA would
review what conditions are necessary to ensure that the product is
used safely, so that it would not be a concern for celiacs.
At this point, Felicia Satchel began taking questions from the floor.
Q: When the ingredients in a product change, are manufacturers
allowed to use up the old product labels before switching to new
labels?
A: The FDA does not permit manufacturers to use old labels, if the
formulation has changed. The only exception is if the
manufacturer adds a sticker that indicates what has changed.
There was a grace period, when the new labeling laws came into
effect, during which old- style labels were permitted. However,
that "grace" period ended some time ago.
Q: Are manufacturers required to identify the specific ingredients
in "natural flavors", etc., if asked for health reasons?
A: Not to individuals. If an ingredient can be shown by scientific
data to be dangerous to a segment of the population, then the
FDA can require full disclosure of that ingredient. Individuals
can not.
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