From: Alice H. Lichtenstein [lichtenstein@hnrc.tufts.edu]
Sent: Wednesday, January 10, 2001 11:46 AM
To: FDADockets@oc.fda.gov
Subject: [Docket No. 94P-0036]

[Docket No. 94P-0036]

Food Labeling: Trans Fatty Acids in Nutrition Labeling, Nutrient Content
Claims, and Health Claims; Reopening of the Comment Period.

Comments respectfully submitted by;
Dr. Alice H. Lichtenstein
Professor of Nutrition Science and Policy, Tufts University
Senior Scientist, Jean Mayer USDA Human Nutrition Research Center on
Aging at Tufts University

1.  Definition of the claim "reduced trans fat".
Since it is proposed that the term trans fat not appear independently on
the Nutrient Facts Panel is seems ill advised to allow a claim
containing the term.  It defies definition since the underlying premise
of the proposed ruling is that the consumer eat less saturated fat and
trans fat, independent of the relative contribution of each.  
Sanctioning the use of the term independent of the nomenclature on the
Nutrient Facts Panel would serve to confuse the consumer unnecessarily
and has no educational value.

2.  Criterion for the claim "reduced saturated and trans fat".
There is considerable benefit from reducing the intake of saturated and
trans fat as low as possible and there appears to be no disadvantage to
encouraging the general population in that direction.  For many foods a
decrease of 25% is quite modest.  Lowering the criterion to 33% or 50%
would encourage food manufacturers to provide products that would be
more healthful to the general population and give consumers more
specific advice when choosing among similar products.

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---------------------------------------
Alice H. Lichtenstein, D.Sc.
Director, Program on Cardiovascular Nutrition
Senior Scientist and Professor, Nutrition
Jean Mayer USDA Human Nutrition Research Center on Aging
Tufts University
711 Washington Street
Boston, MA 02111

phone: 617/556-3127
FAX:   617/556-3103
e-mail: Lichtenstein@HNRC.Tufts.edu