2003P-0132 Part 135 FDA regulations standard of identity frozen dessert
FDA Comment Number : EC44
Submitter : Ms. Ellen Black Date & Time: 12/23/2005 10:12:28
Organization : Ms. Ellen Black
Category : Food Industry
Issue Areas/Comments
GENERAL
GENERAL
Docket No. 2003P-0132

I am writing to urge you not to move forward with the proposed rule to amend the
standards of identity for ice cream. The proposed rule, which would allow
non-milk ingredients and milk from animals other than cows, will encourage the
use of questionable ingredients like milk protein concentrate (MPC) and
ultra-filtered milk.

In addition to being concerned about the lack of testing of ingredients like
milk protein concentrate and ultra-filtered milk, I am concerned that this
proposal could exacerbate the price crisis being suffered by domestic dairy
producers. Most milk protein concentrate, ultra-filtered milk, and milk from
animals other than cows will be imported. Besides hurting
domestic dairy farmers, this leads to concerns about safety. The FDA admits
that they do "minimal monitoring" of MPC as it enters the U.S., yet MPC is
imported from around the world - including countries where dairy sanitation and
food regulations are less stringent.

When consumers purchase something labeled as ?ice cream? they expect a product
made with wholesome milk, not whatever ingredients the dairy industry can think
up. Weakening the standard of identity for ice cream to satisfy industry?s
desire to use cheaper ingredients is a disservice to consumers and I urge you
not to move forward with these proposed changes.

Sincerely,

Ellen Black
Dallas, TX