2003P-0132 Part 135 FDA regulations standard of identity frozen dessert
FDA Comment Number : EC49
Submitter : Ms. Terry Bobb Date & Time: 12/23/2005 10:12:04
Organization : Ms. Terry Bobb
Category : Health Professional
Issue Areas/Comments
GENERAL
GENERAL
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 a??ice creama?? 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 industrya??s desire to use cheaper ingredients is a disservice to consumers and I urge you not to move forward with these proposed changes.

Sincerely,

Terry Bobb, CPhT and Former Nutrition Counselor