2003P-0132 Part 135 FDA regulations standard of identity frozen dessert
FDA Comment Number : EC52
Submitter : Ms. Naomi Goldberger Date & Time: 12/23/2005 10:12:29
Organization : Ms. Naomi Goldberger
Category : Individual Consumer
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 ?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,
Naomi Goldberger