2004Q-0151 Qualified Health Claim (QHC): soy protein and cancer
FDA Comment Number : EC302
Submitter : Mr. Jason McCammon Date & Time: 05/02/2005 06:05:44
Organization : Iron Quest Fitness
Category : Health Professional
Issue Areas/Comments
GENERAL
GENERAL
April 1, 2005

Tomoko Shimakawa, Sc.D.
Division of Nutrition Programs and Labeling
Office of Nutritional Products, Labeling
and Dietary Supplements
Center for Food Safety and Applied Nutrition
Food and Drug Administration
5100 Paint Branch Parkway, HFS-830
College Park, MD 20740-3835

Re: Docket: 2004Q-0151 - Qualified Health Claim: Soy Protein and Cancer

Dear Dr. Shimakawa:

I am writing to protest the proposed soy-protein-prevents-cancer health claim and to request that the FDA hold a public hearing on this matter.

Approval of this health claim would double the sales of soy foods in this country, bringing enormous profits to the soy and food processing industries while putting me, my family and most of the American public at risk.

I have personally experienced serious gastric distresses when consuming soy in any form, but especially textured vegetable protein, like that found in veggie burgers. I have also witnessed several male friends and clients with some form of gynecomastia and feminizing charactorists - all of whom consumed a regular diet of soy protein which is know to increase estrogen levels due to the phytoestrogens in the in soy plant.

I am deeply troubled by the prospect of a soy protein/cancer health claim for the following reasons:

There is no consensus among experts that soy prevents cancer.
Substantial evidence exists showing that soy can contribute to or even cause cancer, including breast cancer.

Cancer statistics and epidemiological studies suggest that soy protein consumption might contribute to lower rates of some types of cancer but to higher rates of other types of cancer.

The plant estrogens (isoflavones) contained in soy protein products can cause thyroid damage, reproductive disorders and other endocrine disruption.

Soy is one of the top eight allergens, and its increased presence in the food supply would jeopardize the health and lives of many Americans.

Several subsets of the population are at special risk, including people suffering from hypothyroidism and cancer.

For the above reasons, I urge the FDA to hold a public hearing on soy protein and to reject the proposed qualified soy-prevents-cancer health claim.

I urge you and the FDA not to give into big business by doing what the FDA was commissioned to do in the first place - protecting Americans not profits.

Thank you,

Jason McCammon, BS, NFPT
Certified Personal Trainer
and Nutritional Consultant