2006D-0066
  

  
Guidance for Industry and FDA Staff: Whole Grains Label Statements
  


  

  

  


  

  
FDA Comment Number : 
  

  
EC16
  



  

  
Submitter : 
  

  
Ms. Mary Palmer-Sullivan
  

  
Date & Time: 
  

  
05/08/2006 02:05:54
  



  

  
Organization : 
  

  
National Barley Foods Council
  



  

  
Category : 
  

  
Food Association
  



  

  
Issue Areas/Comments 
  


  

  


  

  
GENERAL
  


  

  



  

  
GENERAL
  


  

  



  

  
 Docket No. 2006D-0066



The National Barley Foods Council (NBFC) is responding to the announcement in the Federal Register, Vol. 71, No. 33, Friday, February 17, 2006 regarding Draft Guidance for Industry and FDA Staff: Whole Grains Label Statements; Availability.



The NBFC is a not-for-profit organization established in 1989 to serve as an information clearinghouse and promotional and publicity resource for barley food issues as they relate to human health and consumption.  The NBFC membership is comprised of five state barley producer groups. These are the Idaho Barley Commission, Montana Wheat and Barley Committee, North Dakota Barley Council, Oregon Grains Commission and the Washington Barley Commission.



The NBFC would first like to extend its support of labeling and FDA declaration of rule-making that will encourage increased consumption of whole grains for better health as indicated in the Dietary Guidelines for Americans; give consumers greater clarity in the marketplace in order to select whole grain foods; eliminate multiple standards that will confuse consumers and manufacturers; and encourage new food production made with whole grains as well as foods made with a blend of whole and enriched grains.



The NBFC would like to speak directly to Part III Definitions and specifically Number 5 which addresses barley.



We agree that dehulled barley (covered barley in which only the tough inedible outer hull has been removed) is whole grain.  However, it is important to note that other terms are used within the processing industry to describe dehulled barley.  Other terms used to describe this whole grain barley are HULLED and LIGHTLY PEARLED.  While all three terms may be used interchangeably, currently the term HULLED is used most often by processors to describe this barley.  To lessen confusion, we recommend using HULLED as the primary term to describe this whole grain barley.



It is important to note that there is another class of barley that should also be considered whole grain.  Historically, this class of barley has been called NAKED barley.  This type of barley is unique in that the tough inedible outer hull is very loosely adhered to the kernel.  When the barley is harvested in the field, the tough outer hull tends to fall off on its own which means that this barley requires very little to no processing, making it a whole grain.  In more recent years, processors have begun referring to this class of barley as HULLESS barley.  This barley, while more limited in supply, is currently available and should be acknowledged as a whole grain.  We recommend using HULLESS as the primary term to describe this whole grain barley.



The NBFC also recommends that manufacturers be encouraged to use the words WHOLE GRAIN in ingredient listings to help clarify whole grain barley products for easier consumer identification.  



For example, hulled or hulless barley kernels or berries should be labeled WHOLE GRAIN HULLED BARLEY, WHOLE GRAIN HULLESS

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  








  

  
 BARLEY or simply WHOLE GRAIN BARLEY. 



Barley flakes, flour, meal and grits that are made from hulled or hulless barley should be labeled WHOLE GRAIN BARLEY FLAKES, WHOLE GRAIN BARLEY FLOUR, WHOLE GRAIN BARLEY MEAL and WHOLE GRAIN BARLEY GRITS.



Thank you for your consideration of these comments.