2006D-0066
  

  
Guidance for Industry and FDA Staff: Whole Grains Label Statements
  


  

  

  


  

  
FDA Comment Number : 
  

  
EC2
  



  

  
Submitter : 
  

  
Mr. David Liliedahl
  

  
Date & Time: 
  

  
05/08/2006 01:05:13
  



  

  
Organization : 
  

  
Mr. David Liliedahl
  



  

  
Category : 
  

  
Individual Consumer
  



  

  
Issue Areas/Comments 
  


  

  


  

  
GENERAL
  


  

  



  

  
GENERAL
  


  

  



  

  
 I believe the FDA is headed in the correct direction in providing guidance to food manufacturers regarding their qualitative labeling claims for whole grain foods.  However, I believe to provide this guidance merely as a recommendation, without the force of law, will ultimately lead to abuses and erosion of consumer confidence in the FDA and government.  Additionally, I believe the general nutritional education and understanding by most Americans is relatively low, and allowing food manufacturers to make qualitative statements of this nature without threat of sanction by the government leaves open the potential for harm to consumers due to that ignorance.



I further believe the FDA should establish directive guidance regarding the claims that may be made by food manufacturers with respect to health benefits.  For example, manufacturers are permitted to make claims of reduced risks from heart disease based on the presence of whole grains in their foods without any regard for the deleterious health effects of other ingredients in the same food such as trans-fatty acids.  To make a claim of a benefit of reduced risk of heart disease based on the presence of whole grains in a food while ignoring the increase in risk due to the inclusion of trans-fatty acids in the very same food is misleading, and a disservice to Americans.  



I would ask the FDA extend their guidance to ensure manufacturers are not able to make claims of benefits from whole grains in their foods when such foods also contain trans-fatty acids or other ingredients with a strong evidentiary link to an increase in the risk factors for the very disease the manufacturers label touts the product as reducing the risks of.



For reference:

http://www.fda.gov/oc/initiatives/transfat/q_a.html

http://www.hsph.harvard.edu/reviews/transfats.html