From: Anderson, Shellee
Sent: Wednesday, May 10, 2006 1:40 PM
To: Dockets, FDA
Subject: FW: Whole grain labeling.

 

-----Original Message-----
From: george de pasquale [mailto:george@essentialbaking.com] 
Sent: Tuesday, May 09, 2006 6:14 PM
To: Anderson, Shellee
Subject: Whole grain labeling.

I'm not sure if I am too late to actually have suggestion logged.

I would like to respond to the FDA's suggested guidelines by saying that
there needs to be a distinct statement about the overall percentage of whole
grain in a product for it to be meaningful to the consumer.  Too often these
kinds of legislations are geared to the advantage of the large manufacturers
and just end up deceiving the consumer into thinking they are buying a
healthy product. We could use as an example a loaf of bread containing 15 oz
of white flour and one ounce of whole grain flour.  Under your guidelines
the manufacturer could proclaim this to be a whole grain product on the
label.  There would be virtually no added health benefit to the consumer to
eat bread with such a low percentage of whole grain, yet the label would
deceive the customer into believing otherwise.  We have seen this kind of
deception before with "natural", "no added fat", "no cholesterol" and other
phrases that are designed to specifically deceive the customer into a sale
with virtually no cost or effort on the part of the manufacturer except for
marketing dollars. 

Furthermore this is detrimental to the overall quality of bread in America
and the overall health of the population.  The cost of making bread with
100% whole grain is much greater than it is to make bread that just contains
some small percentage of whole grain- the flour itself is much more costly
and the processes are more difficult.  Because of this, truly 100% whole
grain products need to be sold at a higher price.  In my 30 years in the
bread business it is abundantly clear that the vast majority of bakeries
producing truly 100% whole grain products are small businesses.  They don't
have the distribution or shelf life issues that the larger companies have
and so are able to get a better, fresher and more healthy product to the
consumer, albeit at a higher price.  This proposal of the FDA would make it
possible for the big bread companies to compete directly with smaller
businesses by undercutting the price with an inferior product, using
deceptive language on the bag, and all WITH THE SANCTION OF THE FDA!!!

Please reconsider the language of this proposal to accurately reflect the
contents of a given product, to stop handing the competitive edge to the
"big boys" at the expense of jeopardizing the small businesses turning out
higher quality product, and to keep in mind the ultimate goal of your
organization- which should be protecting the health of the public, not
protecting the profits of the big manufacturers.

Sincerely,
-- 
George De Pasquale
COO
The Essential Baking Company