2007N-0277
  

  
 Food Labeling: Use of Symbols to Communicate Nutrition Information, Consideration of Consumer Studies and Nutritional Criteria; Public Hearing

  


  

  

  


  

  


  

  


  

  
FDA Comment Number : 
  

  
EC29
  



  

  
Submitter : 
  

  
Ms. Dayle Hayes
  

  
Date & Time: 
  

  
11/14/2007 11:11:57
  



  

  
Organization : 
  

  
Nutrition for the Future, Inc.
  



  

  
Category : 
  

  
Health Professional
  



  

  
Issue Areas/Comments 
  


  

  


  

  
GENERAL
  


  

  



  

  
GENERAL
  


  

  



  

  
 DEPARTMENT OF HEALTH AND HUMAN SERVICES 

Food and Drug Administration (FDA) 

RE: Docket No. 2007N-02771 



Dear FDA:



Thank you for the opportunity to submit comments on future food labeling initiatives and the use of symbols to communicate nutrition information to consumers. As a Registered Dietitian (RD) and expert in family nutrition education, I believe that food labeling will play an important role in efforts to improve the health of millions of Americans, especially youth and children. 





While counting calories is certainly important, Americans also need to make each calorie count more. This long-standing dietary principle of nutrient density is a cornerstone of current dietary recommendations. The 2005 Dietary Guidelines for Americans and MyPyramid advise people to get more nutrition from their calories  but they need help doing this. Future nutrition labeling efforts should bring the Dietary Guidelines to life and help people identify the most nutrient-dense foods in each food group.



FDA should develop on-pack nutrition symbols to communicate the concept of nutrient density. Any standardized front-of-pack symbol system should highlight the complete package of nutrients in a food  both those we should get more of each day as well as those we should limit. Todays Americans  young and old  are overfed yet undernourished. Focusing on nutrients to limit alone only reinforces this public health issue.



On-pack nutrition symbols should be designed to help people build and enjoy healthier diets. Americans need help building better overall diets  not identifying foods as good or bad. People eat foods not nutrients, and on-pack labeling can help people select and enjoy those foods that provide more nutrient power for their calories.



In my professional opinion, any approach to on-pack nutrition labeling should be:

' Science-driven 

' Transparent and objective 

' Based on the 2005 Dietary Guidelines for Americans and MyPyramid recommendations

' Balanced and incorporating nutrient density  highlighting the complete nutrient package of a food

' Positive  rather than the negative approach of some current traffic light systems based primarily on calories or nutrients that need to reduced

' Validated  by consumer research to ensure that it effectively helps people build healthier diets and achieve positive health outcomes

' Consumer-friendly  ultimately any successful approach must be relevant to what consumes can utilize


  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  


  

  








  

  
 ' Supported with comprehensive educational efforts  for both consumers and health professionals



Thank you again for the opportunity to comment on the future of food labeling. I look forward to reviewing FDA efforts as they are developed.



Sincerely,







Dayle Hayes, MS, RD

President

Nutrition for the Future, Inc.

3112 Farnam Street 

Billings, MT 59102



Phone: 406/655-9082

Fax: 406/656-0580



EatWellMT@aol.com