1998N-0359
FDA Comment Number : EC391
Submitter : Ms. Antigoni Pappas Date & Time: 07/20/2005 04:07:17
Organization : American Heart Association - Food Certification
Category : Health Care Association
Issue Areas/Comments
GENERAL
GENERAL
Section 2.1.2 Enhance Customer Health Information for Better Nutrition: Identifies 2.1.2.c. - Provide for more flexibility in the use of health/nutrient content claims in response to citizens' petitions (Docket #'s 94P-0390 & 95P-0241 - http://www.fda.gov/ohrms/dockets/98fr/04- 25529.pdf) as a 'B' priority.


The Food Certification team of American Heart Association believes that FDA should elevate this from a 'B' priority to an 'A' priority in 2006. Additionally, we suggest that this proposed rule be separated out by identifying the flexibility of the 10% minimum nutrient contribution requirement (Jelly Bean Rule) issue into a separate proposed rule. We recommend that the Jelly Bean Rule issue be separated into its own proposed rule.



Other suggestions for Priorities not listed on FDA's current Priorities List


* With the emerging science on the health effects of various types of fats, the Food Certification team of American Heart Association believes that FDA should consider opening the discussion on revising the criteria for 'total fat' for CHD-related health claims. One option for a total fat upper limit may be the < 6.5-gram level established for the whole grain with moderate fat content health claim.


* The Food Certification team of American Heart Association believes that FDA should consider requiring 'Added Sugar' to be disclosed on the Nutrition Facts panel.