1995N-0294 Quality/fill container; common or unusual name regulations
FDA Comment Number : EC3
Submitter : Mr. George Naylor Date & Time: 08/19/2005 05:08:48
Organization : National Family Farm Coalition
Category : Other Organization
Issue Areas/Comments
August 17, 2005

Re: Docket No. 1995N?0294

National Family Farm Coalition (NFFC) is writing in opposition to ?Food Standards; General Principles and Food Standards Modernization? proposed rule.

NFFC was founded in 1986 to represent family farm and rural groups in 30 states whose members' face the challenge of the deepening economic recession in rural communities caused primarily by low farm prices and the increasing corporate control of agriculture.

According to Federal Register / Vol. 70, No. 97 / Friday, May 20, 2005 / Proposed Rules, ?The proposed general principles will establish the criteria that the agencies will use in considering whether a petition to establish, revise, or eliminate a food standard will be the basis for a proposed rule.?

The above implies and the document as a whole implies not only a reduction of public oversight but, also the possibility of changing food standards by administrative fiat. This would be wrong.

The document further states, ?These proposed general principles are the agencies? first step in instituting a process to modernize their standards of identity (and any accompanying standards of quality and fill of container) and standards of composition.?

However, the problem seems to be not one of ?modernization? but rather, a willingness to actually enforce standards. The use of Milk Protein Concentrates (MPC) in cheese is a useful example.

While, FDA has issued two warning letters on MPCs in 2003, oversight of the MPCs has been lacking. An editorial in the June 16, 2005 issue of the Cheese Reporter by Bob Aschebrock, retired USDA cheese grader is informative. Mr Aschebrock wrote, ?We had roughly 30 or 40 samples of Cheddar and were hard-pressed to find three that were a low end A grade.? In part the problem can be attributed to ?So-called secondary starters. One has to wonder what flavors some of these starters are contributing to our Cheddar and Colby. Some of these ?cocktails? are made up of a number of ?special ingredients?.

Lack of enforcement for existing standards, suggest the proposed rule will only lead to a situation in which food standards exist on paper only.

NFFC is therefore opposed to the proposed rule.


George Naylor, President
Paul Rozwadowski, Chair, Dairy Sub-Committee

National Family Farm Coalition, 110 Maryland Avenue, NE Suite 307; Washington, DC 20002 (202) 543-5675