The Nutrition Subcommittee of the Food and Drug Administration's (FDA) Food Advisory Committee met at the end of April in
During two days of discussion and public testimony, the subcommittee voted on whether or not to reconsider the total fat disqualifying level for heart health claims and if there is sufficient scientific evidence to establish a trans fat DV. Following its discussion, by majority vote, the subcommittee recommended total fat should not be a disqualifier for coronary heart disease health claims and stated that there is not sufficient scientific evidence to establish a trans fat DV. The subcommittee got it right on both points.
The subcommittee's reconsideration of the total fat disqualifying level for heart health claims was clearly warranted given the available scientific evidence. Under current rules, the health claim disqualifying level for total fat is predicated on a 2,000-calorie diet, in which 30 percent of the calories derive from fat.
As evidenced by the content of the report from the
Existing national dietary guidelines advocate a diet "moderate in total fat." The ranges of fat intake and varying ratios of protein to fat to carbohydrate can promote health, weight maintenance or weight loss among the public -- assuming a wide variety of food choices to meet nutrient needs and balance between food intake and physical activity (negative energy balance needed for weight loss).
The reconsideration of the total fat disqualifying level for heart health claims is further supported by the fact FDA has already waived this criterion and replaced it with a disclosure statement for several heart-related health claims: the health claim for stanol and sterol esters, health claim for whole-grain foods moderate in fat, and the qualified health claims for walnuts and nuts.
The subcommittee also was justified in its decision against establishing a DV for trans fat in nutrition labeling, given the lack of sufficient supporting data. Insufficient data exist about current trans fat content of foods and food consumption patterns to make meaningful estimates to establish a DV. Studies of dietary intake of trans fat conclude that trans fat consumption is far below the consumption of saturated fat as a percentage of energy.
Mandatory label changes about trans fat must be carefully considered and coordinated because contextual information about trans fat is related to information about saturated fat and cholesterol, which in turn relates to the future prospect of DVs for other fatty acids.
On a separate question of whether trans fat has greater cardiovascular risk-promoting effects than saturated fat, the subcommittee concluded that the cardiovascular risk-promoting effects from trans fat are greater.
As FDA moves forward in its considerations of DVs for the nutrition label, the agency should not proceed in a piecemeal fashion with further required changes. A series of successive mandatory nutrition label revisions within the span of a few years could undermine consumer confidence in the label. Following the implementation of the trans fat quantitative declaration final rule, consideration of a DV for trans fat should be coordinated into the single set of changes to all DVs that FDA plans to initiate in the near future.
Additionally, there is a lack of data demonstrating that DVs are either understood or widely used by consumers in choosing or assembling foods for a dietary pattern. FDA should develop a strategy to educate consumers about DVs. This strategy should include placing a greater emphasis overall on education, utilizing tools such as the Dietary Guidelines for Americans and the Food Guide Pyramid more effectively.
Robert Earl is senior director for nutrition policy at the National Food Processors Assn., Washington. E-mail him at email@example.com.