Immaculata University - Comment

Document ID: FDA-2007-0566-0005
Document Type: Public Submission
Agency: Food And Drug Administration
Received Date: January 30 2008, at 01:31 PM Eastern Standard Time
Date Posted: January 31 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: November 2 2007, at 12:00 AM Eastern Standard Time
Comment Due Date: January 31 2008, at 11:59 PM Eastern Standard Time
Tracking Number: 803a50bc
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Under the approach to setting DVs, it would be good to differentiate between DVs which are a goal, such as iron or calcium and those which are a maximum, such as sodium or cholesterol. I found both consumers and college students in my class were confused by this concept and thought of all DVs as goals. I suggest use of 2 columns and use of a different term, such as Maximum for items such as saturated fat and sodium. Calories should be kept at 2000; consumers are used to this value. The addition of 2,500 calories on the label should be eliminated; my experience is it can be confusing to the layperson. Calories from saturated fat should be mandatory; this is an important "nutrient" to limit in view of the prevalence of heart disease in this country. The amount of transfat should be listed on a separate line; it has different effects than saturated fat on the body and is more harmful, since it lowers HDL as well as raising LDL. Combining the two for the percentage is acceptable. Grams of total carbohydrate should exclude fiber. Fiber does not provide calories and has benefits that carbohydrates do not. Combining the two is confusing; I have found even Dietetics major students fining this confusing. RDA rather than % should be used for protein. The % is higher than needed and there is excessive consumption of protein rich foods, which are often also the ones high in fat and cholesterol, in this country. Rena Quinton, Immaculata University - Under the approach to setting DVs, it would be good to differentiate between DVs which are a goal, such as iron or calcium and those which are a maximum, such as sodium or cholesterol.

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