National Family Farm Coalition - Comment

On behalf of the National Family Farm Coalition, an organization of 30 family farm groups including many dairy farmers, we are pleased to submit comment on FDA Docket No. 2000P-0586 regarding the labeling of ultrafiltered milk as used in cheesemaking. NFFC adamantly opposes changing the definition of milk to allow ultrafiltered milk to be labeled as "milk." We have previously opposed weakening food standards that allow ultrafiltered milk to be used in cheesemaking processes. America's hardworking dairy farmers have invested considerable time and money into producing wholesome dairy products on which American consumers can rely. By changing cheesemaking standards, American consumers will no longer be able to distinguish between cheese made from American dairy farmers' raw milk and cheese that relies upon alternative "non-milk" ingredients that are nutritionally inferior to "real milk" from cows. It is interesting to note that in December 2007, Canada chose to strengthen its cheese standards by requiring a set percentage of raw milk be used instead of relying upon dairy byproducts such as ultrafiltered milk. The FDA is now taking us a step backwards, jeopardizing the livelihoods of U.S. dairy producers struggling to make a decent living and allowing questionable non-milk products to be classified as milk, cheese or other food. Consumers now face the prospect of more non-milk ingredients in their dairy products. FDA must ensure consumers freedom of choice and the right to know what is in their food and not allow UF milk to be labeled simply as "milk." Ultrafiltered milk is significantly different in composition from milk and nonfat milk. Ultrafiltration is a process by which water, lactose, minerals and water-soluble vitamins are taken away. It is not the nutritional equivalent of milk and significantly alters the chemical composition by weakening nutritional value. Consumers have a right to know if the products they are consuming were made by this process, which is certainly not the equivalent of real milk. UF milk has never undergone safety tests or been granted the FDA's "Generally Recognized as Safe" rules. Studies by the General Accounting Office and the University of Illinois at Urbana-Champaign have shown UF milk to not be nutritionally equivalent to milk. There is no scientific basis to show they are the same. American cheese is a vital part of maintaining a healthy diet. By changing the composition of cheese, consumers will now find themselves with a nutritionally inferior product and have to consume more to be able to receive the same benefits from consuming real cheese that has been fortified with calcium and other vitamins. There is absolutely no consumer demand for cheese made from UF milk and no benefits to be had for America's dairy farmers. Food processors are looking for cheaper ingredients to produce cheese and allowing for UF milk in cheese paves the way for more cheap imports from countries with questionable sanitary standards. Consumers are becoming more and more aware of what is in their food. FDA should ensure, at the very least, that all products that contain our could contain UF milk be clearly distinguished as such from real milk products. We believe proposals by cheese processors are just the first step towards also allowing illegal dry ultrafiltered milk, known as milk protein concentrates (MPC), to be allowed to be defined as milk as well. Any proposal that will change the definition of nature's most perfect food, milk, by allowing adulterated products to be labeled as "milk," puts in serious jeopardy the integrity of our food standards. After all the food scare scandals, both from domestic food and foreign imports, consumers are demanding more accurate information about what is in their food and are interested in maintaining a local food industry. FDA should respect their wishes over those of food manufacturers seeking greater profit. Katherine Ozer, National Family Farm Coalition - ...On behalf of the National Family Farm Coalition, an organization of 30 family farm groups including many dairy farmers, we are pleased to submit comment....