Anna Lisa Scholin - Comment

I would urge the FDA to make an additional improvement in the labeling of animal foods, the declaration by name of the non-certifiable coloring referred to as Cochineal or Carmine. The Center for Science in the Public Interest estimates that allergy to carmine and cochineal extracts are greatly under-diagnosed and can result in severe reactions or even anaphylactic shock. While this change to the regulations addresses foods marketed for feeding primarily pets, human owners of those pets also face exposure through the presence of such food in their home. While the risks posed by passive exposure may be minimal, people – particularly young children – consume food intended for pets more frequently than one would like to think. In January 2009, the FDA decided that the allergy risks warranted the listing of cochineal and carmine by name on the labels for food meant for human consumption. I would ask that this regulation modification for animal food products be similarly extended. While the risks as stated above are less than those posed by foods meant for human consumption, the very real chance of an allergic reaction, potentially requiring hospitalization, would seem to strongly favor at least labeling the product appropriately so people who know that they are allergic can make informed choices. Given the very low costs of compliance estimated for this regulation as stated, this minor addition to the requirements could be expected to add a negligible additional burden upon manufacturers. My complete comment is attached as a document. Thank you for your time.