Dear Reader:
My comment concerns trans fat labeling for restaurant menu items. And I am sorry that my suggestion, if implemented, will make labeling more complicated that it already is.
The proposed regulations do not include listing the level of trans fat in menu items. See III. Q & A Sec. C 7.
Trans fat intake is obviously of major public health concern.
But only the industrially produced trans fat in partially hydrogenated oils has been shown to harm health.
I expect that restaurant food will have far more trans fat from meat and dairy than from the partially hydrogenated oils.
Meat and dairy trans fat is natural, has been consumed for many thousands of years, and does not appear to be dietary hazard.
Including this natural trans fat as part of trans fat would probably confuse most consumers. Especially because the meat and dairy trans fat in FDA regulated packaged foods is almost always below the 0.5g per serving threshold amount.
My suggestion is that only the trans fat coming from partially hydrogenated oils be listed as part of the nutrition analysis of menu foods as per Section 4205.
Implemented this suggestion would spare meat and dairy from being unfairly targeted as sources of unhealthy trans fat. It would single out the trans fat that has been shown over and over to be so unhealthy that health professionals advise consumption be as close to zero grams as possible.
Thank you for giving consideration to my comments.
Sincerely, Richard Perlmutter M.S. Abington Nutrition Services LLc
Richard Perlmutter - Comment
This is comment on Notice
Draft Guidance for Industry; Availability: Implementation of the Menu Labeling Provisions of Section 4205 of the Patient Protection and Affordable Care Act of 2010
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