Comment from Dr. Jill Kuhn

The U.S. Department of Agriculture (USDA) proposed a regulation (FR vol. 76, No 233, Monday, December 5, 2011, 75809-75825) that would greatly REDUCE their oversight of meat and poultry labels thereby increasing the likelihood products will enter the marketplace with UNDECLARED allergens. USDA estimates these new rules will save the Agency $870,000 per year but at what cost to the health and safety of American consumers? One recall, especially one resulting in illness or death, could cost the manufacturer ten times the amount USDA expects to save. This attempt at "cutting costs" (which is clearly a fallacy), puts at harm the 12 million Americans with food allergies. We have a right to know EXACTLY what is in our food and thus protect our family members who have life-threatening food allergies. Why would the USDA which to jeopardize the health and safety of a significant part of the population? People with food allergies are covered under the American with Disabilities Act. Cuts to labeling will lead pretty quickly to lawsuits challenging discrimination against those with food allergies. Additionally, any injury or death that is caused by inaccurate labeling seems to be an unwise business decision.