I sent the following email to the FDA and I suggest that others send a similar email.
"In the press release called "FDA Asking for Public Comment on Food Label Changes" (Docket number P05-15? and found at http://www.fda.gov/bbs/topics/news/2005/NEW01170.html ), it says "Additionally, the agency is seeking comment on the reformulation of the foods or redesign of packaging that may occur if any changes are made to the food label." I am thus submitting comments regarding a redesign on the nutrutional food label. Metric is my preferred system of measurement. I thus find it frustrating on food packages where net contents volume is listed (such as fl. oz. and ml), but where the metric portion of the Nutrional Facts Serving Size section of the food label is often stated in g (though the USA Customary unit used is a still a volume measure (such as tablespoon or cup)). Grams (g) are mass (or "weight") measure and thus is inconsistent with the volume measure of the entire product (ml or L). This makes things very inconsistent, though the grams part is consistent with the portion that lists fat, carbohydrates, and protein in grams. I will suggesst to the FDA that the Nutrional Facts portion of the label for Serving size, list it in BOTH volume and "weight" (mass) metric units when the FPL label (the net contents portion) on the package is in volume units. Likewise in regards to frozen juice (and items with similar labels), when the label states the volume of the reconstituted juice (finished product when water is added), metric units should be included, not just US Customary Units. In addition I prefer metric instead of US Customary units (inch-pound-gallon system). I therefore wish that the Fair Packaging and Labeling Act (FPLA) be ammended to allow metric only labeling (in other words, keeping metric units on the package mandantory, but making US Customary units on the package optional). This will help the country to make progress in adopting metric as the official measurement system, and it would be in harmony with the US government (including the commerce department) declaring that metric is the PREFERRED system of measurement in the USA. I am both a consumer and a business owner who loves metric, see my website at http://www.RenewableElectricity.com for information about reasons for the country to go metric. Following is an example of what I'm talking about: Flavorite Frozen Concentrate Orange Juice says "NET 12 FL OZ (355 mL)". Both of those measurements are for volume. The Nutritional Facts portion says "Serving Size 1/4 Cup (71g)". Cups are volume, but grams are "weight" (technically mass). The metric portion should thus say "(59 mL, 71 g)", since "71 g" can not be easily compared to "355mL, unlike "12 FL OZ" and "1/4 Cup" which are consistent in both being volume measurements. The label then says "Makes 8 fl oz of finished product" and "Servings Per Container 6". It should say "Makes 8 fl oz (237 mL) of finished product" or "Makes 237 mL (8 fl oz) of finished product". The portion that says "Servings Per Container 6" can stay the same. The label says "Calories 110". It really should say "Kilocalories 110" since the food Calorie (with the capital "C") is really the "kilocalorie (namely 1000 calories)" in the old metric system. However the new metric system (SI Metric) uses kilojoules instead calories (or Calories or kilocalories) as the basic unit of energy. Therefore it would be even better to indicate the energy content in kilojoules. The portion of the label that states the grams (or miligrams) of fat, minerals, carbohydrates, and protiens can stay the same, however the grams of transfat (whether artificially hydrogenated or naturally containing transfat) should also be in the label. Thanks for considering my suggestions. I look forward he hearing from you regarding the FDA's view of these suggestions and whether they plan use any of them." ----- Original Message ----- From: "Pierre Abbat" <[EMAIL PROTECTED]> To: "U.S. Metric Association" <[email protected]> Sent: Tuesday, 05 April, 2005 05:40 Subject: [USMA:32619] Re: Food Labeling - a chance for feedback from USMA members! > On Monday 04 April 2005 12:14, Hillger, Don wrote: > > From one of our more active USMA members: > > > > > > > > The FDA is starting to look at changes to nutrition labels: see > > http://www.fda.gov/bbs/topics/news/2005/NEW01170.html > > > > > > > > (Not really any direct relevance to metric labeling. The bottom of the > > release has pointers to the notices, which are scanned so rather huge, > > 1.1MB and 1.5MB). > > > > > > > > The USMA President is urging members to use this as an opportunity for > > metric proponents to suggest kilojoules. But since the FDA's entire > > focus is on calories, kilojoules for energy or even dual labeling with > > calories/kilojoules would probably not be even slightly palatable to > > them. But it is an opportunity to give input and alert the FDA that > > some Americans think it is time to "think kilojoules." > > The second notice is about serving sizes and says that they should be > expressed in "common household measures". We should point out that, although > kitchen scales are not as common here as in other parts of the world, > measuring cups are, and they commonly have a milliliter scale, thus the > milliliter is a common household measure, despite the sentence implying that > it isn't. > > phma > -- > Now I need a magnifier to find my eyeglasses! > -Les Perles de la m�decine > -- No virus found in this outgoing message. Checked by AVG Anti-Virus. Version: 7.0.308 / Virus Database: 266.9.6 - Release Date: 2005-04-11
