Letter to FDA Regarding Petition for Whole Grain Descriptors
Division of Dockets Management
Food and Drug Administration
5630 Fishers Lane, Room 1061
Rockville, MD 20852
June 20, 2005
RE: FDA Docket No. 2004P-0223: Petition to Establish Descriptive Claims for Whole Grain Content
Dear Sir or Madam,
The Soyfoods Association of North America (SANA), the national trade association representing the soy foods industry and a trusted resource in providing and disseminating information about the health benefits related to soy consumption, wishes to comment on the above-referenced citizen petition, which seeks to establish criteria for the descriptive claims “excellent source,” “good source,” and “made from” whole grain content under FDA’s authority. SANA shares FDA’s goal of providing consumers with accurate, truthful, and non-misleading information regarding whole grain content, and agrees with the purposes of this petition.
SANA respectfully submits that the definition of “whole grains” described in this petition, as revised on December 20, 2004, should include soy beans as an example of a generally accepted whole grain. The inclusion of soy beans in this definition is reflective of soy beans long been considered whole grains both in the food trade industry and the current USDA grain standard, which states,“Grain that consists of 50 percent or more of whole or broken soy beans..” (1) To promote clarity and consistency in whole grain claims, we urge FDA to include soybeans as a specific example in any definition or listing of “whole grains” offered for regulatory purposes.
Our members use soy beans as a valuable source of whole grains in soy flours, soy pastas, breads, cereals, and other products, as well as dairy analogs and meat alternatives. Soy-based grain foods and other soy foods provide many health and cardiovascular benefits, and make a meaningful, healthy contribution to consumer intakes of whole grains– meeting the goals of the new U.S. Dietary Guidelines for Americans.
Governmental agencies and the commodity industries support and recognize soy beans as whole grains in the food supply. We urge FDA to establish similar recognition to include soy beans in the regulatory definitions of whole grains in this petition and other regulatory standards. Thank you for your consideration.
Respectfully submitted,
Nancy Chapman, RD, MPH
Executive Director
References:
(1) U.S. Grain Standards Act- 7 C.F.R. s 810.1601
