From: Jennifer Seigal [hiylo@hotmail.com]
Sent: Tuesday, November 04, 2003 3:01 PM
To: fdadockets@oc.fda.gov
Subject: Trans Fat comments

Dear FDA,
You should  DEFINITLY make manufactures of food put on their packages that 
it contains Trans Fat even if it is .00001 gram. Any amount is neccessary 
for consumers to know about. would you want YOUR kids eating this aweful 
product? I don't, but how will parents know if the companies don't say on 
the products? This is a serious issue that affects you in the FDA commision 
and all americans. Do something about it before its your relatives with 
heart disease or a heart attack. Do something about it before its You. Do 
something fast because it is your responisiblity to protect from unsafe 
products.

My desire is for all products to be transfat free. But it is a step in the 
right direction to make all consumers aware of what their eating and to not 
let them be fooled into thinking their eating healthy when their not.

Jennifer Seigal


Docket No. 03N-0076
RIN 0910-AC50



__________________________________________________________________

Here are the comments that we submitted to the FDA.

BANTRANSFATS.COM

October 9, 2003

TO THE U.S. FOOD AND DRUG ADMINISTRATION

DOCKET NO. 03N-0076; RIN 0910-AC50

COMMENTS ON
ADVANCED NOTICE OF PROPOSED RULEMAKING
REGARDING TRANS FAT LABELING

INTRODUCTION

 These comments are made in response to the Advance Notice of 
Proposed Rulemaking (ANPR) published in the Federal Register on July 11, 
2003. [Fed. Reg., Vol. 68, No. 133, July 11, 2003 at page 41507.]

ABOUT OUR ORGANIZATION

 BanTransFat.com, Inc. is a non-profit corporation organized 
under the laws of the State of California.

 On May 1, 2003, we filed a lawsuit against Kraft Foods North 
America, Inc. seeking an injunction against the sale and marketing of Oreo 
cookies containing trans fat to children in California. As a result of the 
lawsuit, Kraft announced that almost across the board, it would eliminate 
trans fat, or cut it to about half a gram per serving in cookies and 
crackers. As we were successful in achieving our goal, we voluntarily 
dismissed the lawsuit.

 There was enormous national publicity during the week of May 
12, 2003 regarding the lawsuit. Tens of millions of people who were 
previously unaware of the presence and danger of trans fats in their food 
products suddenly became aware, and word is continuing to spread.

 On May 14, 2003, a poll was conducted by America Online 
regarding the lawsuit. 655,296 people voted. 26% responded that something 
needs to be done about the trans fat problem. This is a very substantial 
percentage  a quarter of the population. We believe that if a poll were 
taken of women only, the percentage would be much higher judging by the 
e-mail that we have received. This is important, because women are more 
likely than men to be the food purchasers for families.

 Our website has been visited more than 140,000 times since May 
12, 2003. Approximately, 75,000 visits have occurred since we dismissed the 
lawsuit. Hundreds of people visit the website every day. In fact, it would 
be fair to say that it is now the leading trans fat website in the world. A 
Google or Yahoo search for trans fat or trans fats will bring up our 
website at the top of the list. This is important because it means that we 
are almost certainly receiving more e-mail from people interested in the 
trans fat issue that any other governmental or non-governmental 
organization. We are able to assess the views of consumers simply by 
reading the thousands of e-mails that they have sent to us.

 The e-mails that we have received show that the American people 
are deeply concerned and very angry about the presence of trans fat in food 
and the lack of proper labeling. A selection of the e-mail is posted on our 
website, which we urge the FDA to review. It is a very valuable source of 
consumer research.

 We have not posted on the website the hundreds of e-mails that 
we have received from people who are confused by lists of ingredients that 
indicate the presence of partially hydrogenated oil, but zero grams of trans 
fat. However, we will be happy to provide such e-mails to the FDA upon 
request (with names removed).

THE FDAS MANDATE IS TO PROTECT
THE PUBLIC, NOT THE FOOD INDUSTRY

 Under the Nutrition Labeling and Education Act of 1990, the FDA 
shall require that the declaration of nutrients be conveyed to the public 
in a manner which enables the public to readily observe and comprehend such 
information and to understand its relative significance in the context of a 
total daily diet.

 There is a timing element implied in the statutory mandate. 
Unnecessarily deferring mandatory labeling until 2006 violates the mandate. 
Trans fat labeling was first proposed by the FDA as long ago as November 
1999. The FDA has estimated that 2,100 to 5,600 lives each year are being 
lost as a result of the bureaucratic delay. [Fed. Reg., Vol. 64, No. 221, 
November 17, 1999 at page 62772.]

 Walter Willett, M.D. of the Harvard Medical School, who is 
widely acknowledged as one of the worlds leading experts on nutrition, 
estimates that 30,000 or more cases of coronary heart disease are caused 
each year in this country by trans fats. [Eat, Drink, and Be Healthy: The 
Harvard Medical School Guide To Healthy Eating by Walter C. Willett, M.D, at 
p. 73.]

 The FDAs explanation is that the delay is necessary to 
minimize the need for multiple labeling changes and to provide additional 
time for compliance by small businesses to allow them to use current label 
inventories and phase in label changes. [Fed. Reg., Vol. 68, No. 133, July 
11, 2003 at 41466.] We are completely unimpressed by this explanation, and 
so too are large numbers of our supporters who have made their views known 
to us by e-mail. We feel compelled to remind the FDA that the statute 
requires the FDA to protect the public, not the food industry. The FDA 
has elevated an extremely minor commercial issue - preprinted label 
inventories - above its statutory responsibility to save lives and prevent 
disease. The FDAs state of mind concerns us and our supporters greatly. 
The FDA needs to work on rebuilding trust with consumers.

 While the FDAs decision on the timing issue is now behind us, 
the FDA in the ANPR is inviting comments about unresolved trans fat labeling 
issues. However, the initial signs in the ANPR are worrying. The six 
footnote options on which the FDA is seeking comments look like they were 
written by the food industry, or to appease the food industry.

 The FDA should solidly resist food industry pressure to 
underinform or misinform consumers, in violation of the statute and the 
FDAs moral responsibility.

SPECIFIC COMMENTS

 1. THE FOOTNOTE ISSUE

 In 2002, the National Academy of Sciences Institute of 
Medicine issued a report entitled Dietary Reference Intakes for Energy, 
Carbohydrate, Fiber, Fat, Fatty Acids, Cholesterol, Protein and Amino Acids 
(hereinafter the NAS Report). The NAS Reports conclusion was as follows:
There is a positive linear trend between trans fatty acid intake and total 
and LDL cholesterol concentration, and therefore increased risk of CHD, thus 
suggesting a Tolerable Upper Intake Level (UL) of zero. Because trans fatty 
acids are unavoidable in ordinary diets, achieving such a UL would require 
extraordinary changes in patterns of dietary intake. Such extraordinary 
adjustments may introduce other undesirable effects (e.g., elimination of 
foods, such as dairy products and meats, that contain trans fatty acids may 
result in inadequate intakes of protein and certain micronutrients) and 
unknown and unquantifiable health risks may be introduced by any extreme 
adjustments in dietary pattern. For these reasons, no UL is proposed. 
Nevertheless, it is recommended that trans fatty acid consumption be as low 
as possible while consuming a nutritionally adequate diet. (Emphasis 
added.)

 Based on the NAS Report, the FDA proposed in November 2002 that 
instead of a Daily Value, an asterisk would be placed on the right-side of 
the trans fat line of the Nutrition Facts panel directing the consumer to 
the following footnote:
INTAKE OF TRANS FAT SHOULD
BE AS LOW AS POSSIBLE.

 In July 2003, the FDA abandoned its position saying that the 
overwhelming majority of comments opposed the use of the footnote. [Fed. 
Reg., Vol. 68, No. 133, July 11, 2003 at page 41452.] It would appear that 
the FDA may have been swayed by the number of comments rather than the 
contents of those comments. The food industry is obviously far better 
prepared to flood the FDA with comments than the unorganized and uninformed 
public. The FDA should be concerned with what people say, not how many 
people say it.

 The FDA, in its ANPR, has now invited public comments on six 
footnote options. We discuss each in turn.

FDA FOOTNOTE OPTION ONE


INTAKE OF SATURATED FAT AND TRANS FAT SHOULD BE KEPT LOW WHILE MAINTAINING A 
NUTRITIONALLY ADEQUATE DIET.



COMMENTS

 A. We object to the omission of the words as low as 
possible. Those words were drawn directly from the NAS Report and are not 
in any way confusing. They are supported by the comprehensive and solid 
medical and statistical evidence cited in the NAS Report. The message is 
totally valid: try to avoid trans fat if you can.

 The argument that the words as low as possible would result in 
consumers steering away from products containing naturally-occurring trans 
fatty acids is a red herring. The problem is not naturally-occurring trans 
fatty acids. The problem is partially hydrogenated oils. Adding the words 
while maintaining a nutritionally adequate diet would send an appropriate 
message to consumers that they should adopt a balanced diet and not take 
extreme actions which might compromise their health.

 B. The word low, standing alone, is meaningless. It begs the 
question  how much is low? Low can only be understood in relation to 
quantifications of low and high. Low could be 2 grams, 10 grams, or 
50 grams. Consumers will not find the word low helpful in any way. The 
statute requires the FDA to establish labeling which advises consumers of 
the relative significance of nutrient information in the context of a 
total daily diet. The word low standing alone does not convey relative 
significance at all.

 C. The purpose of the footnote is to compensate for the fact 
that there would be no percentage Daily Value on the trans fat line. There 
is a percentage Daily Value for saturated fat and therefore no need for a 
footnote about saturated fat.

 D. We are very concerned with, and would object to, 
identification of trans fat with saturated fat. We need only look to the 
FDAs own findings in support of the Final Rule on trans fat labeling in 
July 2003 for support:
The agency acknowledges that declaring the amount of saturated fat and trans 
fat together, even with the proposed footnote, could lead some consumers to 
believe that the two types of fatty acids are chemically and physiologically 
the same. Clearly, trans fats contain double bonds and thus, are chemically 
distinct from saturated fat. Likewise, although both saturated and trans 
fats do raise LDL-C levels, physiologic distinctions between the two types 
of fatty acids do exist as discussed previously in Comments 10 and 11. 
Clearly, trans fats contain double bonds and thus, are chemically distinct 
from saturated fat. Likewise, although both saturated and trans fats do 
raise LDL-C levels, physiologic distinctions between the two types of fatty 
acids do exist as discussed previously in Comments 10 and 11. [Fed. Reg., 
Vol. 68, No. 133, July 11, 2003 at 41453.]

Accordingly, the agency concludes that it is necessary to disassociate 
saturated and trans fats on the nutrition label so that consumers do not 
misinterpret the declaration of saturated fat by thinking that trans fats 
are included in that definition. [Fed. Reg., Vol. 68, No. 133, July 11, 2003 
at 41453.]

The agency is persuaded by the large number of comments on this issue that 
the proposed action was, in fact, interpreted by many as incorrectly 
classifying the two different fatty acids as ``saturated fat'' and that it 
is necessary to disassociate trans fat from saturated fat to prevent 
misleading consumers in this way. [Fed. Reg., Vol. 68, No. 133, July 11, 
2003 at 41456.]

 The wording of Option One would equate trans fat and saturated fat in 
the minds of consumers, and would lead many consumers to believe that they 
are exactly the same. However, as the FDA acknowledged, trans fat is 
chemically distinct from saturated fat. The FDA found that the association 
of trans fat and saturated fat would mislead consumers. We agree.

FDA FOOTNOTE OPTION TWO
INTAKE OF TRANS FAT SHOULD BE KEPT LOW
WHILE MAINTAINING A NUTRITIONALLY ADEQUATE DIET.

COMMENTS

 See Comments A and B on Option One.

FDA FOOTNOTE OPTION THREE
INTAKE OF SATURATED FAT, TRANS FAT AND
CHOLESTEROL SHOULD BE KEPT LOW WHILE
MAINTAINING A NUTRITIONALLY ADEQUATE DIET.

COMMENTS

 See Comments A, B, C and D on Option One.

 A. We believe that addition of the word cholesterol adds even 
more confusion. As the FDA has pointed out, associating trans fat and 
saturated fat in the minds of consumers is misleading. Associating a third 
element, cholesterol, only compounds the problem.

FDA FOOTNOTE OPTION FOUR
AS PART OF A NUTRITIONALLY BALANCED DIET,
INTAKE OF SATURATED FAT, TRANS FAT, AND
CHOLESTEROL SHOULD BE KEPT LOW.

COMMENTS

 See Comments A, B, C and D on Option One and Comment A on Option 
Three.

 A. We object to Option Four because it makes it appear that 
trans fat is a beneficial and necessary part of a nutritionally balanced 
diet. The message is so perverse that consumers could be expected to try to 
increase trans fat input. Trans fat is not a necessary part of any diet. 
It has no known beneficial effects. The FDA found as follows:
FDA finds that the intervention and observational studies provided strong 
evidence of both a causal relationship between trans fat intake and risk of 
CHD and applicability to the general U.S. population. [Fed. Reg., Vol. 68, 
No. 133, July 11, 2003 at 41446.]

FDA FOOTNOTE OPTION FIVE
HEALTHY DIETS START WITH DIETS LOW IN
SATURATED FAT, TRANS FAT, AND CHOLESTEROL.

COMMENTS

 See Comments A, B, C and D on Option One, Comment A on Option 
Three, and Comment A on Option Four.

 A. We object to Option Five because it makes it appear that 
trans fat is healthy and a necessary part of a nutritionally balanced 
diet. It sounds like an advertisement for trans fat.

FDA FOOTNOTE OPTION SIX
NUTRITIONALLY ADEQUATE DIETS INCLUDE DIETS LOW IN SATURATED FAT, TRANS FAT, 
AND CHOLESTEROL.

COMMENTS

 See Comments A, B, C and D on Option One, Comment A on Option 
Three, Comment A on Option Four, and Comment A on Option Five.

OUR PROPOSED FOOTNOTE OPTIONS

 Our proposed footnote options, in order of preference, are as 
follows:

OUR FOOTNOTE OPTION ONE
INTAKE OF TRANS FAT SHOULD BE AS LOW AS POSSIBLE.

[The footnote could be omitted when there is no partially hydrogenated oil 
whatsoever in the product.]

COMMENTS

 This is the footnote that the FDA has apparently rejected. 
Nevertheless, it is clear, concise, and valid. It is based on the NAS 
Report. We strongly urge the FDA to reconsider its rejection of this 
wording. The words as low as possible are an essential part of any 
footnote. We believe that the words as low as possible are legally 
required in view of the FDAs findings about the dangers of trans fat and 
the NAS Report.

 The food industry is expressing concern that consumers will 
avoid meat and dairy products because they contain naturally-occurring trans 
fat. We believe that this concern is bogus. However, the FDA could allow 
the footnote to be omitted when there is no partially hydrogenated oil 
whatsoever in the product.

OUR FOOTNOTE OPTION TWO
THIS PRODUCT CONTAINS PARTIALLY HYDROGENATED OIL. INTAKE OF TRANS FAT FROM 
SUCH OILS SHOULD BE KEPT AS LOW AS POSSIBLE.

[The footnote could be omitted entirely when there is no partially 
hydrogenated oil whatsoever in the product.] 

COMMENTS

 This wording would address any concern about consumers avoiding 
meat and dairy products because they contain naturally-occurring trans fat. 
It would also inform consumers about the connection between partially 
hydrogenated oils and trans fat, which is a positive and important 
educational step.

OUR FOOTNOTE OPTION THREE
INTAKE OF TRANS FAT SHOULD BE KEPT AS LOW AS POSSIBLE WHILE MAINTAINING A 
NUTRITIONALLY ADEQUATE DIET.

COMMENTS

 This option is far less preferable than our other two options. 
Our concern with this option is that it seriously dilutes, weakens and 
confuses the message about trans fats. However, if adding the words while 
maintaining a nutritionally adequate diet is the price that we have to pay 
to obtain acceptance of the words as low as possible, then as a matter of 
practical politics it may be a price worth paying.

 2. TRANS FAT-FREE CLAIMS

 We have received more e-mail about products that list a 
partially hydrogenated oil in the ingredients, but show zero grams of trans 
fat or claim to be trans fat-free, than any other subject. We have now 
taken steps to make sure that visitors to our website clearly understand 
that the law provides that if a product contains less than 0.5 grams of 
trans fat, the content must be expressed as zero, except when the statement 
Not a significant source of trans fat is used. It is unfortunate that 
they have to rely on our website to clear up their understandable confusion.

 We are not concerned with fine and meaningless distinctions 
between stating that a product has zero grams of trans fat and claims that 
it is trans fat-free. As far as the consumer is concerned, they mean 
exactly the same thing  that the product contains no trans fat. We are not 
confident that the FDA appreciates this point.

 We are surprised and puzzled at the FDAs issuance of the 
rule requiring rounding down to zero, because it is totally inconsistent 
with the following findings made by the FDA as the basis for the Final 
Rule:
As the agency has explained earlier, consumers need information about trans 
fat on all foods, not just those that contain a certain threshold level of 
trans fat, to reduce overall intake of trans fat in the diet. [Fed. Reg., 
Vol. 68, No. 133, July 11, 2003 at 41439.]

Consumers need to know when a product contains less than 0.5 g trans fat 
just as much as they need to know when a product contains 1, 2, or more 
grams of trans fat in order to understand how each product impacts their 
overall dietary intake of trans fat. Such need is not based solely on the 
presence or absence of claims, levels of other fats, or declaration of other 
fats on the label. Consumers need to understand how each product contributes 
to their overall intake of trans fat in order to maintain healthy dietary 
practices which call for reducing trans fat intake as low as possible while 
consuming a nutritionally adequate diet. Consumption of several foods, each 
with 0.5 to 1 g trans fat per serving, over the course of a day may result 
in a significant overall trans fat intake for the day. [Fed. Reg., Vol. 68, 
No. 133, July 11, 2003 at 41451.]

It is the provision of trans fat information on foods consumed throughout 
the day that can assist consumers in maintaining healthy dietary practices, 
and the usefulness of this information is not limited to foods with certain 
nutritional characteristics. In addition, the consumption of several foods 
with 0.5 or 1 g of trans fat per day that may provide a total of 8 g of 
trans fat to the diet would be expected to have the same effect on LDL-C 
levels as consumption of one food with 8 g trans fat. Requiring trans fat to 
be declared only when present at a specified level would be inconsistent 
with statutory directives for nutrition labeling in section 403(q)(1) of the 
act, where amounts of nutrients of public health significance are required 
to be listed, regardless of the amount. [Fed. Reg., Vol. 68, No. 133, July 
11, 2003 at 41451.]

The agency believes that the absence of information of the amount of trans 
fat in a product, when labeling of trans fat as a mandatory nutrient is 
required, even where trans fat is present at less than 0.5 g, would be 
misleading. [Fed. Reg., Vol. 68, No. 133, July 11, 2003 at 41451.]

 The FDA in its Final Rule is requiring that if the serving 
contains less than 0.5 gram, the content, when declared, shall be expressed 
as zero. This makes no sense at all in view of the FDAs findings. It is 
misleading, arbitrary and capricious, and violative of the statute.

 Here are some of the unsolicited e-mails that we have 
received from the public on this subject:
I saw a package of Doritos that has a statement on the front of the bag 
saying it contains zero grams of trans fats. Yet the ingredient list 
includes the words "partially hydrogenated." Can they do that? Is the 
amount so minimal it doesn't add up to a single gram and that's the logic 
behind the statement?

* * *

I have written to the 'dietician' at Take Control (butter substitute/spread) 
with this question: The label says that there are no trans fatty acids. 
However, it also says that Take Control contains partially hydrogenated 
soybean oils. Wouldn't that process produce trans fats? I have not 
received an answer from them. Hope you can help. It has
been such a struggle with high cholesterol, LDL, in spite of exercise, a 
basically vegetarian diet, etc.

* * *
I recently found your website and was curious. You said that Frito Lay was 
getting rid of trans fat in their products. I just grabbed a Cheetos bag 
and while it says 0g Trans Fat, the ingredients include partially 
hydrogenated soybean oil. Can you clear this up for me?

* * *

How is it that the nutritional facts statement says 0 grams of Trans Fats 
but the ingredients list partially hydrogenated soy oil? Doesn't partially 
hydrogenating oil create trans fats? Hope you can offer some insight.

* * *

I noticed recently that some Frito Lays potato chips are showing trans fat 
contents and some have a "stamp" at the front of the package saying "... 0 g 
trans fat". When reading the ingredients, it was found that the BBQ 
flavored (code 0 28400 01473 1) has partially hydrogenated soybean oil 
listed in the ingredients, despite the flashy "stamp" at the front saying 
its free of trans fats. The regular flavor was OK, no trans-fats were 
listed in the ingredients (code 0 28400 01472 1). A small package bought at 
"Rolly Polly" in NE atlanta suburb had the same deceiving "stamp" and trans 
fat included in the ingredients. I tried to call Frito Lays and complain, 
but the line is always busy (800-352-4477). This cannot continue. Now it is 
"in your face" fraud.

* * *

I just munched on some Frito Lay Doritos and in the Nutrition facts, it says 
no Trans Fats. Yet in the ingredients, it has partially hydrogenated soybean 
oil listed. Is that because the serving is so small that it's to minimal to 
list? I
hope we are going to be able to trust the labels to tell the truth!

* * *

I have a question about the labeling. I bought Jolly Times Health Pop at 
Shop Rite last night. I bought it because it stated that it was Trans fat 
free, but then when I got home I read the ingredients and it says that it 
has partially hydrogenated soybean oil. I am confused. Does it have Trans 
fat? It is okay if I do not get a response. I kind of know the answer. 
Companies should not be allowed to false advertise if this product is not 
Trans fat free.

* * *

I just purchased "Jolly Time Healthy Pop Butter Flavored" microwave popcorn. 
I bought it, because right on the front cover, it says "Trans Fat Free". 
However, when I got home and looked at the ingredients, it clearly states, 
"Partially Hydrogenated Soybean Oil".

How can these companies sell their products on the bandwagon of Trans Fat 
Free when they aren't in fact trans fat free? Isn't this a case of false 
advertising? Is there anything that can be done about this? I wrote to the 
company, but I am sure they don't care what one customer thinks. I am taking 
the popcorn back to the store. Thanks for your time.

* * *

Not sure if you guys already knew this, but Jolly Time is guilty of false 
advertising. I just bought a box of Jolly Time - Healthy Pop "TRANS FAT 
FREE" popcorn. Its there as plain as day on the label. However the second 
ingredient is, guess what? Partially Hydrogenated Soybean Oil. What could 
they possibly be thinking? I have made a complaint on their website and 
placed a Better Business Bureau complaint on American Pop Corn Company in 
Sioux City, IA, the makers of Jiffy Pop (says so on the box). What they are 
doing considered a misdemeanor. And, they can't claim that they don't know 
what a TF is.... I
would like your help in nailing these guys. I'm so livid I could scream!

* * *

PLEASE do not allow items labeled 'trans fat free' if there is ANY in there 
at all! I have to seriously watch my intake and it would very confusing to 
me if I saw 'trans fat free' and it still had .45 grams in there!

 The public needs to have this issue clarified, on the label. 
Therefore, we propose that the following statement be added at the beginning 
of the footnote whenever partially hydrogenated oils are listed in the 
ingredients, but the trans fat content is shown as zero grams:
THIS PRODUCT CONTAINS TRANS FAT
IN AN AMOUNT LESS THAN 0.5 G PER SERVING.
CONSUMPTION OF SEVERAL SERVINGS MAY
RESULT IN A SIGNIFICANT OVERALL TRANS FAT
INTAKE.

 This proposed wording will clearly inform the public and 
should prevent them from being misled. It is a necessary corrective 
measure. It is based on the FDAs own finding that consumption of several 
foods, each with 0.5 to 1 g trans fat per serving, over the course of a day 
may result in a significant overall trans fat intake for the day. [Fed. 
Reg., Vol. 68, No. 133, July 11, 2003 at 41451 (emphasis added.).]

 Trans fat-free, zero grams of trans fat, or substantially 
similar claims, claims should be prohibited whenever any trans fat is 
present.

 3. THE TIMING ISSUE

 The current state of affairs is that food manufacturers are 
permitted to state the trans fat content of their products on the Nutrition 
Facts panel, with a blank space instead of a Daily Value. This is a 
dangerous situation, because consumers are very likely to interpret this as 
meaning that they can consume unlimited amounts of trans fat without any 
adverse consequences. It is also, unquestionably, a violation of the 
statutory requirement that the relative significance of the trans fat 
content be stated. Therefore, we request that the FDA move forward with a 
Proposed Rule and the Final Rule as soon as possible. Delay is costing 
lives.

CONCLUSION

 Finally, we quote the FDA once again:
These survey data show that consumers rely on the Nutrition Facts label as a 
guide to choosing foods that meet their dietary objectives. As consumers 
learn more about the dietary significance of trans fat and the dietary 
advice to limit its consumption, the Nutrition Facts panel is where label 
users will expect and want to find this information. If they cannot find 
information on trans fat content there or if it is only there when claims 
are made about fatty acids or cholesterol, they will be hampered in their 
ability to implement the most recent dietary guidance, and are likely to be 
misled about a food's basic characteristics. [Fed. Reg., Vol. 68, No. 133, 
July 11, 2003 at 41450.]

 The FDAs decisions on trans fat labeling will affect 
consumers for many years to come, probably decades. Millions of lives will 
be affected by the FDAs decisions on what goes on the label. People will 
suffer heart attacks and die unnecessarily if the FDA breaches the public 
trust and makes the wrong decisions.

 We strongly urge the FDA to act only in the best interests of 
the consumer and not allow itself to be swayed by bogus concerns expressed 
by the food industry that are designed to prevent consumers from receiving 
the information that they need.

 Sincerely,



  Stephen L. 
Joseph

 Chief Executive 
Officer


 2003 BanTransFats.com, Inc.



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