My name is Lisa Katic and I am the Director of Scientific and Nutrition Policy for the Grocery Manufacturers of America. GMA represents approximately 90% of food, beverage and consumer products sold at retail. As an initial matter I would like to commend FDA for holding this public meeting to collect information on the labeling of the major allergens.

The GMA member companies are committed to meeting the needs of the food allergic community. GMA, along with numerous other food trade associations, formed the Allergy Issues Alliance several years ago because the food industry wanted to proactively address the allergen issue. The Food Allergy and Anaphylaxis Network is an integral part of the Allergy Issues Alliance. As the association that represents food allergic consumers, FAAN is best positioned to provide insight into the labeling practices that would be of most use to this subset of the population.

Regina Hildwine already has mentioned the voluntary program that has been developed by the Allergy Issues Alliance. That voluntary program, which the Alliance released this spring, is the culmination of several months of work by the Alliance members, including the Food Allergy and Anaphylaxis Network. Unlike a regulatory process that will take several years to develop and implement, the Alliance’s voluntary program is now in the implementation stage. GMA’s Board of Directors has adopted the Alliance’s labeling program and the CEO’s of each of our member companies are being asked to implement the program. We fully expect widespread adoption and implementation of the Alliance’s labeling program by our GMA member companies-which account for 170 companies representing the $460 billion industry.

With regard to the plain English labeling, the Alliance’s labeling program specifically addresses this issue and requires the use of the plain English name on the label of foods that contain an allergenic protein that is derived from one of the major allergens. We recognize that it can be a daunting task for the food allergic consumer to learn the names of all of the ingredients that may be derived from an allergen. Milk is a classic example because there are numerous ingredients derived from milk. In accordance with FDA’s regulations, each of these milk-derived ingredients must be declared in the ingredient statement by a different name. Casein, sodium caseinate, and whey are just a few examples of the milk-derived ingredients that must be avoided by a consumer with a milk allergy. The Alliance’s labeling program makes it easier for the milk allergic consumer to identify products that he or she needs to avoid by requiring the use of the common term “milk,” in addition to the name of the ingredient, on the label of foods that contain an allergenic protein from milk.

As the agency is well aware, we have a tremendously diverse food supply that uses a wide variety of ingredients, packaging materials and packaging sizes. Given this variety, there must be flexibility in presenting the common names of the allergens. The Alliance’s labeling program provides this flexibility by offering options for presenting the major allergen’s common name. For example, a manufacturer could use parenthetical statements that identify the plain English name of the allergen in the ingredient statement after the ingredient that is derived from the allergen. An “Allergy Information Statement” also could be placed on the label that lists the common names of each of the major allergens in the food. And the Alliance’s labeling program provides other means of presenting the name of the common allergen. The plain English name would appear either in the ingredient statement or in immediate proximity to the ingredient statement.

In summary, we support the use of the common, plain English names on the labels of foods that contain a major allergen and we believe that the Alliance’s labeling program sufficiently addresses how this information should be presented. Because we anticipate widespread adoption of this program by the food industry, we believe that allergen-labeling regulations are unnecessary. Thank you.

• Gene Grabowski
  

COMMENT
• September 1, 2001  Scientific Analysis Regarding Objectionable Matter in Food
NEWS RELEASE
• August 13, 2001  Food Industry Leading Efforts To Better Inform Consumers About Food Allergies
• May 31, 2001  GMA, Food Allergy Alliance Develop "Easy to Understand" Labeling Guidelines
TESTIMONY
• August 13, 2001  Advisory Labeling of Major Food Allergens
• August 13, 2001  GMA Testimony to FDA on Common English Name Labeling

COMMENT
• April 5, 2002  The Codex “Proposed Draft Amendment to the General Standard for the Labeling of Prepackaged Foods: Quantitative Declaration of Ingredients”
• December 21, 2001  Traceability & Labeling Provisions of Proposed Regulations on Genetically Modified - Food & Feed and Traceability & Labeling
• August 30, 2001  Traceability & Labeling Provisions of the Proposed Regulations on Genetically Modified Food & Feed and the Traceability & Labeling of Genetically Modified Organisms
• July 10, 2001  ICGMA Comments on Australian Country-of-Origin Labeling Proposal
• March 28, 2000  Guidance on Significant Scientific Agreement
CORRESPONDENCE
• January 14, 2003  GMA Letter to FDA Calling for Mutual Recognition of Labeling Standards in North America
• September 12, 2001  GMA Urges Mutual Recognition on Food Labeling between the U.S. and Canada
• November 30, 2000  GMA Supports Canadian Move to Harmonize Nutritional Labeling
• November 12, 1999  In Letter to Clinton, 38 Food, Farm Organizations Urge President to Support FDA Food Biotechnology Policy
NEWS RELEASE
• July 22, 2003  GMA SAYS BIOTECH TRACEABILITY, LABELING RULE WILL INHIBIT TRADE
  EU Labeling Rule Not Supported by Science
• May 29, 2003  GMA RECOMMENDS NEW, EFFICIENT QUALIFIED HEALTH CLAIMS APPROVAL PROCESS
• November 6, 2002   OREGONIANS REJECT MANDATORY BIOTECH LABELING
• May 8, 2002  GMA Says Lawsuit Calling for Warning Labels Unfounded; FDA and California Attorney General Say Chocolate is Safe
• May 7, 2002  .
• August 13, 2001  Food Industry Leading Efforts To Better Inform Consumers About Food Allergies
• July 27, 2001  CURRENT LABELING LAWS ALLOW CONSUMERS TO MAKE "SMART BUYING DECISIONS"
• May 31, 2001  GMA, Food Allergy Alliance Develop "Easy to Understand" Labeling Guidelines
• May 23, 2001  GMA Says Massachusetts Mandatory Labeling Bill "Unnecessary And Redundant"
• May 4, 2001  U.S. Industry and Government Position Prevails on Biotech Labeling at Codex
• May 3, 2001  FDA POLICY KEEPS IMPORTANT HEALTH INFORMATION FROM PUBLIC, GMA TELLS CONGRESS
• January 17, 2001  FDA PROPOSAL FOR BIOTECH LABELING AND PRODUCT APPROVAL "A VICTORY FOR CONSUMERS"
• November 18, 1999  GMA: FDA Biotech Labeling Policy Protects Consumers, "Serves The Public Interest"
• November 15, 1999  Three Dozen Food, Farm Groups Urge President to Support FDA Biotech Policy
• June 11, 1999  GMA: NATIONAL UNIFORMITY FOR FOOD ACT REPRESENTS "COMMON SENSE CONSUMER INITIATIVE" House Bill Introduced by Rep. Burr; Companion to Sen. Roberts' Measure
• May 27, 1999  GMA: COMMON SENSE BILL PROVIDES UNIFORM, SCIENCE-BASED FOOD LABELING STANDARDS FOR CONSUMERS
• May 11, 1999  GMA: "TIME IS RIPE" FOR FDA TO RECONSIDER AND REVISE HEALTH CLAIMS APPROVAL PROCESS
• September 1, 1998  FOOD INDUSTRY URGES FDA NOMINEE TO PUT FOOD ISSUES ON EQUAL LEVEL
TESTIMONY
• March 10, 2003  GMA Testimony in Opposition Connecticut Biotech Food Labeling Bill
• April 8, 2002  GMA Letter of Opposition to California Trans Fatty Acids Labeling Bill
• March 25, 2002  GMA Letter of Opposition to Mandatory Rhode Island rBST Labeling Bill
• February 5, 2002  GMA Letter of Opposition to Hawaii Biotech-Free Food Labeling Bill
• October 9, 2001  GMA Letter of Opposition to Puerto Rico Biotech Food Labeling Bill
• August 13, 2001  Advisory Labeling of Major Food Allergens
• August 13, 2001  GMA Testimony to FDA on Common English Name Labeling
• June 28, 2001  GMA Testifies in Opposition to Suffolk County, NY Bottled Water Labeling Resolution
• May 31, 2001  Food Allergy Issues Alliance Labeling Guidelines
• May 30, 2001  GMA Letter in Opposition to New York Product Dating Labeling Bill
• May 23, 2001  GMA Testifies Against Massachusetts Bill for Mandatory Labeling of Biotech Foods
• May 7, 2001  GMA Testifies in Support of FDA Biotech-Free Labeling Guidance at New York Hearing
• May 3, 2001  FDA POLICY KEEPS IMPORTANT HEALTH INFORMATION FROM PUBLIC
• April 17, 2001  GMA Comments on USDA/GIPSA Advanced Notice of Proposed Rulemaking
• April 13, 2001  GMA Letter of Opposition to Mass. Green Dot Labeling Legislation
• April 11, 2001  GMA Testifies in Support of FDA-Based Maine "Biotech-Free" Labeling Bill
• March 29, 2001  Expert Witness Testifies on Behalf of GMA in Opposition to Maine Mandatory Biotech Food Labeling Bill
• March 29, 2001  GMA Letter in Opposition to Maine Mandatory Biotech Food Labeling Bill
• March 21, 2001  GMA Testifies in Opposition to New Hampshire Mandatory Food Biotechnology Labeling Bill
• March 21, 2001  GMA Testifies in Support of FDA GMO-Free Labeling Guidance at Minnesota Hearing
• March 21, 2001  Voluntary Labeling Indicating Whether Foods Have or Have Not Been Developed Using Bioengineering
• March 15, 2001  Letter in Opposition to Connecticut Prop 65 Clone Bill
• February 15, 2001  GMA Letter in Opposition of Nebraska Product Origin Labeling Bill
• February 14, 2001  GMA Letter in Opposition to Florida "Sell By" Product Dating Bill
• February 9, 2001  GMA Letter of Opposition to Colorado Biotech Food Labeling Bill
• February 9, 2001  GMA Letter of Opposition to Rhode Island rBST Labeling Bill
• February 7, 2001  Biotech Labeling Legislation Pending In Mexico
• February 29, 2000  GMA Testimony, Connecticut Warning Label Legislation, SB 433
• November 18, 1999  GMA Testimony on Biotechnology: FDA Biotech Labeling Policy Protects Consumers, "Serves The Public Interest"
• June 23, 1999  GMA Urges Veto Of Senate Bill 945
• May 10, 1999  GMA Opposes HB 3136
• April 12, 1999  GMA Opposes Legislative Docket 1985
• April 12, 1999  GMA Opposes Legislative Docket 713
• March 10, 1999  GMA Opposes House Bill 887
• July 28, 1998  The Transatlantic Economic Partnership

NEWS RELEASE
• May 3, 2001  FDA POLICY KEEPS IMPORTANT HEALTH INFORMATION FROM PUBLIC, GMA TELLS CONGRESS
• May 19, 1999  GMA: REDUCED TARIFFS, GREATER MARKET ACCESS FOR FOOD PRODUCTS MUST BE U.S. GOALS AT WTO TALKS
• March 16, 1999  FOOD INDUSTRY SUPPORTS INCREASED FOOD SAFETY FUNDING, GMA TELLS KEY HOUSE, SENATE PANELS But Says Congress Should Reject General Purpose User Fees
• March 2, 1999  U.S. FOOD INDUSTRY WELL PREPARED FOR YEAR 2000 GMA, FMI Testimony Shows Food Manufacturers and Retailers Ready for Y2K
• October 2, 1998  U. S. Food Safety Can Be Enhanced Within Existing Regulatory Framework, GMA Tells Presidential Panel
• August 20, 1998  U.S. Food Industry Applauds NAS For Including Science-Based Approach For Food Safety Task Force Cautions Against Disruptive Agency Reorganization
TESTIMONY
• August 15, 2001  Food Fight in the New Economy: The Taxation of Food
• August 13, 2001  Advisory Labeling of Major Food Allergens
• August 13, 2001  GMA Testimony to FDA on Common English Name Labeling
• May 3, 2001  FDA POLICY KEEPS IMPORTANT HEALTH INFORMATION FROM PUBLIC
• September 14, 1999  Slotting Allowances
• September 14, 1999  Wisconsin Recycled Content Bill
• June 24, 1998  GMA Comments On FDA CFSAN Priorities
• March 31, 1998  The Administration's FY1999 Proposed Budget
• February 24, 1998  APEC Sectoral Liberalization And The Stability Of Asian Economies