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Am I pronouncing these right?
Dr. JACKEL. You qualify.

Mr. Botty. But, B, is the only one of many vitamins and nutrients that are often added at the flour mill. Others that would be included under the new requirement are niacin, iron, riboflavin, known as vitamin B2, calcium, all of which have several alternative sources of origin that also must be listed.

Mr. Chairman, we have covered only flour and I submit you can already see the confusion for the consumer and economc restriction on the baker. Let's go down the list of affected ingredients.

No. 2. Sweeteners: The new.order makes it necessary that the various categories of natural sugars be broken down in far greater detail than is now required. Thus, in place of the class name "corn sweeteners" we will have to label specifically either corn syrup, dextrose, fructose or corn sugar. Cane or beet sugars are required to be listed as well, so in natural sugars alone we have six kinds to restrict supply. I'm concerned that under the new regulations we would not have the flexibility of switching to another sweetner source. Economic reasons, disasters and/or strikes might make it a necessity for us to switch from liquid dextrose to liquid high fructose corn syrup. We in the industry have found this move would give us certain latitude and flexibility over competitive pricing situations. For example, under the present proposal, our liquid dextrose would have to be listed as "dextrose.” High fructose corn syrup has to be listed as "corn syrup." Our ingredient legend would have to list one or the other, but could not list both of these sweeteners. On the other hand, if for some unknown reason we had to switch to granulated sugar, we would be restricted in this move because granulated sugar has to be listed as "sugar" or "sucrose." All these labeling regulations remove a lot of our flexibility. Consequently. the cost of continually changing labels will have to be passed on to the consumer. In some cases, the idea of changing labels will be almost impossible and impractical.

No. 3. Shortening: The only place that FDA has recognized our problem is shortening. Here on January 1, 1978, labels can state, “Blend of vegetable and animal shortening-soybean, cottonseed and/or palm oils, lard and hydrogenated beef fat.” While we appreciate this help, we wonder if the consumer is better off and less confused.

No. 4. Water: This has not been brought up by FDA, but how will they treat this critical ingredient in bread products. They eventually will want all water treatments to be listed. Will we be able to bake in Philadelphia or west Texas or California where water must be chemically processed? Or, will FDA require localized listing of water additives?

No. 5. Dough conditioners: Since February 21, 1940, FDA has permitted the baking industry to use the common words "leavening, "yeast nutrients" and "dough conditioners" on labels of bread and rolls. But, on January 1, 1978, after 37 years of suitable labeling without any problems. FDA's rules will change and specific chemical names will have to be listed.

This is another area that removes our flexibility: (a) it locks us into a specific product; (b) it locks us into a set amount of that product. Dough conditioners and softeners are varied due to time of the year.

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As an example, one should have a tendency to use more dough conditioners or softeners in the winter than one would use in the summer. By changing the amount you use, the ingredients in the dough conditioners of softener would also be changed. This change would mean that the ingredient listing would also have to be altered to be in compliance with the Federal regulations. Again, this change in the ingredient listing is impractical, if not impossible to do.

Dough conditioners are chemically complicated and specialized ingredients which are often available from only one source due to patent protection or trade secrets. The baker will be seriously restricted in his formula and process under the new rules because he will be tied to the chemical name on his wrapper. The consumer will be faced with names such as ethoxylated mono and diglycerides, calcium stearoyl-2-lactylate—how do you pronounce the next one?

Dr. JACKEL. Succinylated monoglycerides.

Mr. Botty. Sodium stearoyl-2-lactylate and polysorbate 60. Certainly only a graduate chemist is served by such label requirements.

Remember, baked products are a perishable item and are subject to all kinds of conditions as well as different reactions in different shops in different times of the year. Without flexibility, we are unable to give a high-quality product to the consumer without additional costs which should not be necessary.

6. Yeast foods: These are processing aids only, but are also specialized and complicated. Baked products are a living, perishable item that have sustained man for 5,000 years and are subject to a great variety of conditions as well as different reactions in different locations at different times of the year. Without reasonable production flexibility, we will be unable to give a high quality product to the consumer without additional costs to the consumer, a cost we feel should not be necessary.

To a large extent, yeast foods undergo chemical change in the baking process, but they will still have to be listed in the new rules. In the past they were listed as "yeast nutrients” as outlined in the 1940 FDA Trade Correspondence No. 94. The chemical names which will now be required as hardly in the average housewife's vocabulary, ammonium chloride, ammonium sulfate, calcium sulfate, monocalcium phosphate, potassium bromate, potassium iodate, and–Dr. Jackel, you take the next one!

Dr. JACKEL, Azodicarbonamide.

Mr. Botry. The regulation removes our flexibility of increasing or decreasing the amounts that we need to use to meet widely varying production conditions.

7. Leavening. Baking powder, certainly a common name to each of us, will now be known as sodium aluminum pyrophosphate

Dr. JACKEL. Glucono-deltalactone.

Mr. BOTTY [continuing). Or similar ominous chemical words. Is clarity served by this ridiculous change? The label

requirements for leavening, dough conditioners and yeast foods, Mr. Chairman, were all changed without hearing or notice by FDA in a most arbitrary manner. This alone justifies cancellation, modification or postponement of FDA Order 21 CFR 101.4; formerly 21 CFR 1.10.

I would like to have Dr. Jackel make a statement at this point.

Dr. JACKEL. Mr. Chairman, in 1940, when the Food and Drug Administration issued the trade correspondence to the baking industry they did so deliberately and after considerable study. It was not haphazard. It was a sound, scientific, developed course of action. In their judgment at that time the needs of the consumer were adequately served by using "dough conditioners," "yeast nutrients,” and leavening

In the 37 years that this has been in practice, bakers have been comfortable with this terminology and have learned to operate an industry that serves the utmost level of nutrition and over the years have earned the reputation of being the quiet martyrs in the sense that beri-beri, that results from vitamin B deficiency, has been completely eradicated in the United States. The reason is that bread is so widely distributed and is such a basic food.

Recognizing the unique nature, the Food and Drug Administration established categories so that the consumer could be advised of ingredients, but in a way that they allowed bread to be what it is intended to be, a nutritional and basic food.

This order merely serves to confuse the consumer and to take away the flexibility from the baker to provide the consumer the best type of food available.

There is a very important point here that should be recognized. There is a reason—bread goes back 5,000 years. Bread is in the Bible. Bread is known as the staff of life. No one talks about ice cream as the staff of life or the canned peas as the staff of life and there is a reason for it. Bread is baked from basically agricultural commodities.

The baker does not bake for inventory. The baker bakes a living product. This product is fresh. If these additives are not added that bread becomes stale. In the old days there was a saying, "fresh today, stale tomorrow."

Now, the baker bakes for no benefit to himself, and I repeat, this if for no benefit to himself, adding a certain number of ingredients to the bread other than those that he needs for the loaf. The purpose of those ingredients are to give the consumer bread that may last 10 to 15 days free from mold. He never sees mold. The purpose is to give the consumer bread for the longest life so there is no economic waste.

Second, the dough conditioners, the bread softeners that are used again offer the baker no advantage. It would be cheaper and easier if he did not have to include these additives. His only reason for including them is to give the consumer a loaf of bread which is white, which has a finer texture, which chews a little better in the mouth, and which stays softer longer so a consumer, on a sale maybe, buys three loaves of bread and is able to keep that bread for a week or 10 days to feed her family with a product that remains soft and fresh. These are the reasons why these ingredients are used.

In 1940 the Food and Drug Administration allowed the flexibility. of using the best ingredients available to him. With the new order everything has to be spelled out. What will develop is, the baker will no longer have the flexibility to make the day-to-day, on the spot adjustments that are needed.

What they are overlooking is the fact that bread is a living product. The baker does not bake for inventory. I repeat that. The man who

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makes canned peas, he builds up an inventory. He works out in his laboratory and then makes these changes and goes through all of the proper requirements. The baker, however, gets in flour on a day-today basis. Many bakers in this room, and those that are represented by this group, every day get their shipment of flour. That flour changes. The baker has to be in a position, if he is to serve the best needs of the consumer, to make changes daily so that he can adjust himself to the requirements of the flour that is shipped to his bakery.

The label indicating the specific ingredients and their specific order of predominance will make it illegal for them to make any changes without also changing the label. Now, there is no practical way that he can change the label fast enough.

What does he do? Does he sacrifice the consumers' best interest? Does he take illegal steps? He is a law-abiding citizen. What does he do? This brings the baker a terrible confusion because he really truthfully, gentlemen, has no mechanism available to him to make the adjustments that in 1940 were recognized as necessary and which he has been allowed to make over these 37 years and which truly serve the best needs of the consumer.

Mr. Botry. Thank you, Dr. Jackel.

The specific problems that the new FDA order will create for the wholesale baker on an ingredient by ingredient basis that I have just detailed, were the subject of several long meetings in New York by experts in the bakery industry. These conclusions, incorporated in my opening remarks, were checked and approved by no less an authority on bread chemistry than Dr. Simon Jackel, vice president in charge of laboratory and technical research of the Quality Bakers of America Cooperative, Inc. who just spoke. Dr. Jackel is with our IBA group today to answer any technical questions that the subcommittee might wish to go into. Also, Dr. Jackel is here, as I said at the beginning, to help all of us with the pronunciation of some of the chemical names that will be appearing on the bread labels after January 1, 1978, and if this regulation stands they are going to be buying a bag of chemicals instead of a nutritional food that has sustained man for 5,000 years.

Mr. Chairman, at this time I would like to pass out for the subcommittee's benefit sample labels, to give you some idea of what the legend would look like if this goes through.

Also, I call your attention to the several charts that have been prepared to indicate the differences between the present labels and the new labels that will be required by FDA. It is abundantly clear that the housewife will be both confused and frightened with the new wording from the chemical dictionary.

Dr. Jackel will make the label presentation.

Dr. JACKEL. May I call your attention to what a label on a loaf of cracked wheat that you may have bought, or your wife may have bought, in the supermarket would look like today or a few months ago ? This is what that label will look like starting on the first of the year. It is obvious there are many, many additional pieces of information that have been added to this label.

My purpose is to call your attention to what type of information has been added and to raise the question whether these types of information are helpful to the consumers or perhaps confusing to the consumers. Has this area been explored from the consumers point of view

in sufficient detail ? At present, I do not know. There are too many consumers who would be confused or mislead by that entry.

Nevertheless, under the new regulations it will be necessary for that simple statement to look new: Enriched flour, containing, that is what parentheses mean, bleached flour, malted barley, ferrous sulfate, niacin, thiamine, hydrochloride, and riboflavin. We have taken two words and expanded it out into quite a few. What have we accomplished? Ferrous sulfate, that is iron, which is very important to the American nutrition. However, have we helped the consumer in stating that it is ferrous sulfate? Would it have been adequate to say just iron?

If the baker is tied into the fact that he has to put in ferrous sulfate—if he goes to another miller that uses reduced iron, he has violation on his hands. If he does not have that flexibility he might find himself out of flour. The consumer will ultimately suffer.

Niacin: Would the consumer know if instead of niacin, on the simple label—the label said for instance, hydrochloride. Do we need to educate the consumer to what that is or would it be adequate to just say vitamin B, ? There are many millers that use mononitrate form. The key is thiamine. The other part is just a production simplicity which makes it available for use. But, nowhere does this say vitamin B1. Surely the consumer would be better served if we used the word vitamin B.

Now, whole wheat flour: This is a cracked wheat loaf. The bag indicates that it has whole wheat flour in there, which again tells the consumer the ingredients. Under the new ingredients he will have to put in—he will also have to add to the cracked wheat the wheat kernel that is produced by going through the roller mill. In the past it was absorbed in the whole wheat category. Whether there is anything to be gained by that decision, I do not know.

Sugar: Here it is used to allow the breathing of the loaf to take place. Here he not only has to put that in but he has to spell out the different types of sugar. Here is the word brown sugar. Here is the word corn syrup. Here is the word honey. Every individual type of sugar that is present now must be present on the new label. Is the consumer's best interest served? I do not know. The word sugar in many regards seems to have adequately served the consumer.

Shortening: Here again the consumer knows what that means. I do not think anyone would be mislead by the word shortening. Yet, under the new_labeling requirements the origin of each and every one is required. In this particular case it says the baker is using soybean oil. I do not know whether the consumer benefits or not. The consumer may have been better off just knowing it was shortening.

The nonfat dry milk: That is clear-cut.

Yeast: The yeasts are processing aids to do the job of fermentation better. That is their only purpose. However, now these must be spelled out and they will appear as scary-sounding ingredients: ethoxylated mono- and diglycerides, potassium bromate. The actual components have to be spelled out. In the past they were just listed as yeast nutrients.

In my position with the OBA I receive a lot of mail. I have yet to get my first letter from any consumer asking me to explain to her what

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