Cargill, Incorporated - Comment

March 27, 2008
Division of Dockets
Management (HFA-305
U.S. Food and Drug Administration,
5630 Fishers Lane, Room 1061
Rockville, MD 20852
Docket No. 2005P-0450: Salt and Sodium; Petition to Revise the Regulatory
Status of Salt and Establish Food Labeling Requirements Regarding Salt and
Sodium
Cargill, Incorporated, a global provider of food ingredients including salt, salt
products and sodium reduction solutions, welcomes the opportunity to comment
on the U.S. Food and Drug Administration?s review of the Generally Recognized as
Safe (GRAS) status for salt.
First and foremost, we believe the FDA?s thorough and periodic reviews of the
safety of salt in processed foods over the past fifty years to be comprehensive,
conclusive, and aligned with the original legislative intent establishing the concept
of GRAS. We support the continued recognition of salt as GRAS and find a
process to designate salt as a food additive as unwarranted and unnecessary.
Salt?s presence in the human diet spans thousands of years and sodium is widely
accepted by the scientific and medical community as an essential nutrient in
keeping the human body functioning properly. Salt also serves a number of
important functional roles in food and is critical to shelf-life stability and the food
safety of processed foods.
The issue raised by the pending petition to revoke the GRAS status of salt is not
one of food safety and, therefore, revoking the safety status of this ingredient is
unjustified. The issue raised is one related to imposing dietary modeling on the
public, which seeks to ameliorate the over-consumption of nutrients and energy-
dense foods by segments of the American public. The focus on any one nutrient or
any one segment of the population ignores the understanding that the relationship
of diet to health is complex and requires a multi-faceted approach to the issues of
obesity or diet-related diseases in certain population groups.
Additionally, the proposal to establish sodium limits in foods ignores both the
technical challenges of sodium reduction and the inability to regulate at-home
consumer use of salt. While the use of the food additive regulatory process is not
an appropriate solution, there are positive steps that can be taken to promote
healthy lifestyles and to help consumers reach the daily sodium intake level of
2,300 mg recommended by the 2005 Dietary Guidelines for Americans.
The promotion of a well-balanced diet, based on sound dietary guidance and
recommendations, coupled with moderate daily exercise is fundamental to a
healthy lifestyle. The passage and implementation of the Nutrition Education and
Labeling Act (NLEA) provided an essential tool for consumers by requiring the
labeling of key nutrient information on food and beverage packages as a means to
help consumers make informed food choices. Unfortunately, consumer research
shows that Americans still struggle to understand basic nutrition concepts
expressed in the nutrition facts box. Consumer education and a better
understanding of how to communicate important nutrition information to
consumers is an area ripe for public-private partnership and engagement.
Advancements in taste sensory research and food technology will also support
sodium reduction in processed foods. As a leading food ingredient supplier,
Cargill is working with global leaders in the food and beverage industry on the
issue of sodium reduction. There is significant interest among our customers and
momentum in the food industry to reduce sodium in foods. However, there is no
magic bullet in sodium reduction nor is their one simple drop-in solution. Cargill?s
experience shows that sodium reduction technology innovation will take a
significant investment of resources and, ultimately, taste plays a critical role in
whether a consumer will accept a sodium reduction innovation. Research in
understanding taste receptors and advancements in food technology are also
areas ripe for public-private partnerships and constructively channels the interest of
the food industry and government in providing options for those populations who
may need to reduce sodium in their diets.
We appreciate the opportunity to comment on this important matter. We support
the FDA?s long-standing position that salt is GRAS and do not support its
regulation as a food additive.
Sincerely,
Jodie Horner
President, Cargill Salt


...Cargill, Incorporated, a global provider of food ingredients including salt, salt
products and sodium reduction solutions, welcomes the opportunity to comment
on the U.S. Food and Drug Administration?s review of the Generally Recognized as
Safe (GRAS) status for salt.