From: Dale Schmidt [dschmidt@stoelting.com]
Sent: Thursday, March 15, 2001 11:44 AM
To: fdadockets@oc.fda.gov
Subject: Docket Number OOP-0586CP2

Ms Jennie C. Butler,

I question the advisability of changing the list of approved dairy ingredients to include dry filtered milk products such as MPC.  While there may be room for allowing liquid UF milk as an ingredient, allowing the dried ingredient opens the doors to imported products that are not controlled by quotas or tariffs.

There seems little question that there is already a large amount of imported MPCs being used in cheese and processed cheese products already.  The use of these ingredients does not appear to be allowed under the present standards of identity, and I do not feel it is wise to drop the barriers to their use at this time for three reasons.

1.  Product quality.  I am a licensed cheesemaker from Wisconsin, and was actively involved in the manufacture of cheddar, mozzarella, and blue cheese over a period of 17 years.  As a cheesemaker, and as a consumer I have seen a steady deterioration of the dairy products appearing on our shelves.  As the major marketers of dairy foods,  two major players being Kraft and Leprino through the Pizza industry, have steadily reduced there costs of manufacture by reducing aging requirements, and lower priced ingredients (WPC & MPC), there has been a directly related decrease in product quality.  I would note that Kraft no longer even offers American Process Cheese in the blue box, that my mother used for making macaroni and cheese, toasted cheese sandwiches, and an array of hot dishes that included cheese as an ingredient.  Today the homemaker is left with Velveeta, and any resemblance to cheese is purely accidental.
 
If you have ever had a Pizza made with real mozzarella cheese, (preferably with some smoked provolone, and a little asiago for flavor, you would refuse to eat Pizza Hut pizza (or any other of the fast food chain or frozen pizzas), as the "cheese-like" substance they use looks and stretches like mozzarella, but definitely lacks the true cheese flavor.  
 
At present, most of the damage is in the processed cheese and cheese ingredient business.  If we open the flood gates by changing the rules, it will soon be hard to find "real cheese" even in the Natural retail cuts.  The big boys like Kraft will lead the way, and everyone else will have to follow in order to "stay competitive".  This type of erosion of the quality of the food we eat should not be allowed to be hidden.  Note that casein derived "cheeses" were also inferior in quality, and when forced to label them "imitation cheese", the consumer did not look at the price, they bought the "Real Seal", and imitation cheeses have never prospered.  It is only where the adulteration is hidden in the ingredients label, like on Kraft's Singles,  Note that they are not called Processed Cheese!, that the consumer buys them, blithely unaware that they did not buy cheese.
 
2.  Food Safety:  Foot & Mouth Disease and Mad Cow Disease are real problems in Europe and the rest of the world.  Have we fully established that these are not problems that can be transmitted through the milk, and into the MPC that is being imported?  Until we really know that there is not a concern, we should err on the side of caution.
 
3.  Economics.  I grew up on a small dairy farm, that way of life is dead, and at the present rate of attrition, even the mid sized family farm will soon be a thing of the past.  By opening our domestic dairy products market to foreign dairy products slipped in as MPC, we will quickly force our milk producers down to the world market price.  This has been  occurring on a huge scale in the last two years, as evidenced by the massive increase in MPC imports, the severe drop in Class III milk prices, at the same time that domestic dairy consumption remains high!
 
We are giving away our domestic market for milk, and due to MPC being used as a dairy ingredient while being imported as a non-dairy product, we have not even bargained it away for "something in return" as is typical.  This time we are giving it to them as a freebie!!

And any attempt to say this is "good for the consumer" has not watched retail dairy prices, which have not moved down in correlation to the drop in what is supposed to be the major ingredient, i.e. milk.  The retailers have simply pocketed the increased revenue as a windfall profit.

The opinion expressed is a personal one, and does not represent that of the company I am employed by.

Sincerely,

Dale Schmidt