From: Fred and Dani [danfred@prodigy.net]
Sent: Tuesday, March 27, 2001 4:30 PM
To: fdadockets@oc.fda.gov
Subject: Docket No. 00P-0586 CP2

Fred LaClair

18860 Woodard Road 

Watertown, NY 13601 

March 27 2001

Jennie Butler

Docket Management Branch (HFA-305)

Food and Drug Administration

Room 1061

5630 Fishers Lane

Rockville, MD 20852

Dear Ms. Butler,

I am sending this letter because of my deep concern about the changes in the way the food of this Nation is being processed and offered to consumers. My family has an inherited fondness for cheese and cheese products. 

We do our grocery shopping at a P&C Food Market. While shopping recently, we happened to pick up one each of "Kraft Foods" and "Food Club" cheese singles. To our amassment, we noticed there was a distinctive difference in texture and in flavor and yet the "Kraft Food Brand was the most expensive. Salt dominated the flavor and there was a scant flavor of cheese in the "Kraft Foods" singles. The "Kraft Food" singles were less flexible and they took longer to melt for our grilled cheese sandwiches. 

I compared the ingredients of the "Kraft Foods" and the "Food Club" singles and discovered that the "Kraft Foods" singles contained added ingredients. The "Kraft Foods" singles had "milk protein concentrate" and "water" in addition to "Food Club Brand ingredients. The "Food Club Brand has a logo that contains the word Real but is was missing on the "Kraft Food Brand.

The next time we shopped we purchased a package of "Kraft" Velveeta cheese food product due to curiosity. She fixed grill cheese sandwiches for lunch using Velveeta and after eating a half a sandwich, she threw the rest away. In an attempt to define the flavor, I suffered through mine. She gave the remainder of the package to the cats but they would not have anything to do with it. I am advising people to purchase products that display real on the package and return the substitutes to the market of purchase.

I decided to investigate Milk Protein Concentrates and what I discovered was very shocking. Milk Protein Concentrate is milk that is Ultra-filtered by pumping and circulating, under pressure, through special filters until the determined concentration is achieved. Mush of the lactose is lost, pH rises, bacteria counts rise and other negative characteristics arise. The sludge can then be dried. The product becomes Milk Protein Concentrate (MPC). MPC can not be re-hydrated back into milk. MPC lacks standard of identity and is frequently blended with Casein (a more pure form of milk protein). All dry MPC and Casein is currently imported.

I learned that The Food and Drug Administration (FDA) does not recognize MPCs as having a standard of identity as a food ingredient. They are not "Generally Recognized as Safe" by the FDA. FDA states that imports are subject to the same sanitary standards as US produced food and food ingredients. However, the FDA at port of entry does not inspect MPCs. There are no restrictions on the amount imported.

The use of MPC produces a cheese product that does not age well and melting qualities are reduced. The only reason for using Ultra-filtered milk is to make a cheaper product. Nearly half of the MPC and casein is imported from the European Union. There is a possible risk of transmission of BSE (mad cow disease) and foot and mouth decease. Also, because these products are in the form of dry powder, there is a risk of food terrorism. The sacks that are used for shipment could be a carrier. Less than 1% of all imports are inspected. MPC in not currently a legal food additive, yet there has been no enforcement against its use by either the United States Department of Agriculture (USDA) or the FDA.

In the year 2000, imports of MPC and Casein/MPC blends displaced between 4.5 and 7.3 billion pounds of domestic milk (protein or skim solids basis). This is in addition to pure Casein, which has food, and non-food uses. 

I have been informed that on June 9, 2000, the National Cheese Institute petitioned the FDA (FDA Docket No. 00P-0586 CP2) to change the definition of milk in order to allow the use of both wet and dry ultra-filtered milk (MPC). I was also informed that FDA is expected to issue a ruling in April of 2001. If FDA rules in favor of this petition, it will have a devastating effect on the economy of this Country, US dairy farmers and will further erode food quality and safety. 

I urge you to deny the request of the National Cheese Institute (FDA Docket No. 00P-0586 CP2). The well-known Companies are using their name to deceive and cheat the consumers. The consistency of the substitutes does not conform to that of real cheese. They do not inform the consumers as to the nature of Milk Protein Concentrates or that it is an imported product. If they elect to produce a substitute, they should label it as such. 

Please, do not let the National Cheese producers deprive the cheese lover the privilege of enjoying real cheese. To grant their request is wrong and immoral. 

Sincerely, 


Fred LaClair