ASA to FDA Alternatives Implementation Timeframe Must Be Considered Rather Than Banning Partially Hydrogenated Oils

ST. LOUIS (March 7, 2014) - In a submission to the Food and Drug Administration today, the American Soybean Association (ASA) officially entered its comments on the FDA's proposal to further reduce trans fat consumption by rescinding the generally regarded as safe (GRAS) status for partially hydrogenated oils (PHOs), including partially hydrogenated soybean oil.

While urging FDA not to withdraw GRAS status for partially hydrogenated oils, ASA noted the almost 70 percent reduction and continued downward trend in consumption of trans fats over the last decade, and touted the work of the soybean industry to develop high oleic soybean varieties. These varieties can replace the functionality of partially hydrogenated soybean oil in certain applications like baking, frying, and other food processing without the addition of trans fats. Current projections from QUALISOY indicate that approximately 1.3 billion pounds of high oleic soybean oil will be extracted from the 2016 crop of high oleic soybeans and available for use by the food industry in 2017, with increasing quantities available in subsequent years.

"We are confident that high oleic soybean oil can replace a substantial portion of the between 2 and 2.5 billion pounds of partially hydrogenated oils that are still in the market," wrote ASA in its comments. "But that cannot happen without FDA's recognition of the importance of ensuring a sustainable domestically-produced food supply."

ASA further encouraged the agency to take into account the time needed to ramp-up domestic high oleic soybean oil production; and urged FDA to pursue alternative strategies that have already aided in the dramatic reductions in trans fat consumption over the last decade. These include education, revisions to the nutrition fact panel, and limits on the amount of trans fats that food products can contain to be labeled free of trans fats.

The association also registered serious concerns that FDA's proposal would have the unintended consequence of raising saturated fat consumption as a result of manufacturers opting to substitute higher saturated fat palm oil for PHOs as it waits for high oleic soybean production capacity to catch up with current demand. "This would replace our domestically-grown and sustainable soybean oil with palm oil," ASA wrote. "The saturated fat profile of palm oil is 6.7 grams of saturated fat per tablespoon, compared to just 2 grams for soybean oil. The result of this trade-off would be a 'lose-lose' for both the government and American consumers."

A further consequence of this substitution, according to ASA, is the loss of more than $1.6 billion in farmer income as a result of the immediate switch from soybean oil to higher saturated fat palm oil.

ASA also noted its concern that the FDA's proposal addresses the process of hydrogenation, rather than the end product of the oil itself. "We believe that the FDA's proposal is so sweeping in its application that it would stymie technological advances in oil processing that aren't even envisioned today," ASA commented. "As there is no definition of 'partially hydrogenated,' and as we know that the term encompasses a whole spectrum of oils, we are concerned that new technologies would be a casualty of the FDA's proposal."

Finally, as an alternative, ASA cited the successful approach taken by other nations including Denmark in setting a limit on daily consumption of trans fats in food. Through that approach, Denmark has reduced its per capita intake of trans fat to only 1 gram per day, a level at which trans fat is no longer a significant source of fat intake. "This approach seems a more common-sense way to approach the goal of further reducing trans fats consumption in the U.S. diet than the FDA's current proposal, which we see as likely to lead to increased saturated fat consumption, increased reliance on imported oils in the U.S. food supply, diminished ability for food manufacturers to adopt innovative technologies, and costly in terms of U.S. production and jobs."

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