Matt,

The American College of Preventive Medicine (ACPM) is pleased to support Resolution 2 (I-01), Nutrition Labeling for Trans Fatty Acid Content, submitted to the AMA Medical Student Section by Patrick Birmingham, Jason Cohen, Tamara Gersh, and Vas Naidu. The resolution makes a strong case for disclosing trans fatty acid content on nutrition labels and defining the claim "trans fat free," and the need for FDA to modify its regulations accordingly. This is an important prevention issue with important population implications.

ACPM is the national medical specialty society for physicians whose primary interests lie in preventing disease and promoting health. ACPM represents over 2,000 preventive medicine physicians, most of whom are board-certified in preventive medicine, another specialty area, or both. Preventive medicine physicians are uniquely qualified in both public health and clinical preventive medicine, and typically provide leadership in communities or health settings that bridge the gap between these two disciplines.

We appreciate the opportunity to review and weigh in on this resolution. Feel free to contact me if there's anything else we can do.

Mike

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Michael A. Barry
Deputy Director
American College of Preventive Medicine
1307 New York Ave., NW, Suite 200
Washington, DC 20005
p: 202-466-2044 (x106)
f: 202-466-2662
e: mab@acpm.org

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AMERICAN MEDICAL ASSOCIATION MEDICAL STUDENT SECTION

Resolution: 2

(I-01)

Introduced by: Patrick Birmingham, Loyola University; Jason Cohen, University of Chicago;Tamara Gersh, Northwestern University; Vas Naidu, University of Illinois

Subject: Nutrition Labeling for Trans Fatty Acid Content

Referred to: MSS Reference Committee (Colin Devonshire, Chair)

Whereas, The dietary intake of trans fatty acid (a major constituent in commercial vegetable shortenings and margarines as well as other foods) has been shown to increase LDL cholesterol 1,2 and to be associated with Coronary Heart Disease1,3,4, which is a major cause of mortality in the United States1; and

Whereas, Foods containing trans fatty acids have increased in popularity, and trans fatty acids now account for 2 to 3 percent of total calories in the average American diet5; and

Whereas, The American Heart Association has stated that "the optimal diet for reducing risk of chronic diseases is one in which saturated fatty acids are reduced and trans fatty acids from manufactured fats are virtually eliminated." 6; and

Whereas, The Resident Physician's section introduced a resolution (resolution 509) at the 1997 Annual Meeting proposing that the AMA support an FDA change of policy to require that levels of trans fatty acids be included on nutrition food labels and to support the development of guidelines for fat content claims on foods containing trans fatty acids; and

Whereas, Resolution 509 (A-97) was referred to the Board of Trustees by the House of Delegates and reviewed by the Council on Scientific Affairs whose recommendations were as follows: "the Council on Scientific Affairs recommends that Resolution 509 (A-97) not be adopted, but the council will monitor the FDA's November 9, 1998 proposal to amend its regulations to provide for the declaration of trans fatty acids in nutrition labeling and report as necessary;" and

Whereas, These recommendations were adopted as AMA Policy at the 1998 Interim Meeting; and

Whereas, On November 17, 1999 The FDA proposed to amend its regulations on nutrition labeling to require that the amount of trans fatty acids present in food be included in the amount and percent daily value declared for saturated fats, and to define the claim "trans fat free1; and

Whereas, These new recommendations were not available for consideration at the time that Resolution 509 (A-97) was not adopted; and

Whereas, The FDA has estimated that "three years after the effective date (of labeling change), the proposed change would annually prevent from 6,300 to 12,800 cases of CHD and 2,100 to 4,200 deaths"7; and

Whereas, In its 2000 dietary guidelines, the American Heart Association stated that including trans fatty acid content on food labels and increasing the number of the trans fatty acid free foods could help people limit their intake of "cholesterol-raising fatty acids" to more acceptable levels8; and

Whereas, As of 2001, the FDA’s proposed requirements for the labeling of trans fatty acid content in foods have still not yet received approval for enactment; therefore be it

RESOLVED, That the AMA support the timely approval of the FDA's proposed amendment of its regulations on nutrition labeling to require that the amount of trans fatty acids present in a food be included in the amount and percent daily value, and that definitions for "trans fat free" and "reduced trans fat" be set.

Fiscal note: No significant fiscal impact

References:

1. Department of Health and Human Services, FDA. Food Labeling: Trans Fatty Acids in Nutrition Labeling, Nutrient Content Claims, and Health Claims; Proposed Rule. Federal Register: November 17, 1999 (Volume 64, Number 221). 21 CFR Part 101 [Docket No. 94P-0036]. http://www.cfsan.fda.gov/~lrd/hhtfacid.html

2. Kwiterovich PO. The effect of dietary fat, antioxidants, and pro-oxidants on blood lipids, lipoproteins, and atherosclerosis. J Amer Dietetic Assoc. 97(7 suppl):S31-41, 1997 Jul

3. Temple NJ. Dietary fats and coronary heart disease. Biomedicine & Pharmacotherapy. 50(6-7):261-8, 1996

4. Addis PB, Carr TP, Hassel CA, Huang ZZ, Warner GJ. Atherogenic and Anti-atherogenic factors in human diet. Biomedical Society Symposia. 61:259-71, 1995.

5. Masley SC. Dietary therapy for preventing and treating coronary artery disease. American Family Physician. 57(6):1299-1309, 1998. http://www.aafp.org/afp/980315ap/masley.html

6. Summary of the Scientific Conference on Dietary Fatty Acids and Cardiovascular Health Conference: Summary From the Nutrition Committee of the American Heart Association Circulation. 103: 1034, 2001. http://circ.ahajournals.org/cgi/content/full/103/7/1034

7. U.S. Food and Drug Administration, Center for Food and Safety and Applied Nutrition, Officeof Food labeling. Questions and Answers on Trans Fat Proposed Rule. November 1999. http://vm.cfsan.fda.gov/~dms/qatrans.html

8. AHA Dietary Guidelines. Revision 2000: A Statement for Healthcare Professionals From the Nutrition Committee of the American Heart Association. Circulation. 102: 2284, 2000. http://circ.ahajournals.org/cgi/content/full/102/18/2284