October 17, 2016
Division of Dockets Management (HFA-305)
Food and Drug Administration
5630 Fishers Lane, Rm. 1061
Rockville, MD 20852
Comments of members of the Patient, Consumer, and Public Health Coalition on Voluntary Sodium Reduction Goals: Target Mean and Upper Bound Concentrations or Sodium in Commercially Processed, Packaged, and Prepared Foods
[Docket No. FDA-2014-D-0055]
As members of the Patient, Consumer, and Public Health Coalition, we strongly support the Food and Drug Administration’s voluntary sodium reduction goals. We agree that high sodium consumption “is a contributory factor in the development of hypertension, which is a leading cause of heart disease and stroke.”
We support FDA’s approach to lowering sodium content by avoiding “large, abrupt changes to individual products that might result in noticeably altered taste, greatly reduced shelf life, or other undesirable product outcomes.”
We also support FDA’s “plan to monitor the levels of other nutrients (e.g., added sugars and saturated fat) … to ensure that no broad trends emerge that negatively affect the nutritional quality of the foods.”  This has happened in the past when processed food manufacturers lowered the fat content of products such as cereals, yogurts, and snacks but then spiked the sugar levels to improve taste.
The overall goal of this guidance is to reduce sodium intake in the general population to 2,300 mg/day from the current average adult level of 3,400 mg/day. More than three-quarters of sodium that Americans consume is added when the food is manufactured or commercially prepared. By encouraging manufactures, retailers and food service to reduce sodium, consumers have more access to healthier choices.
Research provides important information that should be used to help determine how best to reduce salt intake. A recent study by the U.S. Department of Agriculture found wide variation in the amount of sodium in similar types of products, which suggests that current food manufacturing practices and food preferences vary enough that sodium levels could be reduced in some types of foods relatively easily, and without reducing consumers’ enthusiasm for those products. Others have examined the amount of sodium in the same or similar items from the same fast food restaurants in different countries or in the US over time. Again there were wide variations in the amount of sodium, suggesting that gradual changes in salt levels would not have a negative impact on consumer preferences. 
We support the FDA’s approach of using mg/ 100g as a standard way to monitor changes in the sodium in various foods independent of changes in serving size or other nutrient levels. However, it would be helpful for consumers and health professionals to also see what these changes mean in units that are found in the marketplace. This would increase transparency and allow outside monitoring.
We also want to encourage caution with the development of new or expanded use of food additives and other substances for food preservation or salty flavor. Any such chemicals or substances should be sufficiently studied to ensure that they do not have a negative impact on health in the short-term or long-term.
By making healthier options more available, consumers are able to choose foods based on what is important to them. We believe that many consumers will choose healthier options when they become available and as lower sodium levels become the norm. Current initiatives by individual companies, New York City, and the United Kingdom have shown that large reductions in sodium content are attainable and attractive to consumers.
We reject the claim that some target levels for sodium might be low enough to be unhealthy. “More than 75 percent of the sodium in the average American Diet comes from salt added to processed foods,” according to the American Heart Association. Consumers can continue to add salt to their food, if they choose to do so, since able salt is plentiful and inexpensive in the United States. Currently, it is difficult for individuals to lower the sodium in their diet because the salt is added before the consumer purchases it. Reducing the sodium in processed and restaurant foods gives individuals greater control over the amount of sodium that they consume.
In summary, we strongly support the FDA’s effort to reduce sodium levels in foods, while monitoring foods to ensure that sodium reductions are not offset by unhealthy changes in nutrients such as increased saturated fat or sugar. The FDA must also ensure that methods to compensate for the reduction do not include substances that could harm consumers. Reducing sodium levels in processed and prepared food would provide consumers with more control over the amount of sodium they consume and thus make it easier for individuals to choose a lower sodium diet and lower the risk for hypertension, heart disease, and stroke.
American Medical Student Association
American Medical Women’s Association
Jacobs Institute of Women’s Health
MRSA Survivors Network
National Center for Health Research
National Physicians Alliance
Washington Advocates for Patient Safety
WomenHeart: The National Coalition for Women with Heart Disease
 FDA DG (June 2016).
 Food and Drug Administration (June 2016). Draft guidance, Voluntary Sodium Reduction Goals: Target Mean and Upper Bound Concentrations or Sodium in Commercially Processed, Packaged, and Prepared Foods [Docket NO. FDA-2014-D-0055].
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 Nguyen PK et al (2016) A systematic comparison of sugar content in low-fat vs regular versions of food. Nutrition & Diabetes 6:e193.
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 Ahuja, JKC et al (2015) Sodium content of popular commercially processed and restaurant foods in the United States. Preventive Medicine Reports 2:962-967.
 Dunford E et al (2012) The variability of reported salt levels in fast foods across six countries: opportunities for salt reduction. CMAJ 184(9):1023-1028.
 Rudelt A et al (2012) Fourteen-year trends in sodium content of menu offerings at eight leading fast food restaurants in the USA. Public Health Nutrition 17(8):1682-1688.
 American Heart Association (December 8, 2015). Processed Foods: Where is all that salt coming from?