Subway to FDA: Don’t penalize firms that are ahead of the game on sodium reduction

If the government plans to set sodium reduction targets for food categories it should take into account progress already made by ‘proactive’ firms or risk unfairly penalizing companies that have taken the initiative, Subway has warned.

In comments filed in the docket for the joint USDA/FDA probe into sodium reduction strategies, Suzanne Greco, vice president, R&D, at the sandwich chain, “respectfully requests that the FDA and FSIS recognize restaurants and food companies that have already made progress in the area of sodium reduction”.

The sodium reduction probe - which is co-ordinated by the USDA’s Food Safety and Inspection Service (FSIS) and the Food and Drug Administration (FDA) - was set up last year to find “potential ways to promote gradual, achievable and sustainable reduction of sodium intake over time”.

The comment period has now closed, with the next steps still to be determined.

Reasonable, safe and impactful targets

If the FDA/FSIS decides that a "federal voluntary sodium reduction program" is the answer, said Greco, "We ask that FDA allows companies to submit historical sodium levels or levels prior to their efforts to reduce sodium.

“To reference current sodium values in companies that have already made substantial progress in reduction as a baseline for sodium targets will effectively penalize and burden proactive restaurants and food companies.”

She added: “The Subway brand would fully participate in a cooperative forum to review voluntary federal sodium targets to insure they are reasonable, safe and impactful.”

NSRI approach is working

Subway, which has made “significant reductions” in sodium in menus in the US, Canada, Europe, Australia and New Zealand,  agrees with the National Salt Reduction Initiative (NSRI) approach to set sodium targets based on distinct food and menu categories per 100 grams, said Greco.

This approach addresses the unique sodium challenges different food and menu categories and accounts for varying portion sizes.”

Breakfast sandwich NSRI sodium target not reachable

However, some targets are proving challenging, she said.

Most current sodium NSRI targets are reasonable. However, a few targets and menu categories need further input from the greater restaurant and food industry community.

“For example, the breakfast sandwich sodium target is not reachable unless the nature of the typical breakfast sandwich is drastically changed. The complete removal of breakfast meat or cheese would be necessary.

Adding a category to distinguish breakfast sandwiches that include breakfast meat and those that do not could be a more flexible approach.”

Voluntary or mandatory targets?

While most food industry commentators advocate a voluntary approach to sodium reduction, some health advocacy groups – notably the American Heart Association – argue that mandatory new low-sodium targets, a daily value for sodium based on an adequate intake of 1,500mg/day and a change in the GRAS status of salt are the only way to tackle excess sodium intakes.

However, other stakeholders have challenged the prevailing hypothesis that cutting sodium – ideally to 1,500mg/day – can reduce the risk of cardiovascular disease, and argue that the government must take emerging science into account when it decides how to proceed.

An FDA spokesman said: "FDA and FSIS are currently reviewing the comments submitted to the docket in response to the September 15, 2011 Federal Register notice which discussed the concept of sodium reduction targets and identified 16 issues for comment."

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