The 1991 proposal also addressed issues related to the mandatory status of nutrition labeling and nutrient content revision, with some modifications of the 1990 proposed regulation (FDA, 1991). Also in 1991 USDA’s Food Safety and Inspection Service (FSIS) announced its commitment to improving harmonization with FDA on nutrition labeling (FSIS, 1991).

FDA again proposed to replace the 1973 US RDAs with RDIs and to establish DRVs. The proposal included reference values for five life stage and gender groups that were to be used for nutrition labeling based on the increasingly complex RDAs (FDA, 1990a, 1991). The five groups were: infants (0–12 months), children less than 4 years of age (13–47 months), children and adults 4 or more years of age (excluding pregnant women and lactating women), pregnant women, and lactating women. FDA proposed that the reference values for these groups be used in nutrition labeling for food targeted to these groups. Because children 4 or more years of age and adults were thought to generally eat the same food, FDA grouped them together to establish one set of reference values to define the general population (FDA, 1990b). This approach thereby simplified nutrition labeling since it resulted in the listing of one column of nutrients on most food.

The proposal called for RDIs for protein and 26 vitamins and minerals for all five age groups. FDA also outlined the establishment of eight new DRVs for food components of increasing concern for Americans but for which there were no established RDAs: total fat, saturated fat, cholesterol, total carbohydrate, dietary fiber, sodium, potassium, and protein (FDA, 1990b).

The DRVs were based on discussions, recommendations, and guidelines presented in Diet and Health (NRC, 1989a) and The Surgeon General’s Report on Nutrition and Health (DHHS, 1988). The proposal also indicated that the tenth edition of the Recommended Dietary Allowances (NRC, 1989b) provided a basis for reexamining current nutrient standards. Additionally, FDA’s proposal cited a range of reports (Butrum et al., 1988; DHHS, 1988, 1989; Expert Panel on Population Strategies for Blood Cholesterol Reduction, 1990; LSRO, 1987; NRC, 1989a; USDA/DHHS, 1985) that provided a basis for expanding the required information on nutrition labeling to include information on nutrients and food components that were associated with risk of chronic disease (FDA, 1990b).

FDA also proposed to calculate RDIs by using a population-adjusted mean of the relevant RDAs rather than the highest-of-the-high, population-coverage approach that was used to establish the US RDAs (FDA, 1990b, 1991). FDA proposed this new approach for



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