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without evidence or examples because, in general, none were provided to the Committee.

As part of its information-gathering activities, the Committee asked State and local officials and consumer groups to comment on the six questions that appear in Appendix C. One of those questions concerned whether there were any other issues that respondents believed should be brought to the Committee's attention as it deliberated on the adequacy of implementation of FDCA and preemption of State requirements. In response to this question, the following points were raised as being of major concern to respondents, although they recognized that these issues were beyond the specific charge of the Committee:

  • The adequacy of the fiscal and personnel resources applied by FDA in enforcing its food labeling requirements as a dimension of implementation.

  • The importance of the enforcement activities of the States to ensure consumer protection in the area of food labeling.

  • The value of existing cooperative relationships between FDA and the States, which have been developed and strengthened over many years.

  • The concerns of States about FDA's implementation of the petition process of NLEA for exemption of a State requirement from preemption and State enforcement of Federal requirements, so that these processes will be uncomplicated and well managed.

The importance of these issues was reiterated through a variety of communications from professional food and drug regulatory groups, food companies, trade associations, and national consumer organizations. An additional issue of particular concern to the food industry was the economic cost of nonuniformity and the potential savings to be realized through increased national uniform food labeling.


Many State officials and a number of consumer groups commented on the importance of enforcement and the future role of the States under NLEA. Commissioner Bob Crawford of the Florida Department of Agriculture and Consumer Services identified a number of problems in his letter to the Committee:

The states are the foot soldiers in the area of food labeling review and enforcement and must be included as equal partners in implementation and enforcement. The states are the crucibles from which good national legislation in consumer issues

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