Due Diligence with Database
by Karen C. Duester, MS, RD
July 1, 2008
Food labelers are frequently
faced with incomplete data from ingredient suppliers.
Despite this lack of data, labelers are obligated to report
accurate nutrient values in the Nutrition Facts for the
product. The same is true for nutrient values that will be
used for nutrition labeling in restaurant/ready-to-eat
Labelers can meet the goal of accuracy in labeling by due
diligence. Due diligence is a term used to refer to the process of performing all necessary steps to
arrive at an accurate conclusion; due diligence includes thorough
recordkeeping to document how the conclusion was derived.
For food labelers, due diligence is a thorough
performance of obligatory nutrition analysis tasks; the
performance utilizes a deep knowledge of food composition
and professional wisdom. This enables labelers to find or
reasonably deduce answers when facts aren’t readily
Due diligence begins by creating a database of nutrient
values for raw materials from which the Nutrition Facts will be derived:
Establish the list of ingredients used in the
products or menu
items to be analyzed.
Determine the nutrients to be tracked. Keep
these in mind while working through the steps.
Have at hand a research quality database with USDA
data. USDA data is based on multiple sample testing;
reported values are statistical averages, unrounded, and for
100-gram portions. Food Consulting Company uses Genesis R&D SQL by ESHA
Evaluate supplier specification sheets for usability
or need for further information.
Ideally the specifications will show:
(usually reported as "per 100 grams")
for all nutrients that will be tracked
moisture & ash
(protein, carbohydrate, fat, moisture, ash)
that add up to 100% of the reported weight
of the ingredient
make sense in context of 4-4-9 formula,
Atwater factors, or another FDA allowed
method for calorie calculation
(sat, trans, mono, poly) that make sense in
context of total fat
components (fiber, sugar) that make sense in
context of total carbohydrate
the source of
data matches for each ingredient.
ingredients and menu items, USDA data will
be the best source; examples are fresh
produce, foods with a standard of identity,
unprocessed raw meats, natural cheese,
butter, sour cream, etc.
spec sheet data for manufactured
items/ingredients that are in ready-to-use
form (such as sandwich spread, cheese sauce
blend, cinnamon roll icing). If necessary,
find a way to derive reasonable values for
missing spec sheet data. There is no single
way to get a value that is not reported.
Sometimes values can be mathematically deduced from trustworthy values already
available. In some cases, it may be
necessary to go
back to the supplier. In other cases it may be necessary
to supplement with laboratory analysis.
spec sheet data into the raw materials database as
a new food item.
Now the food labeler is ready to do the analysis:
Produce data per serving and per 100 grams of
product. One hundred gram (100g) data is standard
for nutrient analysis and allows for quick quality
assurance checks and nutrient comparison of foods.
If the data resources were good, the end nutrient values
will be accurate. However, some foods
will undergo further processing that will change the
Adjust for processing. For example:
methods (baking, frying, simmering, etc.)
alter the moisture content of food. Consider
a cake where the batter weight is 41 ounces
and the baked weight is 36 ounces. The
difference is the loss of five ounces of
moisture (water). The baked cake has more
nutrients per 100 grams than did the batter.
frying alters moisture and nutrient content
but not weight. This is because as fat is
absorbed, moisture is lost. Example: 100g
starting weight, plus 10g fat pick-up, minus
10g moisture loss = 100g end weight. The
absorbed fat contributes calories and fatty
acids that need to be reported.
and marinating, the food to be eaten does
not take up all of the breading and
marinating mixture per recipe. The part left
behind should not be included in the final
calculated nutrition data.
nutrient values for the batch formulation to the
serving size that will be reported.
final values to confirm that they make sense.
add up to 100% of the 100g and per serving
Do fat and
carbohydrate components make sense in
context of their total weights?
make sense based on 4-4-9 calculations (or
another FDA allowed method)?
Do the values
make sense based on knowledge of the food's
In all cases the
Nutrition Facts should reflect what
is present in the food package.
Due diligence through each step of the process
leads to accurate Nutrition Facts and provides
corresponding records that will stand up to public
This article is adapted from an article
published in DBC Dimensions based on an
interview with Karen C. Duester, MS, RD, president of
Food Consulting Company. Food Consulting Company
is the largest outsource
provider assisting food companies in meeting FDA
labeling requirements. The company offers a full
range of food labeling services and can be
www.foodlabels.com or by calling
Consulting Company, 2008
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