Food THE DUE DILIGEnCE CHaLLEnGE a Guide to accurate Database nutrition analysis Karen C. Duester, ms, RD, president Food Originally presented to National Restaurant Association Revised November 2012
DUE DILIGENCE WITH DATABASE NUTRITION ANALYSIS Due diligence is a term that describes the process of performing obligatory nutrition analysis tasks. The performance utilizes deep knowledge of food composition and professional wisdom that leads to accurate and fully-compliant nutrition information for packaged foods and restaurant menu items on a per serving basis. The process enables food labelers to find or reasonably deduce answers when facts aren t readily available. Nutrition Analysis: 8-Step Process Step 1: Gather Your Data Sources... 2 Step 2: Set-up Your Raw Materials Database... 3 Step 3: Enter the Recipe Ingredients and Amounts... 4 Step 4: Make Adjustments for Processing.... 5 Food Step 5: Set the Serving Size... 6 Step 6: Perform the Due Diligence Checks... 7 Step 7: Apply the Rounding Rules... 8 Step 8: Triple-check Your Work.... 9 Nutrient Content Claims.... 10-11 Additional Resources... 12 About Food.... 12 2007-2012, Food. All rights reserved. www.foodlabels.com 1
Step 1: Gather Your Data Sources Establish the list of ingredients used in the recipes you will be analyzing. Determine the nutrients you will be tracking. Have at hand a research-quality database. Food uses Genesis R&D from ESHA Research. Evaluate all supplier specification sheets for usability or need for further information. Ideally, you want information that includes: Unrounded nutrient data Complete data for all nutrients you are tracking Data for moisture and ash Proximates (protein, carbohydrate, fat, moisture, ash) that add up to 100% of the reported weight (typically 100 grams) Calories that make sense in the context of 4-4-9 formula, Atwater factors, or another FDA-allowed method for calorie calculation Fat components (saturated, monounsaturated, polyunsaturated, trans) that make sense in the context of total fat Carbohydrate components (dietary fiber, sugars, sugar alcohol, other carbohydrates) that make sense in the context of total carbohydrate The source of the data Data that passes your own common sense test for the item being described 2 2007-2012, Food. All rights reserved. www.foodlabels.com
Step 2: Set-up Your Raw Materials Database Refer to the list of ingredients in your recipe. Determine which ingredients will need to be entered into the database as new food items and which ingredients will be matched with existing food items in the database. For example, a proprietary sauce manufactured for you will be a new food item, while a tomato slice will be matched with existing USDA data which is already in the database. You may need to interpolate to account for missing values in some instances. Keep in mind: You cannot derive a total trans fat value if you don t have trans fat values for all ingredients. You cannot correctly account for moisture adjustment when you don t have moisture data for all ingredients in your recipe. Proximates will not total 100% when you don t have complete data for moisture and ash. Food If a value is not reported on a supplier specification sheet, there are several ways to determine the value. Sometimes values can be deduced mathematically from trustworthy sources. In other cases, it may be necessary to go back to the supplier to get the information. Or it may be necessary to supplement supplier data with laboratory analysis. 2007-2012, Food. All rights reserved. www.foodlabels.com 3
Step 3: Enter the Recipe Ingredients and Amounts If your data sources are accurate and complete, you will be able to derive accurate nutrient values for your recipe (before processing) by entering the ingredients and amounts into your nutrition analysis software. If you have sub-recipes or pre-prepped ingredients, consider the following: Each sub-recipe needs to be entered individually before you can enter it into the recipe you are analyzing. For example, if you make your own pizza sauce and crust, the sub-recipes for each need to be entered to produce the data for pizza. For items that are marinated, dipped, battered or breaded, the parts left behind in the bowls should not be included in the final calculated nutrition data. 4 2007-2012, Food. All rights reserved. www.foodlabels.com
Step 4: Make Adjustments for Processing Until this step you have accounted for the nutrient values prior to processing. Processing can affect the nutrient content in important ways. For example: If you are simmering a sauce, soup or other item, you will need to enter a moisture adjustment to account for the water evaporation. If you are baking an item such as a cake, cookies or muffins, you will need to enter a moisture adjustment to account for the water evaporation. If you are deep-fat or pan-frying an item, the specific frying oil needs to be treated as a separate ingredient and entered in your list of recipe ingredients according to the amount absorbed. However, the fried item will lose moisture as it absorbs fat. This moisture loss needs to be entered at this step. Some vitamins are not retained during cooking and storage. The vitamin losses should be accounted for during this step. Food Your production data will inform you how to account for many of these processing changes. In some cases, you may need laboratory analysis to provide additional guidance for processing adjustments. 2007-2012, Food. All rights reserved. www.foodlabels.com 5
Step 5: Set the Serving Size To determine the Serving Size for the finished Nutrition Facts Panel you need knowledge about how the product will be packaged and consumed. In addition, you will need to understand the regulations related to Serving Size and Reference Amounts Customarily Consumed. Some of the broad food categories and guidelines for Serving Size are: Products with multiple servings that are measured by volume (tsp, Tbsp, cup) for the serving are labeled by the appropriate volume. Examples include soups, sauces, condiments, spices, cereals, and most prepared salads and desserts. Single-serve items are labeled as one package, such as an energy bar, a small bag of potato chips, or a can of soda. Products with multiple pieces in a package are divided into servings based on the number of pieces in a serving. Examples include a bag of cookies, a loaf of sliced bread, a box of mini-tacos, and a bag of candy pieces. Products sold as a whole but divided into factional pieces are labeled as the fractional piece, such as a frozen pizza, a cake, or a pie. Consult the U.S. Code of Federal Regulations at 21 CFR 101.9 and 101.12 for detailed information about Serving Size and Reference Amounts Customarily Consumed for FDA-regulated foods. 6 2007-2012, Food. All rights reserved. www.foodlabels.com
Step 6: Perform the Due Diligence Checks Now that you have the nutrient profile for your finished product on a per serving basis, you need to perform the due diligence checks to ensure correct calculations. To ensure your nutrient profile is accurate, you ll need to answer yes to the following questions: Does your spreadsheet report contain a value in every cell? Does the total for proximates equal 100%? Do the calories make sense in the context of 4-4-9 formula, Atwater factors, or another FDA-allowed method for calorie calculation? Do the fat components (saturated, monounsaturated, polyunsaturated, trans) make sense in the context of total fat? Do the carbohydrate components (dietary fiber, sugars, sugar alcohol, other carbohydrates) make sense in the context of total carbohydrate? Food The check data feature in the Genesis R&D software can help you validate your nutrition analysis results. 2007-2012, Food. All rights reserved. www.foodlabels.com 7
Step 7: Apply the Rounding Rules The nutrition values you publish should be customer-friendly. This means you should report rounded nutrient values per portion served. FDA has established specific rounding rules for each nutrient. Nutrient Rounding Increments May Round to Zero Calories nearest 5 calories up to 50 calories; if less than 5 calories nearest 10 calories if more than 50 Calories From Fat nearest 5 calories up to 50 calories; if less than 5 calories nearest 10 calories if more than 50 Total Fat nearest 0.5 gram up to 5 grams; if less than 0.5 gram nearest 1 gram if more than 5 grams Saturated Fat nearest 0.5 gram up to 5 grams; if less than 0.5 gram nearest 1 gram if more than 5 grams Trans Fat nearest 0.5 gram up to 5 grams; if less than 0.5 gram nearest 1 gram if more than 5 grams Cholesterol nearest 5 milligram increment; if if less than 2 between 2 and 5 milligrams, may milligrams report as less than 5 milligrams Sodium nearest 5 milligrams up to 140 if less than 5 milligrams; nearest 10 milligrams milligrams if more than 140 milligrams Carbohydrate nearest 1 gram; if less than 1 gram, if less than 0.5 gram may report as less than 1 gram Dietary Fiber nearest 1 gram; if less than 1 gram, if less than 0.5 gram may report as less than 1 gram Sugars nearest 1 gram; if less than 1 gram, if less than 0.5 gram may report as less than 1 gram Protein nearest 1 gram; if less than 1 gram, if less than 0.5 gram report as less than 1 gram Vitamins/Minerals nearest 2% increment up to and if less than 2% DV including the 10% level; nearest 5% above 10% up to and including the 50% level; nearest 10% above the 50% level Reference: 21 CFR 101.9 8 2007-2012, Food. All rights reserved. www.foodlabels.com
Step 8: Triple-check Your Work Once your nutrition analysis results are in final form (Nutrition Facts Panel for a packaged product or a Nutrition Information Guide for a restaurant menu), make sure your values pass the common sense test. Use your knowledge of food composition to review all nutrient values again. For example, it makes sense that you would expect to see higher calories, fat, etc., for a chili cheeseburger than a plain hamburger assuming the burger and bun sizes are the same. Food 2007-2012, Food. All rights reserved. www.foodlabels.com 9
Nutrient Content Claims Use this quick guide to compare your nutrient profiles against common nutrient content claims for FDA-regulated foods. Be mindful of the many nuances for claims contained in the U.S. Code of Federal Regulations. Nutrient Claim Low Calorie Fat Free Low Fat Definition 40 calories or less per serving Main dish/meal: 120 calories or less per 100 grams Less than 0.5 gram fat per serving, and includes no ingredients that contain fat 3 grams or less fat per serving Main dish/meal: 3 grams or less fat per 100 grams, and not more than 30% of calories from fat Saturated Fat Free Less than 0.5 gram saturated fat and less than 0.5 gram trans fat per serving, and includes no ingredients that contain saturated fat Low Saturated Fat 1 gram or less saturated fat per serving, and not more than 15% of calories from saturated fat Main dish/meal: 1 gram or less saturated fat per 100 grams, and less than 10% of calories from saturated fat Cholesterol Free Less than 2 milligrams cholesterol and 2 grams or less saturated fat per serving, and includes no ingredients that contain cholesterol Low Cholesterol 20 milligrams or less cholesterol, and 2 grams or less saturated fat per serving Main dish/meal: 20 milligrams or less cholesterol and 2 grams or less saturated fat per 100 grams Salt Free or Less than 5 milligrams sodium per serving, and does not contain Sodium Free sodium chloride (table salt) or other sodium-containing ingredients Very Low Sodium 35 milligrams or less sodium per serving Main dish/meal: 35 milligrams or less sodium per 100 grams Low Sodium 140 milligrams or less sodium per serving Main dish/meal: 140 milligrams or less sodium per 100 grams (continued on next page) 10 2007-2012, Food. All rights reserved. www.foodlabels.com
Lean Extra Lean Good Source Contains Provides Excellent Source High in Rich in Reduced Lower Light or Lite Meat, poultry, seafood and game meat with less than 10 grams fat, 4.5 grams or less saturated fat, and less than 95 milligrams cholesterol per serving and per 100 grams Meat, poultry, seafood and game meat with less than 5 grams fat, less than 2 grams saturated fat, and less than 95 milligrams cholesterol per serving and per 100 grams 10-19% Daily Value per serving. Example: A good source of iron contains between 1.8 and 3.4 milligrams iron per serving. 20% or more Daily Value per serving. Example: An excellent source of fiber contains 5 grams or more fiber per serving. A nutritionally-altered food that contains at least 25% less of a nutrient than a reference food A nutritionally-altered food that contains at least 1/3 fewer calories or 50% less fat than the higher-calorie, higher-fat version Healthy A food that is low in fat and saturated fat, contains 480 milligrams or less sodium per serving, and provides at least 10% Daily Value for one of these nutrients: Vitamin A, Vitamin C, calcium, iron, protein and fiber Notes: Per serving is a reference amount of more than 30 grams or more than 2 tablespoons. Different criteria apply for smaller reference amounts. Main dishes weigh at least 6 ounces per serving, contain not less than 40 grams each of at least two different foods from at least two specified food groups, and are represented as a main dish. Meals weigh at least 10 ounces per serving, contain not less than 40 grams each of at least three different foods from at least two specified food groups, and are represented as a meal. Food Reference: 21 CFR 101.9, 101.13, and 101.54-65 2007-2012, Food. All rights reserved. www.foodlabels.com 11
Additional Resources To help you in your quest for accurate nutrition analysis, here are some additional resources: Subscribe to Food Label News, a free monthly e-newsletter including topics of interest to food labelers and answers to reader questions: www.foodlabelnews.com/subscribe Request the free one-pager with rules of thumb used by Food ; enter rules of thumb in the Comments box: www.foodlabels.com/contact Join the discussion about topics of interest to food labelers on LinkedIn s Food Label Community: www.foodlabels.com/linkedin/community Register for a Genesis R&D training session: www.esha.com/training About Food Food, founded in 1993, provides nutrition analysis, food labeling and regulatory support to ensure compliance for products sold in North America (U.S., Canada and Mexico) and Europe. With over 1,500 clients worldwide, Food is the largest outsource provider of these services for manufacturers, distributors, importers, and restaurateurs from start-ups to Fortune 50 companies like PepsiCo and Target. Since 1998, Food has partnered with ESHA Research to conduct intensive training for Genesis R&D, the food industry s leading nutrition analysis software. Having conducted hundreds of training sessions, Food continues to provide insights on topics important to food labeling and accurate nutrition analysis. 12 2007-2012, Food. All rights reserved. www.foodlabels.com
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