What FDA’s Guidance Document For Menu Labeling Doesn’t Tell You

Finally!  FDA has released the long awaited guidance document.  It likely answers some of your questions (even if you didn’t like the answer!) but not others.

One thing is for sure: the guidance document doesn’t tell you what to do now. It doesn’t give you step-by-step instructions or a detailed game plan leading up to December 1, 2016.  So what do you do now?

There isn’t a “one size fits all” approach to preparing for menu labeling because each organization has their own starting line.  Some have their recipes analyzed – others don’t.  Some have practice with menu labeling in other states – others don’t.  Some have started preparing – others have put it off.

While the journey will look different for each “covered establishment,” my experience would indicate there are 7 key items that should be on your to-do list as you march toward December 1, 2016.  I like to call it my “7-point readiness plan”.

I’ve recorded a short video (13 minutes and 14 seconds, to be exact!) that summarizes the 7 key steps that should be part of your readiness plan.  Whether you are well on your way to compliance – or haven’t started yet – I’m hopeful the information I’ve compiled helps you along your journey.  My goal is to make menu labeling manageable for businesses and meaningful for consumers.  (PS – Unfortunately, this  video will only be accessible for about week! ) http://www.cldnutrition.com

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What I’ve Learned about Nutrient Analysis of Recipes

I entered into the restaurant industry over 4 years ago. Although it was nowhere in my job description (it never is!), I ended up building and maintaining a nutrient analysis program for the largest full-service restaurant company. I didn’t know much about recipe analysis at that time, but learning anything and everything I could quickly became a necessity.

Chances are, with menu labeling just around the corner you have found yourself in the same boat. While it would be impossible to share everything I know about recipe analysis and building an in-house nutrient analysis program in one short article, I am hopeful I can share a few things that may lessen your learning curve.

 1. Invest in the right resources.

The primary tool you’ll need to do in-house calculated nutrient analysis is a reputable software program. While I can appreciate the need to control the added costs of menu labeling, cutting corners when selecting a software program is not something I would recommend. Instead, carefully consider the capabilities you need and make the investment. Look for a program that is pre-populated with USDA data, allows you to import your own ingredient data when needed, is able to calculate moisture losses and targets (so you don’t have to do this work manually) and can produce the reports you need to demonstrate to FDA that you have a reasonable basis for the claim.

In the book Recipe Nutrient Analysis: Best practices for calculation and chemical analysis (www.culinarynutritionipublishing.com), we’ve created a list of 31 factors (cost, capabilities and compatibility) to consider when choosing a nutrient analysis software. Send me an email if you’d like me to share that list with you.

2.  Enlist the help of an expert.

I’m not sure if recipe nutrient analysis is more of a science or an art, but I do know one thing for sure: it is more complex than I could have imagined. If you think analyzing your recipes simply involves adding up the ingredients in the recipe, think again. Calculating the nutrients in a recipe involves using accurate nutrient information for exact amounts of specific ingredients and then adjusting for any preparation or cooking technique. It is far from an exercise of “plug and play” or simple addition. Trust me when I tell you it requires a specific knowledge base and skillset to do.

Ideally, your nutrient analysis calculations will be performed by a food or nutrition expert who has at least 2 years of experience performing recipe analysis. If you don’t have an expert on staff, contract the work to a consultant or organization that can provide the expertise you need. Fees range from $75 to $250 per recipe, so budget accordingly.   If you must assign this work to an existing employee who does not have experience in this area, consider finding an experienced recipe analyst who can teach and mentor your internal staff via an hourly contract or project fee. Consultants may also be willing to spot check or verify recipes for a reduced fee. If you are going to go to the trouble of putting calories on the menu, you should go to the trouble of ensuring they are as accurate as they can be – and that means enlisting the help of an expert.

3.  Make recipe analysis part of your culinary development process.

You’ll notice I used the term “nutrient analysis program” in the opening paragraph. That’s because analyzing your recipes is not is not a one-time event. Complying with the menu labeling regulation means analyzing your recipes and disclosing that information is now part of what you do. It cannot be an afterthought. Establish a cross-functional team to examine your culinary development process and embed the activity of recipe analysis into your timelines. Formally assign roles and responsibilities and revisit what you’ve established as you move forward so that you can build on what works and adjust where needed.

4.  Send fried foods to the lab.

While it is exponentially more expensive than calculated nutrient analysis, it is recommended that all fried items be analyzed using chemical analysis. Estimating moisture loss and fat absorption is difficult, if not impossible, to estimate accurately using a calculated approach (how much oil does your fried chicken absorb?). Lab fees range from $450 to $1000 per item. Request quotes from several accredited laboratories and try to negotiate their fee based on your volume. It can take anywhere from 10 – 21 days to receive the results from the lab, so you’ll need to come to an agreement with the lab on estimated turnaround time and build that into your timeline.

In addition to fried foods, it is best practice to send marinated ingredients, braised ingredients, seasoned and cooked proteins, house-made stocks, reduced sauces and pickled or fermented foods to the lab as well.