It finally happened. The Food and Drug Administration (FDA) decided partially hydrogenated oils (PHOs) should no longer be Generally Recognized As Safe (GRAS).

FDA’s reason? In its request for comments published in the Nov. 8 issue of the Federal Register, the agency noted PHOs “are the primary source of industrially produced trans fatty acids, or trans fat,” which current scientific evidence establishes as health risks. Thus, FDA declared PHOs to be food additives, which it has the authority to regulate.

If finalized, this move would mean that food manufacturers would no longer be permitted to sell PHOs, either directly or as ingredients in other food products, unless they obtained prior FDA approval as a “food additive” for such use.

Does this mean that trans fat is going to zero? Eliminated — no more PHOs ever used again? Wow! For many of us, this decision came out of left field. I wonder whether FDA was going to give us a heads-up at the October 2013 meeting in Washington that was cancelled due to the US government sequester? 

In making its PHO announcement, FDA noted that since 2006, when trans fat content was put into the Nutrition Facts panel on food packaging, Americans’ trans fat consumption declined to 1 g per day in 2012 from 4.6 g per day in 2003. The baking industry worked diligently in 2006 and 2007 to get the labeled amount to zero in their product line. This push came via a major retailer that made continued shelf space contingent on reaching the definition of “zero” trans fat for the Nutrition Facts panel on that particular food. 

But investigation of products in the bakery aisle ­reveals many that include PHO in the ingredient legend yet state zero trans fat in the Nutritional Facts panel. That’s because under FDA labeling rules, less than 0.5 g per serving equals “zero.”

If PHOs are moved to food additive status, what will happen to the definition of zero trans fat? Will it remain the same at less than 0.5 g per serving? Does the potential switch of PHOs to food additive status also move us into accounting for trans fats in terms of ppm? Is the technology even available to measure trans fats at that level? What about the approximately 1.5% of trans fat in many shelf-stable liquid vegetable oils? Can analytical testing differentiate between naturally occurring trans fats and that produced during hydrogenation?

Shortening options exist for eliminating trans fats, but they are not the all-purpose styles bakers used in the past. Some will be soft instead of hard at room temperature. Their softer texture may require temperature control and consistent ingredient rotation during storage. Some may have lower smoke points, which would be unacceptable for frying donuts.

The new shortening alternatives are blends of different oil types, some using fractions of other oils to achieve the higher solids content bakers often require. These solid fractions will help to replace the texture PHO previously gave to finished products. Shortening and oil suppliers will continue to look for new technology and processing methods to develop these trans-free specialty shortenings as economically as possible.

What’s a baker and snack food producer to do? First, partner with your shortening and oil suppliers. They will provide a select number of their best options to evaluate. These will likely vary by product type. If you are lucky, you might be able to use the same solution across all soft cookies, but you will need a different shortening for crisp cookies.

Right after FDA’s announcement, a reader wrote to me: “We are a small manufacturer of meat pies and other savory, sweet and vegetarian pie items. Our pastry is composed of butter and shortening containing hydrogenated fat. Despite much experimentation and research, there has not been a satisfactory trans-fat-free shortening developed to deliver a similar crumb structure. If we revert to old-fashioned palm oil or lard fats, we consider research has proven they are just as risky to arterial health and high cholesterol. Is this overprotective, poorly thought-out new rule to spell the death of good pastry and pies?”

This reader articulated what many of us are thinking. Will trans-fat-free solutions create different product quality issues and more problematic health issues? Solving one problem and creating another is typically not an approach most of us would like to take.

The reader continued by suggesting another question: “If partially hydrogenated oils move to food additive ­status, will salt and sugar be next?”

Stay tuned to the FDA rulemaking process. Make your comments heard, and articulate what this means to your company, your budgets and your iconic brands.