Committee Responses

Since May 1999, the Defining Dietary Fiber on-line discussion group has served as a public forum for input on the topic of defining dietary fiber. A number of individuals from academia, government, and industry have submitted their opinions on the issue. This page summarizes many of these comments along with responses from select members of the AACC Committee to Define Dietary Fiber.

 

 


 

Physiological vs. analytical definition


In terms of nutritional/physiological parameters, many new carbohydrates not currently having fiber labeling status, such as inulin and several naturally based oligosaccharides, meet the general definition or concept of dietary fiber. They are remnants of plants, they resist digestion by mammalian digestive enzymes, reach the bowel intact, are fermented to short chain fatty acids by resident microflora, and affect both the gastrointestinal tract and its function and influence host systemic physiology.

While no unequivocal definition of dietary fiber exists internationally, where national regulations make provision for a definition of dietary fiber, those definitions usually correspond to one based on non-digestibility (i.e. on a nutritional criterion). In some countries, additional analytical criteria are required. The US has an analytical definition for dietary fiber classification and labeling as defined in 21 CFR A7 101.9 requiring that dietary fiber components must be analytically measured by FDA approved methods before being included in the Nutritional Facts label.

Although for the purpose of food policy it may appear on the surface more practical to apply a simple analytical definition, it is likely not be satisfactory from a nutritional point of view. Understandably, the dietary fiber concept and need for an increased consumption of dietary fiber is based on the healthy effects the various entities making up the concept have on human physiology, and not because of their analytical or physiochemical properties, which in part defined their method of determination. Thus, if specific compounds that represent the dietary fiber concept according to a nutritional definition are not detected as dietary fiber by current applied fiber methods, other more specific methods will likely be required for the analysis of such compounds. Due to the increasing number of naturally-occurring carbohydrates that fit the nutritional definition of fiber, many of which are not measured adequately in current fiber methods because of their different physiochemical properties, it becomes evident that no single analytical method can identify all types of fiber with sufficient specificity, accuracy and precision. As such, it appears reasonable to have several methods as standard for the measurement of differing components of the dietary fiber concept and to further replace or supplement existing methods by appropriately validated methods, if the new methods provide closer agreement with the definition of dietary fiber.

Based on the complexity of defining the dietary fiber concept using analytical terms, a nutritional or physiological definition rather than an analytical definition would appear much simpler in terms of nutritional labeling, feasibility for food policy, law enforcement and the possibility to supply customers with foods that help achieve recommended levels of fiber intake.

Further, as was most evident in the recent article from the New England Journal of Medicine, the current general definition of dietary fiber lends confusion, as it provides no differentiation of insoluble, and soluble fiber types (viscous soluble, non-viscous soluble). As such, misinformation regarding the health benefits of various dietary fiber components can be the result. Moreover, the current definition does not differentiate soluble dietary fiber components of unlike chemical bond or make up and consequently differing physiological effect and potential health benefit. By example, most viscous soluble dietary fibers such as xanthan gum, pectin, guar gum (high water binding carbohydrates) have influence on gastric emptying and have influence on human metabolism and health, such as blood glucose effects and satiety through this gut-based effect. In addition, their fermentation varies by chemical bond, due to the specifics of the gut microflora population and activities of their various fermentation enzymes. By contrast, several non-viscous carbohydrates, such as inulin, have little effect on gastric emptying, but rather have systemic physiological effects through regulation of metabolic pathways through short chain fatty acids (SCFA) produced from their fermentation. Regarding soluble fiber components, it is very important to differentiate the chemical make up of the fiber component as the chemical bond (and the molecular chain distribution) is critical to the fermentation pattern and ultimately the total SCFA production and its profile. As the SCFA regulate key physiological mechanisms differently, such as glycolysis, gluconeogenesis, lipid metabolism, and mineral absorption, it is important that fermentation substrates be selective for specific microflora that produce levels of SCFA that can provide potential for better health, i.e. higher levels of propionate and butyrate rather than acetate. Acetate being known for its contribution to gluconeogenesis, while propionate for its positive effects on glycogen formation, normalizing blood glucose and have effects on reducing cholesterol formation. In addition, butyrate is utilized primarily as energy for colon cells and is a strong differentiating agent, having implications for inhibiting proliferation of colon cancer cells. Several differing soluble fiber components have been shown in vitro using human fecal material to produce relatively high propionate levels and moderately butyrate levels (inulin, beta- glucans, high amylose pea starch), while producing relatively low acetate levels. Combinations of these soluble fiber components are likely to produce desirable health effects.

Thus, when defining the dietary fiber concept, it is important to differentiate or categorize classes of fiber, in addition to specific types of soluble dietary fiber having specific physiological effect.

Often a low cost insoluble dietary fiber component is used in a formulation to increase the fiber label and marketing position of a food or nutritional product. This practice undereducates, misinforms and misleads the consumer as to the true health benefits of the active nutritional components they are consuming. This practice is made possible by design of the current dietary fiber definition.

Scientific definition and regulations need to be more specific and more fully clarify the use of specific dietary components for health, i.e. insoluble fiber (roughage), viscous soluble and non-viscous soluble each combined with a specific chemical linkage and general physiological effect.

Mr. Bryan C. Tungland
Vice President, Scientific and Regulatory Affairs
Imperial Suiker Unie, LLC
Sugar Land, Texas

 


Committee Responses:

 

Inulin and some of the oligosaccharides appear to have physiological impact, thus: 1.) Existing TDF methods should be modified to include these components or 2.) New methods can be added to the TDF procedure…maybe complete dietary fiber? However, I take issue with the concept that low-cost IDF is not advantageous in food products. IDF increases stool weight, etc. Less-refined materials such as brans and peels that are essentially food processing by-products may contain important associated compounds that act synergistically with fiber constituents to improve human health. Fiber has multiple benefits and thus multiple sources of fiber are useful to include in the diet. – Mary Ellen Camire

Overall, a useful contribution highlighting inulin’s place in the dietary fiber debate. – Stuart Craig


The statement “No single analytical method can identify all types of fiber with sufficient specificity, accuracy, and precision” translates into “It’s unlikely that a universal method can be developed for the determination of all types of fiber.” This is not unique for fiber analysis. Nutritional and physiological definition of dietary fiber have been based on epidemiological studies on foods (fruits and vegetables), yet most of the animal or human studies employed purified fiber sources, such as pectin, guar, cellulose, wheat bran, etc. Differentiation of insoluble and soluble fiber types must depend on analytical (specifically physicochemical) definition. Currently, the designation is strictly method dependent. When the day comes that sequencing of polysaccharides is as routine as for purified proteins, we should be able to answer the questions regarding the true chemical makeup of the fiber components as based on their chemical bonds. Betty Li

 

I think the definition can be expanded beyond just the physiological parameter of non-digestibility, but this could be accomplished in a companion document to a simple definition or statement. This companion document should offer a great deal of additional information. A method or methods should not be the deciding factor in having a definition of dietary fiber or limit the food components, which should be included as dietary fiber. Additional methods should be available to recover and quantitate oligo-, di- and mono-saccharides, which are non-digested and non-absorbed. It remains to be decided how small an oligosaccharide (DP less than?) should be considered a source of dietary fiber. At the present time, I favor including compounds with DP values of three (3) and higher.  Based on the complexity of proposed dietary fiber components, there appears to be more than one category for non-digestible and non-absorbable carbohydrates in foods. There are dietary fiber components derived from plant cells, those that are derived from plant cells but not recovered by current methods for DF analysis, and those manufactured or isolated as (poly)saccharides", "carbohydrate analogues", "dietary fiber analogues" or "bulking agents". These many food carbohydrates, non-digestible and non-absorbable, need to be adequately described, and possibly in the accompanying document. For some of these carbohydrates, additional verification of their physiological effect(s) will explain why these compounds should be defined as dietary fiber. Does everyone agree we have sufficient information to suggest a change in colon pH, an accumulation of SCFA, and changes in intestinal microflora are advantageous and benefit long term health? The current discussions on a definition of dietary fiber will help review the available information on these important topics and effects of dietary fiber. Do terms such as "laxation", "soluble dietary fiber", "insoluble dietary fiber" and "oligosaccharides" need to be included in the definition? Is the term "health" or some variation of this term, such as "disease prevention" implied in the definition of dietary fiber or should it be clearly stated in any definition? - Dennis Gordon


RETURN TO LIST OF COMMENTS


 

Dietary fiber as “calorically inert”

 

I have a simplistic way of looking at fiber: any plant carbohydrate material (or its equivalent) that cannot be converted into calories through digestion and absorption. If oligosaccharides are absorbed and converted into calories, they would be excluded by this definition, which can be summarized as "calorically inert."

Marion Nestle
Department of Nutrition and Food Studies
New York University

 


Committee Responses:


Bacteria partly or completely hydrolize polysaccharides, yielding fatty acids that provide some energy, thus these compounds are not really calorically inert. Lignin is important – why exclude it? – Mary Ellen Camire


We must move beyond the “inert” concept towards physiological benefits. – Stuart Craig

This definition will exclude virtually all types of fiber except cellulose or whatever can be recovered in the feces. – Betty Li

 

I agree with Mary Ellen Camire that all dietary fiber is fermented to some degree in the large intestine. (There are a few exceptions.) There is a very good debate currently in progress as to the amount of energy liberated through the fermentation of non-digestible and non-absorbable carbohydrates. The debate centers on how much net metabolizable energy (NME) is contributed to the host. This is an important topic for research now and in the future. The fact any of these carbohydrates, including those currently considered dietary fiber are fermented with energy loss through other pathways or retained as NME may be the one criterion for including them as a source of dietary fiber. Their fermentation leads to biochemical changes caused by the bacteria in the intestine and subsequent physiological function(s). Are these biochemical and physiological changes beneficial? – Dennis Gordon

 


RETURN TO LIST OF COMMENTS


 

“Oligo” vs. “poly”


Being familiar with the cell wall components from first hand experience, I feel comfortable with the current definition of dietary fiber. Adding other components would seriously dilute the meaning. Whatever is added is already covered under "Additives" and I feel that it should remain there. This includes synthetic polymers. Inclusion of oligosaccharides in the definition would defeat the purpose. After all, these are mostly soluble, and don't fit the definition of fiber. Fiber, from definition, means a long chain or strand, for which the term 'oligo' does not qualify. If it would be long, it would be 'poly'.

Geza Hrazdina
Professor of Biochemistry
Department of Food Science and Technology
Geneva, N.Y

 

 

Committee Responses:


This argument reminds me of the line from Romeo and Juliet: “A rose by any other name….” Since the interest in fiber derives from its health benefits, these properties should be included in the definition. – Mary Ellen Camire


Nicely put, Mary Ellen. This comment captures the “traditionalist” view, which requires serious debate over the next months. – Stuart Craig

This brings us to the question as to whether sugar alcohols, raffinose, stachyose, etc. should be included in the fiber definition, as others have suggested later on. – Betty Li

 

Why does dietary fiber only have to be a long chain carbohydrate having a DP value of 10 or more? Many oligosaccharides may be proven to be beneficial to the host. There is accumulating evidence that oligosaccharides (DP < 10) are beneficial. See my earlier comment to B. Tunglund. Exclusion of oligosaccharides because they cannot be recovered by a current method of analysis should not be a reason for excluding them as a source of dietary fiber. Again I agree with Mary Ellen Camire, the body will recognize an oligosaccharide in nature the same as if it was synthesized in the laboratory or produced through genetic engineering. I think we are all interested in the "associated substances'" which are consumed along with plant foods whether they provide polysaccharides or oligosaccharides. Although there is accumulating evidence for many of the "associated substances" in plant foods as to their importance to human health and disease, we are discussing a definition of dietary fiber. Other definitions may be needed for "associated substances". Yes, I acknowledge that it may be the combination of dietary fiber and "associated substances" in plant foods, which may be most effective in promoting health and preventing disease. However, dietary fiber can stand-alone based on its physiological importance to the body, thus a definition for dietary fiber would be helpful. – Dennis Gordon

 


RETURN TO LIST OF COMMENTS


 

A nutritionist’s views


I believe that for the uses identified, the rather "classic" definition will suffice. I feel that the issues surrounding resistant starch, various oligosaccharides, etc cannot be resolved at this stage and can/should be dealt with separately. Sometime in the future we may be able to add/include additional compounds to the dietary fiber or "oligosaccharide" list. Persons/manufacturers may still be able to identify the compounds included in foods/supplements even if not "covered" in the definition.

Peter L. Beyer MS, RD
Associate Professor,
Dietetics and Nutrition,
University of Kansas Medical Center
Kansas City, Kansas

 

 

Committee Responses:


This comment does not explain how consumers will know that the compounds not recovered in the AOAC TDF procedure behave in the body as fiber. – Mary Ellen Camire

 

Communication of the scientific evidence of physiological benefits is the best counter to this “do it later” argument. – Stuart Craig


The issues surrounding resistant starch, various oligosaccharides and others are part of the objectives for a reexamination of the current definition(s) for dietary fiber. Whether the issues can be resolved remains to be seen as we consider all the comments received from individuals and open discussions at various workshops, forums, and symposia planned for the remainder of 1999. – Betty Li

 

There may have to be more than one chemical description of dietary fiber components as part of a new definition. How do we both regulate and allow progress in the form of new "carbohydrate analogues" or "dietary fiber analogues" into the food chain and possibly onto the food label? There is an interesting precedent with the approval and use of non-digestible and non-absorbable fat substitutes into the food supply. Although they are fats, they are not included as part of the fat content of a food on its Nutrition Facts panel. Added to this list of fat substitutes in our diet are sterols added to margarine's to block the absorption of dietary cholesterol. We have the opposite situation with some carbohydrates proposed as dietary fiber. Can labeling allowances be made for oligosaccharides, or "carbohydrates analogues" or "dietary fiber analogues" or "bulking agents" especially if they are shown to have positive physiological effects? How do we make allowances in the definition of dietary fiber to be honest with the consumer, scientific community and ourselves? – Dennis Gordon

 

 


RETURN TO LIST OF COMMENTS


 

Including synthetics in the dietary fiber definition


Because of my educational background, research interests, and a certain perspective on how fiber should be defined, I am quite comfortable accepting FDA's/USDA's definition of dietary fiber as it stands now. As some synthetics are also finding use in processed foods, it may be appropriate to broaden this definition to include synthetics.

Gur Ranhotra, Ph.D.
Director, Nutrition Research
American Institute of Baking
and Adjunct Professor, Kansas State University

 

 

Committee Responses:


I agree with the inclusion of synthetic, but am curious about FDA/USDA definition (??) – Mary Ellen Camire

 

“Synthetics” should have human clinical data to substantiate physiological benefits. Otherwise, we lose credibility. – Stuart Craig

 

We need guidance as to how we could broaden the current definition to include “synthetics” and avoid the danger of including, nondiscriminately, any food components which reach the colon. – Betty Li

 

There is no FDA/USDA definition of dietary fiber. Current FDA rules, appearing in the CFR, pertain to what is measured and reported on the Nutrition Facts panel. The FDA in their rules on health claims refers to dietary fiber provided by whole cereals/grains, fruits and vegetables. In making laws to incorporate the amount of dietary fiber on the food label, the results obtained by approved AOAC methods has become the de facto definition of dietary fiber in the United States. This dietary fiber is the residue resulting after a food is treated with three hydrolytic enzymes, plus the material precipitated in 70% ethanol. The project of evaluating the historical definition and proposing a new definition for dietary fiber can be forwarded to the FDA for their possible consideration. One of the big issues today is that certain manufactures of "carbohydrate analogues", "dietary fiber analogues", "(poly)saccharides" or "bulking agents" would like their compound(s) classified as dietary fiber. Instead of addressing the issue one carbohydrate at a time, this project to review the definition of dietary fiber will help bring many similar questions together which may have a common answer. – Dennis Gordon

 


RETURN TO LIST OF COMMENTS


 

Compounds resulting from processing & preparation


I strongly believe that the definition of dietary fiber should not change to reflect the changes in the diet because there are several compounds of high molecular weight that resist the digestion by digestive enzymes of the human digestive tract these compounds are produced through food processing or food preparation or adding the compounds to perform certain function. I'll try to give examples:

1.      Polydextrose (cyclic)

2.      Fat substitutes, olestra

3.      Scorched or burnt food such as those resulted during barbecue fried breaded products etc.

4.      Polymerized fatty aldehydes which are produced as a result of breakdown of oxidized fat

5.      Polysorbates which are used as emulsifiers or surfactants

6.      Cartilages and hair etc. I hope these examples will help you not to change the definition.

 

Sami M. Al-Hasani, Ph.D.
ConAgra Frozen Foods Analytical Laboratory
Columbia, Missouri

 

 

Committee Responses:


Actually, these examples had the opposite effect on me. Perhaps bacteria cannot digest Olestra, but what shall we do with undigested fat that ends up in the colon because the person has taken a chitosan supplement or the new fat-absorbing drug Xenical? The lipid will surely nourish some bacteria. Do we have any info on the utilization of lipids in the colon? – Mary Ellen Camire


Deeper into “Pandora’s Box”. – Stuart Craig


These are diet constituents we need to give some serious considerations during our discussion on defining dietary fiber. – Betty Li

 

There are many non-digestible and non-absorbable polymers-compounds in our food supply, albeit in small amounts, which are not dietary fiber. These compounds should not be included as DF and for the most part they are excluded. An analytical correction is made to exclude nitrogen-containing compounds in most AOAC methods to measure dietary fiber. I agree polyols and polysorbates should not be included in the definition of dietary fiber. Resistant starch was found to be an artifact in the analysis of dietary fiber. Now resistant starch is commercially produced and added to foods as a source of dietary fiber and to lower its calorie content. Will the same happen with Maillard products in the future? I hope not. Many compounds will have to be individually reviewed to be included as a source of dietary fiber. MEC mentions an interesting compound chitosan derived from chitin. Are these two polymers dietary fiber? Issues raised by Al-Hasani need to be resolved. – Dennis Gordon

 


RETURN TO LIST OF COMMENTS


 

Synthetic oligosaccharides


Although there is no universal consensus on the definition of dietary fiber, the results of the international survey by Prosky and Lee JAOAC, 78(1), 22-35(1995)) showed that most respondents favored a definition based on both physiological and chemical attributes, as opposed to the idea of fiber being the sum of remnants of plant components resistant to digestive enzymes. However, there was no discussion in the survey of either synthetic oligo- or polysaccharides being incorporated into the definition of fiber. If synthetic oligosaccharides are to considered as dietary fiber, then what is the molecular weight cut-off going to be? n3D5, 10, 15, etc.? Since most components of fiber are polymers of high molecular weight, I think it is questionable to include a synthetic component of low molecular weight as dietary fiber, especially if it doesn't precipitate under conditions of existing methods, i.e. 75% alcohol. The definition of dietary fiber needs to be based on scientific analysis and consensus, not on marketing concepts.

Bob Sapp
ConAgra Frozen Foods Analytical Laboratory
Columbia, Missouri

 

 

Committee Responses:


Good points. I think we selected DP3D10 as a cutoff. – Mary Ellen Camire


I have a problem with DP 10 as a cutoff. It’s just as arbitrary as 80% ethanol, and analytically very difficult. FDA has an issue with low DP, but especially mono- and disaccharide. These can be more easily quantified. So, is DP3 a more reasonable cutoff? – Stuart Craig

As we know, the distinction between oligo- and polysaccharides is rather arbitrary. The International Union of Pure and Applied Chemistry assigns oligosaccharides to be DP3-DP9, and polysaccharides to be > 10. It is not based on any specific physicochemical characteristics. – Betty Li

 

The latest definition agreed upon at the recent AACC/ILSI workshop, June 2-3, includes the term (poly)saccharides. I think the intent of this term was to include saccharide polymers above a DP-10 value (poly), and to oligosaccharides below DP-10. There was no consensus as how low a DP number should be included as a source of dietary fiber. This must be resolved. Future discussions should provide an explanation or justification as to what is included and excluded from any new definition. I initially agree with SASC that a DP value of 3 could be a cut-off. Again, any method that incorporates an arbitrary inclusion limit by precipitation in 70% ethanol should not be a criterion in defining dietary fiber. If we consume FOS naturally occurring in foods, our body physiologically considers this a form of dietary fiber although it was not recovered in the AOAC assay. – Dennis Gordon

 


RETURN TO LIST OF COMMENTS


 

Using pharmacopoeia as a guide in defining dietary fiber

 

As we walk the fine line of pharmaceutical (drug) ADA nutraceutical, functional food, suplements, etc., it may behoove us to use the same "template" as that of pharmacopoeia, i.e. structure-function to define those fibers (natural and synthetic) that are resistant first to alimentary human enzymes (non-digestible and/or non- absorbable) and secondly (and separately) to fermentation while defining the microflora of relevance.

Robert Serrano
Grain Millers, Inc.
VP-Technical Operations
Eugene, Oregon

 

 

Committee Responses:


Good point. – Mary Ellen Camire

This gets us toward defining scientific criteria. – Stuart Craig


Drugs are well characterized compounds, whose structure-function can be tested. No matter how we eventually define dietary fiber, it will remain a complex entity. – Betty Li

 

I agree with the comments of Mary Ellen Camire and Stuart Craig. Expanded comments like this should be included in the collateral document to accompany a simple and useful definition. – Dennis Gordon

 


RETURN TO LIST OF COMMENTS


 

Inulin


I have been doing some work with inulin, which some people would like to see listed as a dietary fiber. Since it is not digested by enzymes but is fermented it is difficult to find a place for it on a label. I think Canada may list it as a fiber. It would be good to be consistent. In Europe inulin is used in more products and there is a lot of interest here too. Nebraska is growing some chicory and looking at it as a crop to rotate with sugar beets.

Marilynn Schnepf
University of Nebraska

Lincoln, Nebraska

 

 

Committee Responses:


I agree that harmonization with Canada is important and that inulin has benefits. – Mary Ellen Camire


Ditto. – Stuart Craig


This calls our attention to the question: Are we seeking a definition for dietary fiber mainly for nutritional labeling, for diet/health relationship, for nutritional research purposes, or for all of the above? – Betty Li

 

Yes, any definition agreed upon in the United States must consider trade among all countries. Canada does have guidelines on novel sources of dietary fiber. These guidelines can be found at this website. The Canadian definition of dietary fiber, not included in their Food Directorate's guidelines on novel dietary fiber is provided. This definition was approved in the 1985 report of their Expert Advisory Committee on Dietary Fibre. The Canadian definition of dietary fiber is: "Endogenous components of plant material in the diet which are resistant to digestion by enzymes produced by man. They are predominantly nonstarch polysaccharides and lignin and may include, in addition, associated substances". – Dennis Gordon

 


RETURN TO LIST OF COMMENTS


 

Primary principles, characteristics, etc. of dietary fiber



Principles to use in defining dietary fiber:

1.      Dietary fiber is a marker for plant foods in the diet.

2.      Dietary fiber is chemically complex and hence the methods for are not digested by enzymes of the mammalian small intestine.

3.      The physical characteristics of dietary fiber components vary.

4.      The term dietary fiber, in contrast to specific chemical composition, encompasses a physiologic definition of fiber.

 

Primary characteristics of dietary fiber:

1.      Predominately of plant origin

2.      The primary components are nonstarch polysaccharides and oligosaccharides. Polymers that cannot be digested by enzymes from the mammalian small intestine

 

Issues that influence the definition of dietary fiber:

1.      Analytical methods are likely to include some additional non-digestible materials such as lignan and Maillard reaction products. Although these compounds are not categorized as carbohydrate, they are a part of the non-digested material in the gut.

2.      Oligosaccharides and resistant starch are carbohydrates, they are not digested in the small intestine, and function like nonstarch polysaccharides as fermentable carbohydrates. In this context they should be included in dietary fiber.

3.      Dietary fiber is a generic term that encompasses the physiologic characteristics of this food component. Alternatively this food component can be defined based on chemical components (e.g. NSP, oligosaccharides, cellulose, resistant starch etc.). In a sense this is analogous to considering chemical composition vs. bioavailable nutrient (e.g. digestibility of proteins vs. N content, equivalents for vitamins vs. isomers) both approaches are useful from a nutrition perspective and not mutually exclusive.

4.      Sources of fiber can be characterized according to physical characteristics such as water holding capacity, viscosity, fermentability, and binding capacity. Defined conditions are needed for determining these characteristics of
fiber.

 

Barbara O. Schneeman, Ph.D.
College of Agricultural and Environmental Sciences
University of California at Davis

 

 

Committee Responses:


Excellent. – Mary Ellen Camire


Ditto. – Stuart Craig

This is a comprehensive listing of all the characteristics and issues concerning dietary fiber. We should examine all the points thoroughly. – Betty Li

 

I would first agree that dietary fiber should be restricted to carbohydrates, non-digested and non-absorbable. There are so many different physiological functions associated with dietary fiber. Which are the most important and should be stated or implied in a definition? How important is fermentation in the definition of dietary fiber? Some people would like to include the term "fermentation" in the definition. These comments again suggest the need for a collateral document to expand in detail and list categories of compounds to be included as dietary fiber. The term "non-starch polysaccharides" is an appealing term to be used with the definition of dietary fiber. This term is used in the United Kingdom and Canada in their definitions of dietary fiber. If this term were used, it would imply that any type of resistant starch or oligosaccharides should not be included in the definition. – Dennis Gordon

 


RETURN TO LIST OF COMMENTS


 

Classes of carbohydrates


Perhaps this is an opportunity to mesh chemical composition, analytical needs and physiological function, and distinguish the various carbohydrates. Undigestible, naturally occurring disaccharides (i.e. lactose), oligosaccharides (stachyose, raffinose), and sugar alcohols (sorbitol, mannitol), among others, elicit physiological responses that have been inadequately recognized. Data on effects and functions of the different classes of carbohydrates have accumulated over the past 25 years, and analytical methodology for their analysis has continued to improve.

We may be in a position to use existing carbohydrate categories - monosaccharides, disaccharides, polyols, oligosaccharides (DP 3-10) and polysaccharides - to recognize that these other classes have beneficial properties, although they are not dietary fiber, and at the same time, integrate function and chemical composition.

 

Each class of carbohydrates would contain digestible and undigestible categories that could include natural and synthetic compounds.

Each class could be analyzed accurately (as well as reproducibly, as now is the case for some of these components) for its chemical composition.

Each class would have to be characterized for other properties that precipitate the physiological response to ingestion, i.e. laxation with polyols and oligosaccharides; viscosity for the hypocholesterolemic mechanism of action; laxation with non- or incomplete-fermentation; short chain fatty acid pattern resulting from fermentation. Obviously, some of these responses have been more thoroughly elucidated than others, and there is a need for physiologically relevant measures. In this regard we have not made as much progress.

Each category within a class of carbohydrates would elicit a specific set of physiological responses.

It may be most appropriate to retain the term dietary fiber and the current definition to identify the heterogeneous and naturally-occurring mixture of polysaccharides and lignin that are present in foods.

The strengths of this approach include:

1.      Use of the chemical classification of carbohydrates

2.      Characterization of physicochemical properties

3.      Association of function or physiological effect with composition and properties

4.      Recognition of benefits of other carbohydrates, natural and synthetic

5.      Recognition of the complex and variable component in the food supply we currently term dietary fiber

 

The limitations of this approach include:

1.      Lack of laboratory methodology to predict physiological response

2.      Lack of physiologically relevant measures of physicochemical properties.

 

Within this framework, compounds would be correctly labeled and manufacturers would be able to promote healthy benefits of their products.

Since processing may alter properties of naturally occurring materials, there would need to be demonstration by manufacturer that response was the same. An example that comes to mind is partial hydrolysis which can reduce a hypocholesterolemic response. I believe that for many of the functions that have been elucidated in the past 25 years, in vitro or analytical tests that give physiologically relevant results can be standardized.

I have been uncomfortable for some time with several materials being labeled dietary fiber, when in fact, they are an oligosaccharide or polysaccharide.

Judith A. Marlett, Ph.D.
University of Wisconsin
Department of Nutritional Sciences

 

 

Committee Responses:


Very good points, but I wasn’t sure of how lignin and chitosan would fit in. – Mary Ellen Camire


How much can we fit on the nutrition label? Can we have “fiber” and another term? Probably not. Increasing “fiber” content of  foods by replacing digestible ingredients with non-digestible carbohydrates leads to improved health. Therefore, it is more practical to broaden the fiber term. – Stuart Craig

 

Along with Barbara Schneeman’s comment above, the author has outlined a number of important factors to be considered during our discussion on defining dietary fiber. – Betty Li

 

I think the term dietary fiber should remain and the term used on the Nutrition Facts panel of food packages. I agree with Marlett. We now have the chance to categorize the many different compounds into common physiological functions. – Dennis Gordon

 


RETURN TO LIST OF COMMENTS


 

Effects of processing on starch or protein


I think that fiber should be defined from a physiological perspective, because the effects of food processing can render starch or protein undigestible therefore allow it to act as fiber.

Gabriel Keith Harris
USDA Fellow
Department of Food Science and Technology
Columbus, Ohio

 

 

Committee Responses:


Undigested protein has been overlooked in our discussions. I believe that the USDA WRRC found that such protein can lower cholesterol. – Mary Ellen Camire

Pandora’s Box II. – Stuart Craig

Should we simply ignore those food components that are produced during processing, even though they may possess certain physiological characteristics attributable to dietary fiber? – Betty Li 

 

I favor dietary fiber being restricted to carbohydrates thus eliminating any type of polymerized fat or protein. I invite Dr. Harris to submit a definition he feels would include more physiological actions-perspectives of dietary fiber. The AACC Committee to Dietary Fiber is looking for ideas on a definition that could include more on the physiological action(s) of dietary fiber. – Dennis Gordon

 


RETURN TO LIST OF COMMENTS


 

Characterizing related qualities of carbohydrates


I don't have a problem with the present definition, although it is somewhat arbitrary. It is probably useful to have additional ways to characterize related characteristics of carbohydrates, but I would favor additional adjectives or using other names until we know their relevance to physiology and disease risk. For the most part, these are research issues.

Walter C. Willet, M.D., Dr. P.H.
Chair, Department of Nutrition
Harvard School of Public Health

 

 

Committee Responses:


I disagree that these issues are research-based. – Mary Ellen Camire

There is sufficient data to support broadening the definition. -  Stuart Craig

This is a reasonable suggestion we should keep in mind. – Betty Li

 

I agree with MEC and SACS that additional research is not needed now as we consider a definition for dietary fiber. Adequate discussion with available information will go a long way in helping to possibly propose and defend a new definition. If the present definition were arbitrary, would inclusion of such terms as "(poly)saccharides" and "carbohydrate analogues" be acceptable in a new definition. These terms must be defined. – Dennis Gordon

 


RETURN TO LIST OF COMMENTS


 

More detailed compositional statement needed?


I agree with the need for a more accurate definition or description of dietary fiber. The current definition is too narrow and contributes to limit our thinking about the diverse chemical, physiological and physical properties of fiber. Research indicates that the physicochemical action of fiber components are diverse in different parts of the digestive system and impacts human health. Although the current definition of dietary fiber has served us well as an estimate of mass of materials and amount of soluble/insoluble, it oversimplifies the role of fiber. The committee might consider a more detailed compositional statement, such as nonstarch polysaccharides chemical composition; sterols, waxes and other indigestible lipids; and phenolic compounds. Also, I think the word fiber connotes plant polysaccharide materials that exclude the other chemical classes.

Wallace Yokoyama, Research Chemist
USDA, WRRC
Albany, California

 

 

Committee Responses:


I agree. – Mary Ellen Camire

There’s a lot to consider. – Stuart Craig

Interesting point on the word fiber. Should we consider dropping that altogether? Probably not. – Betty Li

 

Again, I think a simple statement of definition and a supporting document will satisfy Yokoyama's suggestion. I also think Yokoyama is correct in stating the term "dietary fiber" pertains to plant foods, whole grains and cereals, fruits and vegetables. What are the best terms to have in a definition to describe oligosaccharides (DP <10), isolated sources of dietary fiber, and carbohydrate analogues? – Dennis Gordon

 


RETURN TO LIST OF COMMENTS


 

Subdivisions of dietary fiber definition

 

My views are the following: The definition already accepted by the U.S. FDA and the Department of Agriculture is, if a short definition is wanted, appropriate. Of the alternative wording "hydrolysis" vs. "digestion." I prefer the latter, since a substance or botanical component might not be resistant to hydrolysis by human (digestive tract) enzymes but yet end to be regarded as dietary fiber due to incompleteness of the hydrolysis, e.g. affected by physical barriers or similar factor. In addition to the main definition, a reconsideration of the subdivision of dietary fiber should be made for the following reasons:

 

 

 

 

Yrjo Malkki
Managing Director, Cerefi Ltd, a consulting company holding
industrial rights to patented and non-patented processes for
enrichment of oat dietary fiber. Affiliation formerly Director and
Professor, Food Research Laboratory of the Technical Research Centre
of Finland Author and co-author of 10 original research papers and 3
patents related to dietary fibre

 

 

Committee Responses:


FDA/USDA definitions…is this a pervasive industry belief? The criteria for solubility are not strong and need to be carefully considered. – Mary Ellen Camire


Good points.  – Stuart Craig

I agree completely with the preference of using “digestion” vs. “hydrolysis” and with the statement that the definition and determination of soluble fiber is not satisfactory as they stand now. Viscosity is one certain dietary fiber constituents. – Betty Li

 

I am not sure we need to explain soluble and insoluble dietary fibers in the definition. A discussion of these topics could be included in the accompanying document. The comments of other suggest sources of dietary fiber be categorized based on their chemical, physical and physiological properties. Viscosity is just one of these properties. – Dennis Gordon

 


RETURN TO LIST OF COMMENTS


 

Position of the Corn Refiner’s Association, Inc.


The Corn Refiners Association, Inc. (CRA) appreciates the opportunity to provide these comments regarding the appropriateness of the current definition for dietary fiber. Because of the growing importance of physiological function ascribed to fiber fractions, the definition of dietary fiber and prescribed analytical method should be carefully identified.

The CRA is the national trade association representing the corn wet milling industry. Members of the Association produce starches, sweeteners, alcohol, feed ingredients and vegetable oil using the corn wet milling process.


The dietary fiber analytical methodology needs to be improved to better support the current structural/physiological definition. The present methodology has resulted in confusion to consumers, food formulators and regulators, and has impeded the development of new foods to assist the public in achieving national nutrition goals like those promoted in the Dietary Guidelines for Americans.

Defining fiber in terms of more specific physiological function to encompass all known health benefits of fiber and a formulated list would be unduly restrictive. Rather, the analytical methodology should be broadened to encompass both insoluble and soluble components of fiber. Specifically, we believe the approved analytical method which is specific for insoluble fiber should be broadened to include soluble fiber which is not currently recovered.

The following comments consider specific issues raised in this dicussion:

Should the definition include oligosaccharides and other saccharides That are not recovered with the current AOAC method for measuring total dietary fiber?

 

Yes. Oligosaccharides like polydextrose and other saccharides,  currently excluded with the current AOAC method for measuring total dietary fiber, should be included in the definition. This is provided they satisfy Trowell?s redefinition of dietary fiber, accepted by the scientific community in 1976. The definition was broadened to include all indigestible polysaccharides (mostly plant storage saccharides), such as gums, modified celluloses, mucilages, oligosaccharides and pectins. However, Trowell's definition retains the original physiological requirements of edibility and digestion resistance. During the 1995 AOAC International Workshop on the Definition and Analysis of Complex Carbohydrates and Dietary Fiber, participants confirmed that the physiological definition of fiber does indeed include digestion-resistant oligosaccharides.

 

How should synthetic polymers be considered in any new and updated definition?

 

For synthetic polymers to be considered dietary fiber, they should conform to the following requirements: Structural; polysaccharide or lignin composition. Physiological; edible and digestion resistant.

 

Should non-digestible and non-absorbable but fermentable oligosaccharides and monosaccharides be included?

 

Digestion-resistant oligosaccharides should be included in the definition of dietary fiber; digestion-resistant monosaccharides appear to be outside the scope of any reasonable definition. Given sufficient exposure (time and concentration) to an energy source, lower bowel microbes will adapt to virtually any oligo- or polysaccharide substrate and ferment it to some degree. Some fermentation products provide significant health benefits.

 

Is dietary fiber only obtained from edible plant cells?

 

No. As stated above, the chief determinants for dietary fiber should be structural similarity to plant cell polysaccharides or lignin, and the physiological requirements of edibility and digestion resistance. There are components commonly used in foods today that satisfy these determinants, are not directly obtained from edible plant cells, but may be derived from plant materials.The definition should be restricted to substances that are suitable for use as a food source. Materials listed as food ingredients, GRAS substances and food additives all fall within this definition. Fiber from microbial cells (e.g., yeast cell wall glucans) or products from non-edible plants that are produced to meet FDA requirements as legal food ingredients would be acceptable.

 

Should the definition include both a chemical and physiological component?

 

Yes. Both are already included in the definition. If both are not required, then classes of compounds allowed to be called dietary fiber could conceivably be broadened to include hormones and other biologically active molecules of non-saccharide or lignin origin.

 

In conclusion, the CRA supports broadening the analytical methodology to include soluble dietary fiber. New food ingredients are available to food formulators that show physiological benefits of dietary fiber but are excluded because they are not recovered with the official analytical method.

Jennifer Snyder, Director of Technical Affairs
Corn Refiners Association, Inc.

 

 

Committee Responses:


Good points. – Mary Ellen Camire


A nicely structured series of answers.  Stuart Craig

These comments represent very thorough responses to some questions Dennis Gordon has raised in his letter to colleagues. How we are going to define soluble fiber remains a critical question. – Betty Li

 

Thank you for these excellent comments. – Dennis Gordon

 


RETURN TO LIST OF COMMENTS


Home ~ History ~ Articles ~ Events ~ What's New ~ AACCnet

© Copyright 1999 The American Association of Cereal Chemists