August 5, 2022
Robert M. Califf, M.D. (CERTIFIED)
Commissioner of Food and Drugs
U.S. Food and Drug Administration
10903 New Hampshire Avenue
Silver Spring, MD 20993
Re: Source of Xanthan Gum, D-Mannose, and D-Glucuronic acid
Dear Dr. Califf:
Based on the testimonies from the 17K+ members in our corn allergy support groups reacting to xanthan gum, we require confirmation from the FDA, in writing, to present to food manufacturers related to the "source" of xanthan gum, D-Mannose, and D-Glucuronic acid; since many food manufacturers are claiming that the xanthan gum in their products is derived from sources other than corn. My own reaction to xanthan gum is swift and severe due to my IgE-mediated allergy to corn, since xanthan gum contains allergenic corn protein.
The NIH National Library of Medicine, PubChem CID 131750926, clearly defines xanthan gum as "Corn sugar gum."
https://pubchem.ncbi.nlm.nih.gov/compound/131750926
Code of Federal Regulation 21CFR172.695
Sec. 172.695 Xanthan gum.
"The food additive xanthan gum may be safely used in food in accordance with the following prescribed conditions:
(a) The additive is a polysaccharide gum derived from Xanthomonas campestris by a pure-culture fermentation process and purified by recovery with isopropyl alcohol. It contains D-glucose, [emphasis added] D-mannose, and D-glucuronic acid as the dominant hexose units and is manufactured as the sodium, potassium, or calcium salt."
https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/cfrsearch.cfm?fr=172.695
Glucose = blood sugar essential for the survival of all living organisms
D-Glucose = laboratory-created form of sugar produced from cornstarch (dextrose)
L-Glucose = laboratory-created form of sugar
Therefore, it appears the only source of xanthan gum is corn sugar produced from cornstarch (D-glucose), 21CFR184.1857.
Code of Federal Regulation 21CFR185.1857
Sec. 184.1857 Corn sugar.
"(a) Corn sugar (C6H12O6, CAS Reg. No. 50-99-7), commonly called D-glucose or dextrose, is the chemical [alpha]-D-glucopyranose. It occurs as the anhydrous or the monohydrate form and is produced by the complete hydrolysis of corn starch with safe and suitable acids or enzymes, followed by refinement and crystallization from the resulting hydrolysate."
https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=184.1857
Re: D-mannose and D-glucuronic acid
We would also appreciate confirmation from the FDA, in writing, confirming the source of these substances.
On behalf of corn-allergic citizens, we appreciate your attention to this critical matter.
Sincerely,
Diane H., Corn Allergy Advocate
Corn Allergy Advocacy/Resources
https://cornallergyadvocacyresources.blogspot.com/
Email: cornallergyinitiative@gmail.com
Twitter: @CornAllergy911
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