Last week when Dr. David Kessler, commissioner of the Food and Drug Administration, explained the government's new food labeling proposals, he compared the existing jargon to Alice's conversation with Humpty Dumpty on the meaning of "glory" in Lewis Carroll's "Through the Looking Glass."

"When I use a word," Humpty says, "it means what I choose it to mean -- neither more nor less."

Alice wasn't happy with Humpty's ability to make words mean so many things. And, likewise, Dr. Kessler has not been happy with the food manufacturers' elastic meanings for words like "% fat free," "No cholesterol," "fresh," and "lite."

"When the new label appears, words will no longer simply mean what marketers want them to mean," he promised. "Words will have consistent meanings -- meanings the American public can understand."

But before the proposals even got a federal docket number, food industry pressure groups were churning out press releases and complaining that parts of the proposal are "misdirected and misleading," "overly stringent" and will have a "chilling effect on industry's ability to create and market innovative new products."

If they succeed in weakening the regulations, Dr. Kessler's view of the new label could become as much a fairy tale as Lewis Carroll's story. Industry, consumers and consumer groups have 90 days to comment after the proposal is published in the Federal Register. (See box, 8D.) All final changes in the &r; proposals must be made by Nov. 8, 1992, according to the Nutrition Labeling and Education Act. Although the law did not require labels on meat and poultry products, the Department of Agriculture has also issued compatible labeling regulations. Revised labels will start showing up in grocery stores after May 8, 1993.

Currently, only about 60 percent of all processed foods carry nutrition labels. Nutrition labeling has been voluntary unless a food made a nutrition claim or was fortified with vitamins or minerals, but the proposal would make nutrition labeling mandatory for most processed foods. Most spices, small packages (generally those no larger than a package of Life Savers), restaurant food and food produced by small businesses would be exempt.

Key elements of the proposal include standardization of serving sizes, definition of descriptive terms so consumers can count on the meanings from product to product and control of health claims allowing only those that have been scientifically documented. The new labels would disclose the amount-per-serving for total calories, calories from fat, total fat, saturated fat, cholesterol, total carbohydrates, complex carbohydrates, sugars, dietary fiber, protein, sodium, vitamins A and C, calcium and iron.

But other parts of the proposal have become controversial -- serving sizes, terms describing nutrients and some health claims.

Serving size

Food manufacturers have determined their own serving sizes and this free-for-all has resulted in what critics call unrealistic serving sizes, such as putting two pretzels in a package and labeling it as 1 1/2 servings. The labeling act requires FDA to base serving size on an "amount customarily consumed." If a package contains less than two servings, it will be considered a single serving. For example, the proposed serving size for a soft drink is 8 1/2 ounces. Therefore, a 12-ounce soda can, currently two servings, now will be one.

FDA says new serving sizes are based on what people really eat, but controversy has arisen because the servings are based on 10-year-old data. The reason: The General Accounting Office recently found that the USDA's most recent food consumption survey was flawed by mismanagement, reporting bias and a 34 percent response rate which the GAO said "may not be !c representative of the U.S. population."

The proposal establishes 131 standard serving sizes for some 17,000 food products. But a spokesman for the Grocery Manufacturers of America says people don't buy in standard serving sizes, they buy products. And products differ. The GMA's Jeffrey Nedelman says the industry will have to work with the FDA over the next year to adjust the recommended serving sizes.

"Food comes in all shapes and sizes," he says. "For example, a muffin can come in 2 ounces or 4 ounces." Under an FDA proposal setting standard muffin serving size as 2 ounces, a 4-ounce muffin would be considered two servings -- "even though consumers would probably eat the whole thing. It's silly. Most people think of one muffin as one serving."

Just how light is 'lite'?

A "dictionary" of 22 terms has been created to define terms that have become meaningless during the past decade. For example, olive oil has been labeled as "light" or "lite" when it was merely light in color. Under the proposal, light may be used only if the product has a third fewer calories than a comparable product.

But the industry isn't happy with some of these definitions. The loudest objections are coming from the International Food Information Council, a non-profit organization funded by food and beverage companies. Spokeswoman Claire Regan says the FDA definition for low fat -- 3 grams or less of fat per serving and per 100 grams of food -- is "overly stringent" and would eliminate use of this term on foods that have been substantially reduced in fat.

"There are lower fat sour creams on the market that wouldn't fit the definition," she says. "A typical 2 tablespoon serving is 3 grams, but a 100 gram portion is 7 tablespoons. You wouldn't use 7 tablespoons unless you were making a recipe for four or more. Not all foods are eaten in larger servings."

To provide consumers with a variety of options, she says fat descriptors should be in four categories: low fat (4 grams per serving), very low fat (no more than 2 grams per serving), fat-free (no more than 1/2 gram per serving) and reduced fat (at least one-third fat reduction).

"The proposed regulations also restrict the use of the term 'light' on food labels," she says. "Light should include foods modified ,, to be lower in fat, independent of calories. Foods reduced in fat by at least one-third of their full-fat counterparts should qualify for the term 'light in fat.' "

Health claims

Until 1984, when FDA relaxed its position, if a food made health claims it was considered a drug and had to submit medical studies to back its claims. Under the new law, FDA was instructed to examine evidence on 10 relationships between nutrients and disease. The proposals allow manufacturers to claim four food and health links -- calcium and osteoporosis, sodium and hypertension, fat and cardiovascular disease, fat and cancer. Two others -- fiber and heart disease and fiber and cancer -- have been postponed for further study.

The GMA's Nedelman agrees that FDA should allow the fiber claims. The chief beneficiary would be cereal manufacturers, especially Kellogg's which is credited with starting the spate of health claims in the mid-'80s when it cited the NCI's suggestions to eat a high-fiber diet in order to prevent certain cancers on its All-Bran cereal.

"If the evidence is good enough for the National Cancer Institute, it ought to be good enough for the FDA," Mr. Nedelman says.

Meanwhile, consumer groups are worried that the manufacturer's complaints may result in a delay.

"We fear that the food companies will run back to Capitol Hill and ask for an extension on all these regulations," says Bruce Silverglade, legal director for the Center for Science in the Public Interest. "Then the public will have to wait even longer for nutrition labeling. There is no justification to extend the compliance deadline. The sooner we get these new food labels, the sooner will can start to save money on health care and begin to prevent heart disease and cancer."

How to comment on labels

Food manufacturers and organized consumer groups aren't the only ones who can affect the proposed food labeling regulations. Individual consumers can comment, as well.

Consumers need submit only one copy of their comments; all others must submit in duplicate. Include a docket number; deadline is 90 days after publication in the Federal Register.

* Comments on the Food and Drug Administration proposals should be sent to: Dockets Management Branch, HFA-305, Food and Drug Administration, Room 1-23, 12420 Parklawn Drive, Rockville 20857. The docket number was not available at press time. To get the number, call the FDA Dockets Management branch at (301) 443-1544.

* Comments on the USDA proposals should be sent to: Policy Office, ATTN: Linda Carey, Food Safety and Inspection Service Hearing Clerk, Room 3171 South Building, Food Safety and Inspection Service, U.S. Department of Agriculture, Washington, D.C. 20250. Refer to Docket No. 91-006P. Oral comments, as provided for in the Poultry Products Inspection Act, may be directed to: Charles Edwards, FSIS, (202) 205-0080.