DOES IT make sense to add Vitamin C to Kool Aid or Tang?Is it rational to process 22 nutrients out of whole grain flour and put back only eight? Are vitamin-coated breakfast bars and breakfast drinks a reasonable alternative to a traditional breakfast?

If the Food and Drug Administration's new guidelines for food fortification had been developed 20 years ago, before such products were on the market, the answers to those questions might be "No." As things stand Kool Aid, Tang, Wonder Bread, Betty Crocker Breakfast Bars, Carnation Instant Breakfast and dozens of other nutrient-fortifiedfoods, especially certain cereals, are probably here to stay, though some of them may have to change their advertising.

FDA defines food fortification "the addition of discreetnutrients such as vitamins, mineral or protein to foods." FDA says the guidelines are meant to keep the fortification of foods from going berserk. Some people say it already has.

The major flow in the concept of improving diets throughfortification was addressed by Jim Hightower in his book, "Eat Your Heart Out." Discussing FDA's attempts in 1971 to triple the amount of iron in enriched white bread he wrote: "First a sizable portion of the population (especially males) would be getting too much iron, and something like 5 percentof the people could actually be endangered by the levels contemplated -- including the millions of Americans with sickle-cell anemia. Secondly, the very part of the population that needs the iron is not the most likely to goble weight-increasing bread to get it. Instead of boosting the horsepowerof everybody's bread, and boosting the price along with it,it makes more sense to spend some of those advertising dollars to educate the public and family physicians on the need for iron and its ready availablity in such foods as chili con carne with beans, hamburger, veal cutlets, lima beans, black strap molasses and sirloin steak -- not to mention liver."

The guidelines, which do not carry the force of law, started out six years ago as regulations, which could be enforced. But FDA's lawyers said there was no section of the law under which a product could be banned just because it was fortified contrary to rules set down by the agency. The lawyers also said the agency could not require a company to indicate on its label when the government didn't approve of the fortification.

The result is a document which calls for voluntary compliance from the food industry to "promote the rational addition of nutrients to food."

There are several categories under which FDA considers fortification "rational." One is to correct deficiency diseases in large segments ofthe population. This was the first use of food fortification: that addition of iodine to salt to prevent goiter, of Vitamin D to milk to prevent rickets are example.

The second is to restore nutrients lost in processing. One of the earliest examples was the effort to improve the nutritional quality of white bread, which had lost practically all of its nutrients through processing. But if the new guidelines hadbeen in existence when bread was first enriched, would bakers have been permitted to restore only three nutrients when many more were removed? (Iron, not originally in grain, wasadded to correct a deficiency in the population.) Accordingto the new guidelines, all nutrients lost in measurable amounts (2 percent of the Recommended Daily Allowances for 22 nutrients) through storage, handling or processing must be restored, not just those the manufacturer chooses to restore because they "are inexpensive and technologically simple to add."

The third category of enrichment deals with foods which are used as complete meal replacements. Liquid diets andspace sticks are examples. Fortification of such foods calls for the use of all the 22 vitamins and minerals included in the guidelines. The fortication is to be in proportion to the total caloric content of the food.

Another categoryconcerns itself with new foods, foods which are fabricated to mimic traditional foods. Fortification guidelines are designed to make the new food the nutritional equivalent, moreor less, of the traditional food.

In the past a distinction has been made between fortification (adding nutrients toa food which it did not possess in its natural state), and enrichment (restoring nutrients lost in processing). Under the new guidelines this distinction has been erased.

FDA has decided that "it is inappropriate to fortify snack foods such as candies and carbonated beverages.

"Their fortification could readily mislead consumers to believe that substitution with fortified snack foods would ensure a nutritionally sound diet."

According to an FDA official, the definition of snacks would also include foods such as potato chips and pretzels. But would it include cookies and cupcakes? No one is prepared to answer that question yet.

"A lot of this is going to be fought out in the courts," says a Department of Agriculture official. How the guidelines are interpreted could have a direct bearing on the fortified "breakfast bars" which some schools use in place of traditional foodsfor their breakfast programs.

Two years ago USDA tried to ban these high-sugar, high-fat, fortified donuts, cupcakesand similar confections which had been conceived under a previous administration as replacements for servings of fruit and bread or cereal. Opponents of the products believe feeding such foods to children runs counter to nutrition education since children are unable to distinguish between the fortified versions and their look alikes (often called junk foods) which do not contain the added nutrients.

But lobbyinginterests convinced Congress that kids might go hungry without them. Rather than risk a fight with Congress, USDA has put the ban in limbo. The new guidelines might strengthen USDA's case.

The guidelines should prove helpful to the USDA in another fight. Assistant Agriculture Secretary Carol Foreman says they will prevent fortification of foods which have been banned from school vending machines under a regulation which takes effect July 1. Under that regulation soft drinks, certain candies and water ices cannot be sold in schools. In order to qualify as a food which can be sold in competition with the school lunch, the food must contain 5 percent of the Recommended Daily Allowance for one of eight nutrients. There has been some concern that manufacturers could simply fortify any of the non-acceptable products with 5 percent of just one nutrient, thereby qualifiying it for salein school. Foreman says such fortification, under FDA's guidelines, would be classified as irrational.

Since the guidelines do not contain a "grandfather clause," affecting products which are already on the market irrational or not theVitamin C in Kool Aid is likely to stay. As are Total, King Vitamin, Speical K and Product 19, which contain 100 percent of the minimum daily requirements for some nutrients. While cereals eventually will be the subject of a separate setof guidelines, Taylor Quinn, associate director for compliance in the FDA's Bureau of Foods, says such fortification is"not rational. One hundred percent fortification of cerealdoesn't fit the guidelines. You're just selling a vitamin pill in cereal form and that's why they are labeled an multi-vitamin supplement."

But the new guidelines may take their toll on certain kinds of advertising: "It is inappropriateto make claims about the addition of nutrients to a food that has been fortified to make it nutritionally equivalent tothe food it replaces." Will that mean Tang cannot imply that because of its Vitamin C content it is suitable replacement for orange juice?

The Federal Trade Commission has no answers to those questions yet but it seems fairly certain thata company like Hoffman-LaRoche would no longer be able to advertise to the trade: "Your fruit drink or juice, fortifiedwith 60 milligrams of Vitamin C per serving can be promotedas a nutritional substitute for traditional breakfast juices."

FDA's position lies somewhere between Hoffman-LaRoche and that of nutritionist Carole Christopher who believes that "despite assurance from food technologists we simply do not know enough to ensure the nutrient adequacy of foods fabricated to replace conventional foods."

". . . the list of nutrients specified . . . should be considered subject to modification as new nutrition knowledge makes changes advisable. It is reasonable to anticipate that FDA will propose a number of U.S. RDA's for minerals, such as selenium, molybdenum, and chromium . . ." Since the original document was published six years ago minerals already have been added to the list: potassium and manganese.

Increased reliance on fabricated and refined foods fortified with a limited number of nutrients, has scientists worried. According to Dr. Walter Mertz, chairman of the Nutrition Institute at the Departmentof Agriculture: "In the future we will not be able to rely any more on our premise that the consumption of a varied, balanced diet will provide all the essential trace elements, because such a diet will be very difficult to obtain for millions of people . . ."