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Michael Taylor, FDA’s associate commissioner for foods, gave a major speech yesterday at the George Washington University School of Public Health.

In it, he talked about the origin and effectiveness of HACCP (Hazard Analysis and Critical Control Point) controls for preventing food safety problems.  HACCP, he explained, works just like other aspects of public health practice.  It requires:

• understanding the specific food safety hazards that could affect a particular food production operation,

• devising and implementing scientifically validated controls to minimize the hazards,

• monitoring the implementation of preventive controls to verify effectiveness, and

• making corrections and adjustments as needed, based on experience.

He then went on to say how FDA plans to put the Food Safety Modernization Act into action:

We are well on our way to developing a proposed produce safety rule that addresses areas such as employee hygiene, water quality, soil amendments, and animals in the growing area, as FSMA mandates.

In food facilities, such as processing and packaging plants, we will be proposing rules that are grounded in the widely embraced principles of preventive process control for food safety, similar to HACCP.

The law requires each facility to… (1) evaluate the hazards that could affect food safety, (2) specify what preventive steps, or controls, to put in place to minimize or prevent these hazards, (3) specify how the facility will monitor these controls to ensure they are working, (4) maintain routine records of monitoring, and (5) specify what actions the facility will take to correct problems that arise.

For example, in a facility that produces peanut butter, factors such as  ingredient safety, sanitation, and cross contamination would have to be considered. After the outbreak of Salmonella typhimurium in peanut butter in 2008 and 2009, which caused 714 cases of illness, the company had to reevaluate the hazards in its facilities so this wouldn’t happen again.

Such review and correction – and a sharp focus on specific hazards – will become the norm under a system of preventive controls.

Taylor outlined FDA’s vision for preventive controls from farm to table.  Now, if Congress will just give it the resources to do all this, we might actually have a food safety system that functions.

A reader, Jeff Harpell, comments on my scheduled talk in Barcelona:

I lived in Barcelona last year and the year before….While they are becoming more influenced by American fast food, having both parents work, and buying more from one stop food markets, the lifestyle, social support systems, i.e., healthcare and eating habits still are very different from the USA

….I suspect that the Catalonians are concerned about their citizens’ heading down a path of bad eating habits and how to prevent them. Any thoughts to share?

Three first impressions:

1.  The tourist bureau on La Rambla gives out a free city map courtesy of McDonald’s.  The map helpfully identifies the location of all of the McDonald’s outlets in Barcelona, and its such a relief to know that you don’t have to go far to find one.  I counted at least 10.

2.  The Carrefour supermarket has a meat section unlike any supermarket meat section in the United States. Those unwrapped hams are not cheap (yes, that’s 79 Euros, nearly $140, but it’s a big ham).  Leaving the ham attached to the hoof is an interesting touch.  I can only imagine what the New York City health inspectors might say about them.

3.  The Boqueria open-air food market has the most beautiful cut fruit for sale—something like this would make getting those daily fruit servings a real treat.

More to come!

FDA’s program is generally limited to enforcing the Hazard Analysis and Critical Control Point—the internationally recognized food safety management system—by conducting inspections of foreign seafood processors and importers each year.

These inspections involve FDA inspectors reviewing records to ensure the processors and importers considered significant hazards, including those resulting from drug residues if the seafood they receive are from fish farms.

The inspectors generally do not visit the farms to evaluate drug use or the capabilities, competence, and quality control of laboratories that analyze the seafood.

• Aquaculture assessments have been limited by FDA’s lack of procedures, criteria, and standards. In contrast, the EU reviews foreign government structures, food safety legislation, the foreign country’s fish farm inspection program, and visits farms to ensure that imported seafood products come from countries with seafood safety systems equivalent to that of the EU.
• FDA’s sampling program does not generally test for drugs that some countries and the EU have approved for use in aquaculture. Consequently, seafood containing residues of drugs not approved for use in the United States may be entering U.S. commerce.
• FDA’s sampling program is ineffectively implemented. For example, for fiscal years 2006 through 2009, FDA missed its assignment plan goal for collecting import samples by about 30 percent.
• In fiscal year 2009, FDA tested about 0.1 percent of all imported seafood products for drug residues.
• FDA’s reliance on 7 of its 13 laboratories to conduct all its aquaculture drug residue testing raises questions about the agency’s use of resources.
• FDA has inspected 1.5 percent of Chinese seafood processing facilities in the last 6 years.

And Congress wants to cut FDA’s resources.  I have no doubt that the FDA could be more efficient but the scope of what it is expected to do with limited resources is beyond absurd.

From where I sit, the entire food safety system needs an overhaul and the problems with food imports are a good reason for doing that.

Sunday’s New York Times has not one but two articles about “functional foods,” those with something added over and above what’s in the food in the first place.

A front-page story, “Dessert, laid-back and legal,” describes brownies.  No, not brownies laced with marijuana.  This time they contain the sleep-inducing drug melatonin.

The brownies, according to the Times, contain just as much melatonin as are found in drug pills but are cheaper and can be purchased with food stamps (another reason for taking a look at the whole question of SNAP benefits?).

Since melatonin is a drug and not an approved food additive, the makers of these products are trying to get around the annoying FDA restrictions by marketing the brownies as “dietary supplements.”  Supplements, by order of Congress when it passed the Dietary Supplement Health and Education Act (DSHEA) of 1994, do not have to meet FDA’s rigorous scientific criteria for safety or efficacy.

DSHEA applied to supplements, not foods, but the FDA has chosen to regulate foods containing such additives by the weaker rules applying to supplements and to deal with them as a regulatory gray area.   Is melatonin a drug, a supplement, or in brownie from a food?  The FDA is going to have to decide this, and fast.

A much longer story in the business section, “Foods with benefits, or so they say” (in which I am quoted) focuses on the entire point of functional foods: the ability to put something in a product that allows you to market it using health and wellness claims.  Health claims sell food products.  People like buying products with a “health aura,” no matter how poorly the health claim is supported by science.  Science is irrelevant here.  Marketing is what’s relevant.

As I discuss in my book, Food Politics, until the early 1990s, the FDA did not allow health claims on food products.  Claiming a specific health benefit for a food, said the FDA, meant that the food was being marketed as a drug.  If a food was being marketed as a drug, it needed to prove safety and efficacy, something no food maker wanted to do.

When Congress passed the Nutrition Labeling and Education Act in 1990, it struck a deal with the food industry.  The industry was objecting that because Nutrition Facts labels required them to say what was bad about their products, they ought to be allowed to say what was good about them.  Congress agreed, and forced the FDA to review the science linking certain food ingredients to health benefits as a basis for permitting health claims.

The FDA approved some claims but rejected others.  The rejected companies took the FDA to court, and the courts mostly ruled in favor of the companies on the grounds of the First Amendment.  The FDA stopped trying to control unsupported health claims and only recently has taken then on again.

But as sales soar, federal regulators worry that some packaged foods that scream healthy on their labels are in fact no healthier than many ordinary brands. Federal Trade Commission officials have been cracking down on products that, in their view, make dubious or exaggerated claims. Overwhelmed regulators concede that they are struggling to police this booming market, despite recent settlements with makers of brands like Kellogg’s Rice Krispies and Dannon’s Activia, which the authorities say oversold their health benefits.

To the distress of international food marketers, the U.S. currently has much looser regulations about health claims than are available in Europe.  The European Food Safety Authority has been reviewing thousands of petitions for health claims on food products and turning most of them down as scientifically unsubstantiated.  That doesn’t stop American food makers from loading on the claims.

From the ivory tower in which I sit, the remedy is easy: don’t allow health claims on processed foods at all.  The claims are all inherently misleading, as would be obvious if you gave it a minute’s thought.

But if they aren’t worth much to you, they are worth plenty to the marketers of processed foods.  And that’s what this is really about.

Thanks to a reader, Sam Boutelle, I have now been introduced to the Cool School Café.  This is a company that markets special deals on processed food products to school food service directors:

Cool School Cafe® Manufacturer Alliance (CSCMA), founded in 1995, is an industry leader in School Foodservice marketing. CSCMA is a unique resource for you, SFS Directors and purchase decision-makers, to learn about food manufacturers serving the industry plus have the opportunity to earn valuable marketing support for their meal program.

The way this works is that your school joins the program, and CSCMA lets you know about manufacturers’ special offers.  You buy the stuff and get points for everything you buy.  You redeem the points for free stuff.  Clever, no?

And what kinds of products are targeting schools?  Try this, for example:

I’ll bet you never would have guessed that something like this could be a health food!  Zero grams trans fat!  Only 35% sugar by weight!

Let’s hear it for nutritionism in action.  All a company has to do to get its products into schools is to get them to meet USDA’s standards for nutrients.

You think USDA should change from nutrient-based to food-based standards?  Here’s all the evidence you need.

The Future of Food conference in Washington last week is now pretty much online (although I’m still having trouble with some of the links).  Much of it is well worth a listen, certainly Prince Charles’ thoughtful speech on sustainability, but also the one that I thought the most powerful—comments by Robert K. Ross, head of the California Endowment.

In the first 8 minutes of his talk, Dr. Ross explained that he comes to the issues discussed at the conference from the angle of public health and obesity, yet climate change, soil quality, hunger, and economic development are all wrapped up in the obesity issue.   Here is my paraphrase of what he said (with my emphasis):

If you care about these issues, you have to decide whether you are a group, network, or a movement.

Nothing short of a powerful movement will reverse the trends that are in front of us.

The tobacco battle is the proudest victory of public health, although not yet fully accomplished.

The scientific community first understood that tobacco was bad for health in 1921.  Hundreds of studies followed.  Yet it was not until 1965 that the Surgeon General first got permission for a warning label on cigarettes.  Only in the 1990s did we have policy and practice changes that included environmental incentives to drop the tobacco habit.

In other words, we have had a 100-year war on tobacco.

A side-by-side comparison of food and tobacco indicates that food, health, and sustainability are far more complex issues than tobacco.  We do not have 100 years to deal with these problems.

The tobacco wars were not about lack of scientific data.  They were and are a power issue.

The only way to confront power is to build a movement that wields power.

Science-based, evidence-driven policy wonks and researchers want more science.  But if you think you are in a policy debate and the other side thinks it is in a fight, you are not going to come out too well.

We need to bring as much rigor to the fight as we do to the science.

Food advocates: take careful note.

It used to be that the “soda wars” referred to Coke vs. Pepsi.  No more.  Today’s soda wars are fought on the health front, as more and more evidence links sugary drinks to obesity and other health problems.

The current issue of the New Yorker has an article by John Seabrook (in which I am briefly quoted) about Pepsi’s attempt to “health up” its snacks and drinks.

Seabrook’s article, “Snacks for a fat planet,” describes the extraordinary amount of money and effort Pepsi is spending to try to tweak its products to make them seem healthier.  His article doesn’t exactly give Pepsi a pass (as some of my readers have complained), but it does not really come to grips with how sugary drinks and snacks affect health or how Pepsi is marketing its products in developing countries.

That, no doubt, is why Pepsi has sent out a press release to reports that enclosed the complete article and suggested that reporters might be “interested in the company’s focus on its innovative approach to:”

• Reduce salt, fat and sugar across the portfolio – the New Yorker feature explains PepsiCo’s effort to re-shape natural salt so that it has more surface area, and, in turn, is perceived as “saltier” on the tongue – meaning they can maintain all the salty flavor in Lay’s but reduce overall sodium content
• Scale more drinks and snacks made with whole grains, fruit, vegetables and dairy to new markets – e.g. bringing vegetable-based gazpacho (perhaps with an edible whole grain spoon) to the U.S.
• Test new ingredients brought back from “treks” around the world – e.g. using a state-of-the-art robot in PepsiCo’s new Hawthorne, NY research lab to test botanicals and other natural ingredients from near and far – e.g. even secluded villages in the far East – to determine their impact on taste and viability for use in PepsiCo snacks and drinks (Do they intensify sweetness? Can they be a substitute for sugar? Do they have a particular healthful function?)

Score this one as a win for Pepsi.

Along with such pledges, Pepsi is aggressively marketing sodas to teenagers.  The San Francisco Chronicle reports on Pepsi’s new “social marketing” vending machines.

At a trade show in Chicago this week, PepsiCo rolled out a prototype interactive soda machine that lets you send a drink as a gift to a friend or a random stranger.

“Our vision is to use innovative technology to empower consumers and create new ways for them to engage with our brands, their social networks and each other at the point of purchase,” Mikel Durham, PepsiCo Foodservice’s chief innovation officer, said in a press release.

“Social Vending extends our consumers’ social networks beyond the confines of their own devices and transforms a static, transaction-oriented experience into something fun and exciting they’ll want to return to, again and again.”

But these kinds of marketing pushes are not confined to Pepsi.   Advertising Age reports that Joe Tripodi, Coke’s chief marketing officer of Coca-Cola explains the company’s growth strategy: focus on teenagers:

The company sees huge opportunities to grow colas, and the business as a whole, around the world in the next decade. Teen recruitment will be particularly important, as the company follows demographic trends.

“There was a time [a decade ago] when we walked away from teen recruitment and probably lost a generation of drinkers,” Mr. Tripodi said. “Parts of the world lost confidence in cola as the engine of growth. We’ve gotten that back in a big way. …When you look at the massive opportunity in so many huge countries in the world, that’s what energizes us and why we believe cola is still at its very early stages.”

And then there are partnership strategies. The latest is Sonic drive-ins’ campaign for Limeades for Learning. The campaign encourages eaters to vote for school projects like those that support physical activity.  Sonic promises to fund the projects with the most votes. The Limeades, by the way, are 620 calories (for a medium) or 950 calories (for a large).

Finally, for now, the Boston Globe reports that most Massachusetts voters support a sales tax on sodas if the money is used for some useful purpose.  But:

The American Beverage Association has been aggressively fighting taxes on soda, as cities and states across the country look for new tools to counter an obesity epidemic and raise revenue amid squeezed budgets. It has spent millions fighting initiatives that impose product-specific excise taxes on sugar-sweetened beverages and has been successful in nearly every attempt.

Expect more such public relations efforts superimposed on fundamental marketing techniques aimed at kids and fighting back on taxes and other attempts to limit soda intake.

How does this comport with the spanking new advertising guidelines to children or any of the previous pledges? Is sending a soda to a friend an activity or marketing? Or both?

http://www.sfgate.com/cgi-bin/blogs/techchron/detail?entry_id=87904

You might think that turning a deserted and trash-filled empty lot into an urban farm would please city officials, but not in Oakland CA.

Yesterday’s San Francisco Chronicle has a sobering article on the efforts of Novella Carpenter, author of the terrific Farm City (a book I use in my classes), to make her working farm legal.

To continue running her farm, Novella needed a conditional use permit which would cost about $2,500.  She got the money by raising it through her Ghost Farm blog.

The good news is that city officials are listening.

Oakland planning officials said they are about to embark on an ambitious plan  to revamp the zoning code to incorporate the increasing presence of agriculture  in the city.

The plan is to develop rules and conditions allowing anyone to grow  vegetables and sell produce from their property without a permit. The Oakland  plan would go beyond that of other cities, including San Francisco, because it  would also set up conditions for raising farm animals without a permit….Oakland’s rules have always allowed the growing of vegetables and raising  animals for personal use on residential property. But selling, bartering or  giving away what you grow is not legal without a permit. The new rules will  establish limits on distributing food, including food byproducts like jam,  without a permit.

Animals are likely to be the most contentious issue because neighbors tend to  be more bothered by bleating, honking, clucking and crowing. Complaints about  vegetables are rare.

I”m guessing other cities will have to start dealing with these issues if they haven’t done so already, not least because so many people want backyard chickens.

I’m growing salad and blueberries on my Manhattan terrace, but not enough to sell, alas.  Maybe next year!