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The FDA is taking comments on label proposals until August 1 (see info at end of post).  Here’s mine on voluntary vitamin D labeling.

July 17, 2014

TO:  FDA

FROM:  Marion Nestle, Professor, New York University

RE:  Proposed revision to Nutrition Facts Panel: VITAMIN D

This is to argue against permitting food companies to voluntarily label added “Vitamin” D on the Nutrition Facts panel.  Doing so will not promote—and may possibly harm–public health.

Rationale

• “Vitamin” D is not a vitamin; it is a hormone synthesized by the action of sunlight on skin.  For this reason alone, it does not belong on the food label.
• Vitamin D fortification must be understood as a form of hormone replacement therapy.   As such, it raises questions about efficacy, dose, and side effects that should be asked about all such therapies.
• Fortification and supplementation provide hormone Vitamin D by the oral route.  This is not physiological.  Active vitamin D is synthesized in the body through a series of reactions that begin with the action of sunlight on skin.  Sunlight on skin produces ample Vitamin D, is regulated to promote synthesis as needed and avoid toxicity, and may lead to synthesis of other useful biological components; the unphysiologic oral route does not produce the same benefits.[i]
• As a hormone, Vitamin D is found naturally in very few foods (e.g., fish); in them, it is present in small amounts.  It is present in most foods as a result of fortification.
• Permitting Vitamin D to be listed on food labels will encourage fortification, undoubtedly of foods that would not otherwise necessarily be recommended.  To cite just one example: Yum Bunny Caramel Milk Spread fortified with vitamin D at 10% of the DV.  This product is half sugars by weight, marketed as “a good source of calcium and vitamin D,” and clearly aimed at children. See: http://www.yumbunny.com/about-us.   Whether such products should be considered “good sources” also deserves scrutiny.
• The U.S. Preventive Services Task Force concludes that evidence is insufficient to determine how Vitamin D supplementation (and, therefore, fortification) affects fracture incidence.[ii]^,[iii],[iv] 
• Data from the Women’s Health Initiative also are consistent with largely inconclusive findings about hormone Vitamin D supplements and bone health.[v]
• The Institute of Medicine (IOM) does not consider deficiency of Vitamin D to be a serious problem in the United States, except among certain population groups.  Instead, because of widespread fortification and supplementation, it is concerned about the possibility of adverse consequences from overconsumption through supplementation or fortification.[vi]
• Many scientific debates about hormone Vitamin D are as yet unresolved.[vii]^,[viii]  
• The lack of compelling research has permitted Vitamin D to become “trendy.”  It is advertised on boxes of fortified cereals, has its own pro-supplement advocacy group, and generates millions in annual supplement sales.[ix]

In the absence of stronger evidence for benefit from fortification, and some evidence for possible adverse consequences, the FDA should not contribute to further commercialization of this misnamed hormone by permitting it to be listed on food labels.

References

[i] Wacker M, Holick MF.  Sunlight and Vitamin D: A global perspective for health. Dermato-Endocrinology 2013;5(1):51–108.

[ii] Cranney A, Horsley T, O’Donnell S, Weiler H, Puil L, Ooi D, et al.  Effectiveness and safety of vitamin D in relation to bone health. Evidence Report/Technology Assessment No. 158. Rockville, MD: Agency for Healthcare Research and Quality. 2007.  http://www.ncbi.nlm.nih.gov/books/NBK38410. Accessed February 5, 2013.

[iii] Chung M, Balk EM, Brendel M, Ip S, Lau J, Lee J, et al  Vitamin D and calcium: a systematic review of health outcomes. Evidence Report/Technology Assessment No. 183. Rockville, MD: Agency for Healthcare Research and Quality. 2009.  http://www.ncbi.nlm.nih.gov/books/NBK32603/. Accessed February 5, 2013.

[iv] Chung M, Lee J, Terasawa T, Lau J, Trikalinos T. Vitamin D with or without calcium supplementation for prevention of cancer and fractures: an updated meta-analysis for the U.S. Preventive Services Task Force. Ann Intern Med. 2011;155(12):827-38.

[v] Prentice RL, Pettinger MB, Jackson RD, Wactawski-Wende J, LaCroix AZ, Anderson GL, et al.  Health risks and benefits from calcium and vitamin D supplementation: Women’s Health Initiative clinical trial and cohort study.  Osteoporosis Int.  2013;24(2):567-580.

[vi] Institute of Medicine.  Dietary Reference Intakes: Calcium, Vitamin D.  Washington, DC: National Academies Press, 2011.

[vii] Rosen, Clifford J,  Abrams, Steven A,  Aloia John F. et al.  IOM Committee members respond to endocrine society vitamin D guideline. J Clin Endocrinol Metab. 2012;97:1146-1152.

[viii] Holick, Michael F,  Brinkley Neil C, Heike, A et al  Guidelines for preventing and treating vitamin D deficiency and insufficiency revisited.  J Clin Endocrinol Metab. 2012;97:1153-1158.

[ix] Much growth in vitamin sales driven by vitamin D.  Nutr Business J. 2009;14(6/7):5.

Here’s how to file comments:

The proposed revisions are to:

• Nutrition and Supplement Facts Labels
• Serving Sizes 

The FDA makes it very easy to file comments. It provides:

• All necessary information in one place.
• A short guide and checklist

File comments here

• Nutrition and Supplement Facts Label: Docket FDA-2012-N-1210  Comment here now
• Serving Sizes: Docket FDA-2004-N-0258  Comment here now

Politico ProAg’s Helena Bottemiller Evich has been reporting on the School Nutrition Association (SNA) meeting in Boston this week (and see the video conversation with her editor, Jason Huffman, about the meeting).

One of her points: from the kinds of junk-food products exhibited, you would never know that the SNA was at war with the White House over USDA’s nutrition standards for school meals (see my previous posts).

As she explains, food companies have had no problem coming up with look-alike products that meet USDA standards:

More than 400 exhibitors showed off their innovations designed to meet the Department of Agriculture’s new regulations…PepsiCo, which owns Tropicana, Quaker and Lays, has a long list of products that meet the new rules, including Reduced Fat Doritos and Cheetos, Stacy’s Pita Chips and Munchies. Windsor Foods, which specializes in food service, has come up with whole grain-rich egg rolls that the company says kids love.

General Mills displayed a modified version of Chex Mix, a whole grain Betty Crocker cookie and a Cinnamon Toast Crunch cereal bar: “Snacks so good, kids won’t know they’re nutritious,” according to the marketing flyers.

…while the changes to lunch standards may be giving many school nutrition professionals fits, the food manufacturing industry is drooling over the opportunity to gain more sales inside what has been described as the nation’s largest restaurant: The school lunch program serves 30 million kids each day and represents a $30 billion per year market for the food industry, according to the Center for Science in the Public Interest.

…SNA benefits from the food industry’s enthusiasm in school lunches. The largest chunk of the group’s revenue is generated at its annual conference, which brought in $4.7 million in 2012. The association charges $15,000 to sponsor an education session track featuring a company representative and $20,000 to put company logos on hotel key cards.

Evich quotes Michele Simon, who also attended the meeting.

Walking through that hall, it’s very hard to see where the changes are,” she said. “It’s still pretty appalling to see the types of junk food that can pass as acceptable food for school meals. It seems like there’s a disconnect between the uproar over the improved guidelines and all these vendors who seem to have no problem meeting them.”

Michele sent me a photo of one such product.

For photos of other such items, see Michele Simon’s other images on Time Magazine’s site, and Nancy Huehnergarth’s collection of what she calls “The Good, the Bad and The Ugly Food Exhibits.”

To understand what this is about, take a look at the Public Health Advocacy Institute’s report on Copycat Snacks in Schools.  The “better for you” versions are sold in schools, but you can hardly tell the difference between those and the “not so good for you” commercial versions from the nearly identical packages.

How can food and beverage companies get away with this?  This is the result of USDA’s setting nutrient-based, rather than food-based standards for school meals.  Setting nutrient standards allows food companies to tweak the formulas to give the USDA what it requires.

Is a slightly “better for you” option necessarily a good choice?  Surely, schools can do better.

I always am interested in Michele Simon’s provocative reports.  Her latest, Whitewashed, is no exception.  It’s about how the government promotes dairy foods, no matter what kind or where they appear.

Read her blog post here.

Download the full report here.

Read the executive summary here.

Here’s are some of the surprising (to me) findings detailed in the report:

• About half of all milk is consumed either as flavored milk, with cereal, or in a drink;
• Nearly half of the milk supply goes to make about 9 billion pounds of cheese and 1.5 billion gallons of frozen desserts–two-thirds of which is ice cream;
• 11 percent of all sugar goes into the production of dairy products.

Where the government enters the picture is through the “checkoff programs” for promoting milk and dairy.  These are USDA-Sponsored programs, paid for by dairy farmers through checkoff fees, but run by the USDA.

U.S. Department of Agriculture employees attend checkoff meetings, monitor activities, and are responsible for evaluation of the programs. The U.S. Supreme Court has upheld the legality of the checkoff programs as “government speech”, finding: “the message … is controlled by the Federal Government.”

The report has some interesting findings about the checkoff.  Although checkoff funds are supposed to be used for generic marketing, the dairy checkoff helped:

• McDonald’s make sure that dairy foods play an important role in product development.
• Taco Bell introduce its double steak quesadillas and cheese shreds.
• Pizza Hut develop its 3-Cheese Stuffed Crust Pizza and “Summer of Cheese” ad campaign.
• Dominos add more cheese to its pizzas as a result of a $35 million partnership.
• Domino’s “Smart Slice” program introduce its pizza to more than 2,000 schools in 2011.
• Promote “Chocolate Milk Has Muscle” and “Raise Your Hand for Chocolate Milk.”

I like dairy foods, but should the government be doing this?

I read about General Mills’s introduction of non-GMO Cheerios back in January, but didn’t get around to looking for them until this weekend.

I was expecting to see something like this (thanks Fooducate):

Instead, the information is tucked into a side panel. 

This may explain why General Mills is complaining that the non-GMO is not doing a thing to boost sales of Cheerios.  If anything, sales are “down somewhat.”

And here’s a good one: According to one professor, the non-GMO Grape Nuts and Cheerios are going to be less nutritious than the GMO versions.

Post Foods’ new non-GMO Grape Nuts (click here ) no longer include Vitamin A, vitamin D, vitamin B12 or vitamin B2 (Riboflavin)*, while the new non-GMO Original Cheerios no longer have Riboflavin on the ingredients list (the old version has 25% of the daily value in a 28 g serving while the new version has 2% of the DV).

How come?  It’s hard to find non-GMO vitamins (who knew?).  Vitamins, it seems are often produced from genetically engineered microorganisms, or from microbes growing in fermentation tanks that are fed a nutrient mix that contains ingredients from GM sugar beets or corn.

Should we be worried about nutritional deprivation among Cheerios eaters?

Cheerios are essentially a vitamin pill wrapped in rapidly absorbable starch.

The ingredients: whole grain oats, corn starch, sugar, salt, tripotassium phosphate, wheat starch.

Everything else is added vitamins.

Personally, I prefer my cereals with no added vitamins (they taste bad).  And I doubt they make much difference to health.

Whether non-GMO will have a noticeable effect on sales of Cheerios remains to be seen.

If General Mills doesn’t advertise the change, it can’t expect non-GMO to boost sales.

Curious, no?

Once again, Congress—under pressure from lobbyists—is micromanaging USDA’s food assistance programs.

This time it’s the WIC program (Special Supplemental Program for Women, Infants, and Children).

The lobbying is coming from the National Potato Council, which wants—no surprise—white potatoes to be included the list of foods approved for purchase with WIC benefits (the “WIC Package”).

I love potatoes but they don’t need to be in WIC.

Here’s what this is about.

The WIC Food Package

This is designed to meet the special nutritional needs of at-risk low-income pregnant, breastfeeding, non-breastfeeding postpartum women, infants and children up to five years of age.  Rules published in the Federal Register in 2007 aimed to promote long-term breastfeeding by providing WIC participants with a wider variety of foods including fruits and vegetables and whole grains (see summary here).

Although the rules allow states considerable flexibility, they specifically exclude white potatoes.

The New York State WIC package, for example, allows any variety of fresh vegetables and fruits except white potatoes (sweet potatoes and yams are allowed).

These rules are the result of an Institute of Medicine study released in 2005.  This study found that WIC participants already ate plenty of white potatoes.  The report said it would be better for WIC to encourage consumption of a wider variety of vegetables.

Potato industry lobbying

For the last five years, the potato industry has been lobbying to include white potatoes in the WIC package.

Potato lobbyists are active these days.

For example, the Maine potato lobby succeeded in getting Congress to tell the USDA that it could not set any limits on the number of times per week that white potatoes could be served in school lunches.  That ploy worked and this one may work too.

The National Potato Council lobbyists induced Congress to add a clause to the 2014 omnibus appropriations bill.  When President Obama signed that bill on January 17, he directed the USDA to allow all varieties of fresh, whole, or cut vegetables to be included.  Translation: white potatoes, and French fries at that.

If the USDA fails to comply, Agriculture Secretary Tom Vilsack must submit a report to Congress explaining why not.

The National Potato Council makes this statement: “This action sends a clear message to USDA that it is obligated to base its nutritional policy on the latest nutritional science, which calls for an increase in starchy vegetable consumption for all Americans, including WIC mothers and children.”

It does?  I’m not aware of such science.

The Institute of Medicine is currently reviewing the WIC package and I seriously doubt that it will find a deficiency of starchy vegetables in American diets.

This is about getting potato growers a chunk of taxpayer money spent for the WIC program.

Why should anyone care?

If Congress caves in on white potatoes, it will open a Pandora’s box of pressures from lobbyists representing every food product currently excluded from the WIC package.

If lobbyists for white potatoes succeed, can those for “fruit”-flavored cereals and sports drinks be far behind?

The WIC program has always focused on encouraging recipients to consume foods that will best promote their own health and that of their children.

It would be better for WIC recipients—and a lot better for American democracy—if the potato industry stopped manipulating Congress and interfering with USDA nutrition programs.

As Food Navigator-USA puts it, “No, wheat does not make people fat and sick.”

Bread lover that I am, I consider recent research to be giving us good news.

Food Navigator is referring to a review of research on whole wheat and health just published in the Journal of Cereal Science of all places.  The authors conclude that unless you have celiac disease or wheat allergies, eating whole-wheat foods is good for you.

In fact, foods containing whole-wheat, which have been prepared in customary ways (such as baked or extruded), and eaten in recommended amounts, have been associated with significant reductions in risks for type 2 diabetes, heart disease, and a more favourable long term weight management. Nevertheless, individuals that have a genetic predisposition for developing celiac disease, or who are sensitive or allergic to wheat proteins, will benefit from avoiding wheat and other cereals that contain proteins related to gluten, including primitive wheat species (einkorn, emmer, spelt) and varieties, rye and barley…Based on the available evidence, we conclude that whole-wheat consumption cannot be linked to increased prevalence of obesity in the general population.

The authors find little evidence in support of popular myths:

• Proliferation of wheat products parallels obesity and is causally related.  No, it does not.
• Wheat starch differs from starches in other foods in especially undesirable ways.  No, it does not.
• Whole wheat bread has a higher glycemic index than sugar.  No, it does not.
• Wheat contains opioids that make people addictive. No, they do not.

In the meantime, the FDA has been working on updating its 2006 guidance to industry about how to label statements about whole grains. The agency has been conducting research on how consumers judge:

• Food products, including nutritional attributes, overall healthiness, and health benefits.
• Labeling statements in terms of their credibility, helpfulness, and other attributes.
• Terms and statements such as “Made with Whole Grain”, “Multi-Grain”, and “100% Whole Wheat.”
• Whole grain statements beyond the scope of the statements themselves (i.e., halo effects).
• How whole grain statements influence consumer use of the Nutrition Facts.

Can’t wait to see the results.  They ought to be out soon.

I’ve written frequently about the “natural” issue—what’s natural in foods and what’s not—on this site and now must do so again.

Yesterday, FoodNavigator reported that the FDA “respectfully declined” to decide once and for all whether foods labeled “natural” can include GMOs.

To summarize what brought this on:

• Judge Yvonne Gonzalez Rogers referred a lawsuit over “all-natural’ claims on GMO-containing Mission tortilla chips to the FDA to decide whether GMO-containing products can be considered “natural.”
• So did two other judges in cases involving Campbell Soup and General Mills Kix cereal.

The FDA’s letter to the three judges says the agency has to make decisions like this in the context of rulemaking, not litigation.

So how about making a decision about what “natural” means once and for all?

Not a chance.  The FDA says it has better things to do:  “Because especially in the foods arena, FDA operates in a world of limited resources, we necessarily must prioritize which issues to address.”

Back to court, this one goes, or so it seems.

Two today:

General Mills: GMO-free Cheerios

General Mills says it will make a GMO-free version of its Cheerios cereal.  This is surprising because it says Cheerios’ oats have never been GMO.   Now, it will take extra trouble—and, no doubt, charge more—to make sure the GMO and non-GMO sugars and corn don’t mix.

USDA deregulates 2,4-D herbicide for GMOs

The USDA released its draft Environmental Impact Statement:

as part of its review to determine whether to deregulate genetically engineered (GE) corn and soybean plants that are resistant to several herbicides, including one known as 2,4-D.  [USDA] APHIS is performing an assessment of these GE plants, while the Environmental Protection Agency (EPA) is conducting a concurrent review of the related herbicides.

…Dow AgroSciences’ GE corn and soybean plants are the first developed to be resistant to 2,4-D and are intended to provide farmers with new plants to help address the problem of weeds that have developed resistance to other herbicides.

Dow, which filed the petition for this action, is pleased.

Is 2,4-D safe?  The USDA says yes.

The National Pesticide Information Center sort of says so too, except that it lists plenty of reasons for concern, “possibly carcinogenic” among them.

Earth Justice points out that this action will allow farmers to douse fields with 2,4-D:

The potent and toxic 2,4-D has been linked to many human health problems. It also is likely to harm non-genetically engineered crops in neighboring fields, threaten endangered species, and ultimately lead to the development of weeds that are resistant to it, leading to even more problems.

Even more reason to buy and promote organics!